Could New Zealand’s response to our tobacco challenge1 be furthered by targeting tobacco product waste?

Delany et al in the Journal in recent months have proposed a new smokefree legislative framework that could progress Aotearoa New Zealand to being smokefree by 2025.2 The authors outlined a number of aspects of tobacco control that this proposed legislation would address, including a focus on the product and on the need to visually denormalise smoking.2 We think the targeting of tobacco product waste (TPW), concentrating on cigarette butts in particular, could provide a novel strategy to address these dual aims and also reduce an environmental nuisance.

Regulation of TPW has received modest attention in the tobacco control space.3 However, it is an issue, with claims of 4.5–5 trillion cigarette butts littered worldwide each year.4,5 Cigarette butts are a common (possibly the most common) item collected during urban litter surveys.6 This waste is not inert; rather it contains a myriad of noxious chemicals, many posing environmental4,5,7 and direct health hazards.8

Like secondhand smoke exposure, TPW on our streets, bus stops, parks and beaches is a visible reminder of tobacco use.9–12 For smokers, the exposure may serve to normalise further the already ritualised nature of TPW disposal.13–15 Unsurprisingly, the tobacco industry has long been concerned that public resistance to TPW would negatively impact the acceptability of smoking and be a target for anti-tobacco policy.9 In response the industry has funded/supported a number of strategies to address this risk to their business.9

A number of policies have been proposed/implemented internationally to reduce TPW and which may be relevant to New Zealand, including:3,5,9,13,16–19

• a fee/tax on TPW;
  
• designated TPW littering fines;
  
• product stewardship frameworks for tobacco products (modelled on examples like the mandatory take-back policy in the European Union for electronics);
  
• legislating for extended producer responsibility, eg, a Model Tobacco Waste Act;13
  
• cigarette pack or cigarette butt deposit schemes (similar to other products,16 and as trialled in Vancouver for cigarette butts9,17,18);
  
• cigarette butt collection/recycling,5,9,13,16–18 eg, as tried recently in Vancouver19 that creates new products and composts the residual tobacco;
  
• using bags or pouches for collecting TPW (for an example, see Figure 1).
  

Adopting similar strategies in New Zealand may also serve to further highlight the hazardous nature of tobacco products and reduce an environmental nuisance. As a corollary, they could, in a small way, help simultaneously progress towards the Smokefree 2025 goal1,2 and improve our street and recreational environments. Such an approach could be supported through greater local government action in addressing TPW.

None of this of course lets tobacco companies off the hook. Any strategy aiming to address TPW needs to primarily target the product and industry, not the individual who smokes. In fact, the tobacco industry has a long history of denying its role in TPW generation and management, preferring to shift the debate to one of individual responsibility and on blaming smokers for littering.9

So now imagine the following scenario, using cigarette butt pouches as a way to collect TPW:

"As a tobacco company, I have to pay to insert a pouch into each cigarette packet and have to pay the 10 dollar TPW levy to central government. I may decide to charge extra for each cigarette packet, to defray costs."

"As a smoker, I may be paying more for my cigarettes (or not, depending on whether the tobacco company decides to increase the cost). I have to collect my cigarette butts and put them into a pouch supplied in the cigarette pack. I’m facing the need to collect and carry around my used cigarette butts. To get a portion of the levy back, I have to take a full pouch to a pharmacy or my general practice and swap the pouch for a cheque and smoking cessation advice."

"As a pharmacy or general practice, I’m pleased to be involved with this health issue. I have the opportunity to, in the short-term, gain some revenue (I receive $4 of the levy for every full pouch collected) while promoting health and supporting people to quit. Every two weeks I send the collected and sealed pouches to a central depot that processes the litter in a safe and environmentally sound way. I’m engaging more often with my patients who smoke than I used to, and this is a great opportunity to help them."

The disagreeable nature of the task could actually be its most redeeming feature. It would internalise an externality–where the fact that people who smoke do not then want to do the transaction, simply highlights the cost borne by others who do not smoke. We will know that the pricing is right once we no longer see cigarette butts in the streets. Requiring all smokers to receive smoking cessation advice/support within this process may also help quit attempts and long-term quit success,20–22 thereby further contributing to the Smokefree 2025 goal.

Figure 1: Example of a cigarette butt collection bag or pouch.

