This is an HTML version of an attachment to the Official Information request 'Smokefree Aotearoa 2025 Action Plan'.

Sent by: 
To: [email address]
[email address]
cc: [email address], [email address], 
.nz
[email address], [email address]
bcc:
17/02/2021 11:58 pm
Subject: wondering if you can help with our understanding around very low nicotine 
cigarettes
Hi Sally
ACT 1982
I received a response from  Eric - his thoughts are in caps after my queries in the message below.
Richard
Dear Eric
INFORMATION 
I hope you are keeping well.
I am getting in touch because the issue of VLNCs has potentially become a live one in NZ. 
The context is that the new Govt Minister is committed to preparing an action plan for 
consultation setting who NZ's smokefree goal can be achieved. As you will probably remember 
we have advocated strongly that mandated VLNCs should be a key intervention, and we recently 
re-iterated that call in this blog. 
https://blogs.otago.ac.nz/pubhealthexpert/five-strategic-approaches-to-achieving-the-smokefree-
aotearoa-2025-goal/ [blogs.otago.ac.nz] 
RELEASED UNDER THE OFFICIAL 
The Minister and Ministry of Health team are gathering information about the feasibility of such 
an approach and a query has come up (see below) about which VLNCs are available and the 
technical feasibility of mandating such products.

My understanding is that:
1. The only (?) available VLNCs at the moment are a range of varying concentration products
(including 0.4mg/ml) produced as 'Spectrum' by the company 22nd Century in the US using
low nicotine level tobacco plants. However, these products are currently mainly (wholly?)
available for research purposes and are not for sale to the general public. I am not sure if
'Magic' low nicotine cigs are still available in Europe - I think these were produced by 22nd
Century as well.
22NDCENTURY HAS APPLIED FOR A MODIFIED RISK TOBACCO PRODUCT 
APPLICATION AND THE FDA ADVISORY BOARD REVIEWED THAT APPLICATION A 
YEARS OR SO AGO.  THEIR INTENTION WAS TO MARKET IT UNDER THE NAME 
ACT 1982
“VLN”.  I AM NOT SURE OF THE STATUS OF THAT APPLICATION, BUT THIS NEWS 
RELEASE (
https://www.globenewswire.com/news-release/2021/01/11/2156515/0/en/22nd-Century-Group-E
xpands-VLN-Tobacco-Growing-Program-to-Support-Anticipated-Demand-of-the-Company-s-R
educed-Nicotine-Content-Cigarettes.html).  IT DOES SUGGEST THEY ARE GEARING UP 
FOR A LARGER SCALE PRODUCTION, SO THEY MIGHT BE ABLE IN A POSITION TO 
MAKE THEM AVAILABLE ON THE SCALE NEEDED IN NZ. 
INFORMATION 
1. Other very low nicotine cigarettes (Next, Quest) have been produced in the past by major
tobacco companies but these were not successful within a market where nicotine-containing
cigs etc were still available and none of the big tobacco companies currently produce such a
product commercially. I was not aware that Pall Mall Slims Silver, or Virginia Slims
Superslims etc are VLNCs.
AGREED THAT NONE OF THEM CURRENTLY PRODUCE VLNCs; HOWEVER, THEY 
ARE FULLY CAPABLE OF DOING SO.  IF VIA GENETIC ENGINEERING, IT WOULD 
TAKE A WAY SINCE THEY WOULD HAVE TO GROW THE CROPS.  IF EXTRACTION, 
IT MIGHT BE MUCH EASIER.  NOT SURE ABOUT PALL MALL OR VIRGINIA SLIMS – 
I HAVE NOT HEARD THAT. 
1. It is perfectly feasible for cigarette and other tobacco products to be made with a minimal
level of nicotine concentration through the use of genetically engineered low nicotine plants
(or I believe that nicotine can be extracted/degraded from tobacco). Note, genetically
engineered products could be an issue in the NZ context.
CORRECT, SEE ABOVE.  THIS IS NOT A TECHNICAL CHALLENGE.  THAT SAID, I AM 
RELEASED UNDER THE OFFICIAL 
SURE THE INDUSTRY WILL MAKE IT SOUNDS LIKE A HUGE HURDLE.  LARGE 
SCALE PRODUCTION MIGHT BE BUT STARTING IN NZ MAY NOT PRESENT THE 
SAME LEVEL OF CHALLENGES. 
Would you be able to respond with your expert views on these points and perhaps be available to 
talk to the Ministry or Minster's team. If you can't help could you suggest anyone who we could 
approach (e.g. Neil B, Dorothy H, Tracy Smith?)

 
Thanks very much.
 
