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I was a long time smoker who, despite repeated attempts to quit using traditional means, was unable to do so. I have since switched from dangerous cigarettes to using a Nicotine based e-cigarette vaping devices, something that Public Health England states is 95 per cent less harmful than smoking a cigarette and which the Royal Australasian.
 I wish to formally register my opposition to the proposed amendments currently under consideration by the TGA in relation to the future treatment of Nicotine under Schedule 4, 6, and 7 of the Commonwealth Standard for the Uniform Scheduling of Medicines and Poisons (Poisons Standard) on the following grounds:
 Incoherent, inconsistent and illogical regulation which promotes cigarette use at the expense of less harmful e-cigarettes:
 The impact of these amendments being adopted would result in the diabolical situation that if approved, all Nicotine for human use (including Nicotine used in e-cigarette and vaping products) will only be available after an individual first obtains a prescription from a doctor and then makes a purchase through a licensed pharmacy. Cigarettes, the most dangerous way to consume Nicotine, and which are responsible for 18,000 preventable deaths in Australia each year, will be exempt from the changes and will continue to be freely available at over 20,000 locations without a prescription.
 Smoking rates in Australia are not dropping and we need to try something different:
 Despite some of the world’s strictest tobacco control measures, between 2014-15 and 2017-18 the daily smoking rate remained “relatively similar”, only declining from 14.5 per cent to 13.8 per cent. 
 Even with unprecedented tobacco control measures and continued increases in tobacco excise rates, the Government comprehensively missed its own target to reduce the smoking prevalence rate to 10 per cent in Australia between 2012 and 2018 (since extended to 2025). In contrast, since smoke-free alternatives have been available in overseas markets, cigarette sales have declined rapidly, including in Japan . For this target to be achieved will require a significant shift in thinking and a retranslation of foreign experiences by adopting a new approach including in New Zealand. 
 The solution is in adapting a New Zealand Regulatory Model
 New Zealand’s regulation of vaping and smokeless tobacco products seeks to strike a balance between protecting and preventing new users from starting to use Nicotine, whilst also supporting smokers to switch to a much less harmful product. 
 The New Zealand laws will : ban the sale of vaping products to under-18-year-olds; prohibit advertising of vaping products and smokeless tobacco; restrict the sale of flavoured vaping products and e-cigarettes to R-18 specialty stores; introduce a product safety system – which enables the Ministry of health to recall, suspend and issue warnings about vaping products.
 Conclusion
 Putting in place additional barriers to limit e-cigarette users access to Nicotine for vaping, whilst still allowing cigarettes to be freely available is illogical, inconsistent, and unsustainable. As an alternative, it would be proposed that a more suitable policy approach modelled on the New Zealand experience be embraced as a matter of urgency. Such an approach would produce the dual outcome of driving down smoking rates by giving Australia’s 3 million smokers a more sustainable pathway whilst also protecting against new uptake.
 Yours sincerely,

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