However, there are caveats and cautions that will need thought. To start, with any TPW collection scheme, there would need to be due safeguards (including hygiene and safe collection)—albeit exchange programmes have been workable, effective and safe in New Zealand in the past (eg, needle exchange).23–27 Compensation for collectors would need to be enough to be financially viable, and we cannot, perversely, have windfalls to cigarette manufacturers from monies not uplifted by consumers and collectors—in effect, ‘bonds’ that go uncollected (which may inadvertently and paradoxically raise the profitability of tobacco).

There could be other risks too, with potential unintended consequences. Although there are reviews highlighting issues around implementing policy,28 local and international research or evaluation evidence to support such a TPW collection scheme (eg, around acceptability, likely interest, impact, costs, etc.) is sparse—albeit similar deposit/return schemes have been successful with other waste products (eg, glass bottles in Oregon and South Australia16). Clearly we have not begun to assess costs of administration or exactly how the supply chain for collection bags would work. Such practicalities need to be thoroughly considered.

Likewise, although any TPW collection also imposes a cost on tobacco companies, might arguably smokers bear the greatest burden, and thus does this approach implicitly support the ‘individual responsibility’ argument the tobacco industry relies on so heavily?9,16,29 Would such levies risk being passed onto smokers and create other problems, given the increasing resentment of existing excise tax increases?30

Alternatively, the tobacco industry could be made more directly responsible for its producing a product component (the filter) that offers no benefit in reducing the harm from smoking and creates a considerable environmental menace. Might a better strategy in fact be to simply impose a direct cost on tobacco companies (pro rata by market share) and recoup the costs of TPW collection and disposal?13 Funds could be used to meet costs currently borne by local authorities (and rate payers) and could also be used to support more direct cessation services.

We will need to assess evidence of wider impacts elsewhere (eg, shifts in attitudes towards smokers, tobacco industry or changes in smoking behaviours) where TPW management has been introduced, including accompanying costs and risks. It is too early to answer such questions; to date evaluations are still happening, eg, the City of Vancouver continues to evaluate its pilot project to recycle cigarette butts31—albeit meantime with reports there of barriers, although those obstacles have apparently been political rather than practical.32

So in short, we do not have answers yet. But we want to at least encourage the New Zealand health sector as a whole to start thinking about ways of developing solutions and undertaking robust costings. Regardless of options and their costs, the earlier these conversations happen, the better. Perhaps now it is time for us to begin to consider such novel approaches locally?

‍

Could New Zealand’s response to our tobacco challenge1 be furthered by targeting tobacco product waste?

Delany et al in the Journal in recent months have proposed a new smokefree legislative framework that could progress Aotearoa New Zealand to being smokefree by 2025.2 The authors outlined a number of aspects of tobacco control that this proposed legislation would address, including a focus on the product and on the need to visually denormalise smoking.2 We think the targeting of tobacco product waste (TPW), concentrating on cigarette butts in particular, could provide a novel strategy to address these dual aims and also reduce an environmental nuisance.

Regulation of TPW has received modest attention in the tobacco control space.3 However, it is an issue, with claims of 4.5–5 trillion cigarette butts littered worldwide each year.4,5 Cigarette butts are a common (possibly the most common) item collected during urban litter surveys.6 This waste is not inert; rather it contains a myriad of noxious chemicals, many posing environmental4,5,7 and direct health hazards.8

Like secondhand smoke exposure, TPW on our streets, bus stops, parks and beaches is a visible reminder of tobacco use.9–12 For smokers, the exposure may serve to normalise further the already ritualised nature of TPW disposal.13–15 Unsurprisingly, the tobacco industry has long been concerned that public resistance to TPW would negatively impact the acceptability of smoking and be a target for anti-tobacco policy.9 In response the industry has funded/supported a number of strategies to address this risk to their business.9

A number of policies have been proposed/implemented internationally to reduce TPW and which may be relevant to New Zealand, including:3,5,9,13,16–19

• a fee/tax on TPW;
  
• designated TPW littering fines;
  
• product stewardship frameworks for tobacco products (modelled on examples like the mandatory take-back policy in the European Union for electronics);
  
• legislating for extended producer responsibility, eg, a Model Tobacco Waste Act;13
  
• cigarette pack or cigarette butt deposit schemes (similar to other products,16 and as trialled in Vancouver for cigarette butts9,17,18);
  
• cigarette butt collection/recycling,5,9,13,16–18 eg, as tried recently in Vancouver19 that creates new products and composts the residual tobacco;
  
• using bags or pouches for collecting TPW (for an example, see Figure 1).
  

Adopting similar strategies in New Zealand may also serve to further highlight the hazardous nature of tobacco products and reduce an environmental nuisance. As a corollary, they could, in a small way, help simultaneously progress towards the Smokefree 2025 goal1,2 and improve our street and recreational environments. Such an approach could be supported through greater local government action in addressing TPW.

None of this of course lets tobacco companies off the hook. Any strategy aiming to address TPW needs to primarily target the product and industry, not the individual who smokes. In fact, the tobacco industry has a long history of denying its role in TPW generation and management, preferring to shift the debate to one of individual responsibility and on blaming smokers for littering.9

So now imagine the following scenario, using cigarette butt pouches as a way to collect TPW:

"As a tobacco company, I have to pay to insert a pouch into each cigarette packet and have to pay the 10 dollar TPW levy to central government. I may decide to charge extra for each cigarette packet, to defray costs."

"As a smoker, I may be paying more for my cigarettes (or not, depending on whether the tobacco company decides to increase the cost). I have to collect my cigarette butts and put them into a pouch supplied in the cigarette pack. I’m facing the need to collect and carry around my used cigarette butts. To get a portion of the levy back, I have to take a full pouch to a pharmacy or my general practice and swap the pouch for a cheque and smoking cessation advice."

"As a pharmacy or general practice, I’m pleased to be involved with this health issue. I have the opportunity to, in the short-term, gain some revenue (I receive $4 of the levy for every full pouch collected) while promoting health and supporting people to quit. Every two weeks I send the collected and sealed pouches to a central depot that processes the litter in a safe and environmentally sound way. I’m engaging more often with my patients who smoke than I used to, and this is a great opportunity to help them."

The disagreeable nature of the task could actually be its most redeeming feature. It would internalise an externality–where the fact that people who smoke do not then want to do the transaction, simply highlights the cost borne by others who do not smoke. We will know that the pricing is right once we no longer see cigarette butts in the streets. Requiring all smokers to receive smoking cessation advice/support within this process may also help quit attempts and long-term quit success,20–22 thereby further contributing to the Smokefree 2025 goal.

Figure 1: Example of a cigarette butt collection bag or pouch.

However, there are caveats and cautions that will need thought. To start, with any TPW collection scheme, there would need to be due safeguards (including hygiene and safe collection)—albeit exchange programmes have been workable, effective and safe in New Zealand in the past (eg, needle exchange).23–27 Compensation for collectors would need to be enough to be financially viable, and we cannot, perversely, have windfalls to cigarette manufacturers from monies not uplifted by consumers and collectors—in effect, ‘bonds’ that go uncollected (which may inadvertently and paradoxically raise the profitability of tobacco).

There could be other risks too, with potential unintended consequences. Although there are reviews highlighting issues around implementing policy,28 local and international research or evaluation evidence to support such a TPW collection scheme (eg, around acceptability, likely interest, impact, costs, etc.) is sparse—albeit similar deposit/return schemes have been successful with other waste products (eg, glass bottles in Oregon and South Australia16). Clearly we have not begun to assess costs of administration or exactly how the supply chain for collection bags would work. Such practicalities need to be thoroughly considered.

Likewise, although any TPW collection also imposes a cost on tobacco companies, might arguably smokers bear the greatest burden, and thus does this approach implicitly support the ‘individual responsibility’ argument the tobacco industry relies on so heavily?9,16,29 Would such levies risk being passed onto smokers and create other problems, given the increasing resentment of existing excise tax increases?30

Alternatively, the tobacco industry could be made more directly responsible for its producing a product component (the filter) that offers no benefit in reducing the harm from smoking and creates a considerable environmental menace. Might a better strategy in fact be to simply impose a direct cost on tobacco companies (pro rata by market share) and recoup the costs of TPW collection and disposal?13 Funds could be used to meet costs currently borne by local authorities (and rate payers) and could also be used to support more direct cessation services.

We will need to assess evidence of wider impacts elsewhere (eg, shifts in attitudes towards smokers, tobacco industry or changes in smoking behaviours) where TPW management has been introduced, including accompanying costs and risks. It is too early to answer such questions; to date evaluations are still happening, eg, the City of Vancouver continues to evaluate its pilot project to recycle cigarette butts31—albeit meantime with reports there of barriers, although those obstacles have apparently been political rather than practical.32

So in short, we do not have answers yet. But we want to at least encourage the New Zealand health sector as a whole to start thinking about ways of developing solutions and undertaking robust costings. Regardless of options and their costs, the earlier these conversations happen, the better. Perhaps now it is time for us to begin to consider such novel approaches locally?

‍