Richard
 
1982
From:Sally Stewart <[email address]>
ACT 
Sent:Monday, February 15, 2021 3:43 PM
To:Richard Edwards <[email address]>
Cc:Carolyn Shivanandan <[email address]>
Subject:wondering if you can help with our understanding around very low nicotine cigarettes
 
Kia ora Richard, we’re wondering if you can help us better get our heads around VLNC or if you 
INFORMATION 
can suggest who can. The background is that Chris Bullen suggested to the Minister that these 
only exist in research contexts, which we didn’t think was right. The Minister asked us to follow 
up (and also answer the question about whether it’s technically feasible – which it clearly is).
 
OFFICIAL 
Carolyn has been doing some digging around and her note is copied below. Are you – or can you 
think of someone – we can talk with to better understand the various options on the market 
THE 
internationally.
 
UNDER 
Ngā mihi
Sally
 
 
RELEASED 
There is evidence that very low nicotine cigarettes are available, or can be manufactured 
internationally.  (e.g. Spectrum / Moonlight,  Next, etc.) Research quoted in the ASPIRE report 
talks about 0.4mg/g as being the level of Nicotine needed to have an effect. This is significantly 
lower than cigarettes currently on the market in New Zealand.    

 
There are also a variety of products seemingly marketed overseas by main stream tobacco 
companies that might meet the nicotine levels that are being discussed? For example Pall Mall 
Slims Silver, orVirginia Slims Superslims (which apparently has 0.1mg of nicotine). This is a 
link to a Victorian govt spreadsheet with testing information with various examples - 
https://www2.health.vic.gov.au/Api/downloadmedia/%7B2B981D89-5DC2-4630-9335-2F8B3E
AC1DFE%7D [apc01.safelinks.protection.outlook.com]   
 
1982
It would be helpful to understand if any work has been done comparing the nicotine levels in 
these types of cigarettes with what has been proposed in experimental settings. There seems to 
ACT 
be different ways to measure – mg/cigarette, mg/g, and just mg, and perhaps different ways to 
test and present data more broadly so I am wondering if it is not as straight forward as it would 
seem?  
 
 
INFORMATION 
Sally StewartlManager, Tobacco Control Programmels 9(2)(a)
Population Health and Prevention, Ministry of Healthlwww.moh.govt.nz
[apc01.safelinks.protection.outlook.com] OFFICIAL 
 
 
THE 
Professor/Ahorangi Richard Edwards  
Co-Director, ASPIRE 2025 Research Centre 
UNDER 
Department of Public Health | Te Tari Hauora Tūmatanui 
School of Medicine and Health Sciences 
University of Otago, Wellington | Te Whare Wānanga o Otāgo, Te Whanga-nui-a-Tara 
RELEASED 
PO Box 7343 | Wellington South | New Zealand | DD s 9(2)(a)
 
http://www.otago.ac nz/wellington/departments/publichealth/ 
https://aspire2025.org nz/ 
 

Web: http://www.otago.ac.nz/wellington/departments/publichealth/staff/otago023413 html 
Twitter: @ProfEdwardsNZ 
E-mail: [email address] nz 
Skype:  pr.edwards.nz 
From: Richard Edwards <[email address]>
Sent: Monday, February 15, 2021 4:48 PM
1982
To: Sally Stewart <[email address]>
Cc: Carolyn Shivanandan <[email address]>; Nick Wilson  ACT 
<[email address]>; Janet Hoek <[email address]>; Andrew Waa 
<[email address]>
Subject: Re: wondering if you can help with our understanding around very low nicotine 
cigarettes 
 
Hi Sally
INFORMATION 
 
I have contacted Eric Donny from North Carolina (see  
https://school.wakehealth.edu/Faculty/D/Eric-C-Donny) who is first author of this article:  
https://tobaccocontrol.bmj.com/content/26/e1/e37 . 
OFFICIAL 
 
THE 
See message below.
 
Great to see that the Minister is pursuing this option
UNDER 
.
 
I’ll forward on his response.
 
RELEASED 
Richard
 
 

Dear Eric
 
I hope you are keeping well.
 
I am getting in touch because the issue of VLNCs has potentially become a live one in NZ. 
1982
 
The context is that the new Govt Minister is committed to preparing an action plan for 
ACT 
consultation setting who NZ's smokefree goal can be achieved. As you will probably remember 
we have advocated strongly that mandated VLNCs should be a key intervention, and we recently 
re-iterated that call in this blog. 
 
https://blogs.otago.ac.nz/pubhealthexpert/five-strategic-approaches-to-achieving-the-smokefree-
aotearoa-2025-goal/ 
INFORMATION 
 
The Minister and Ministry of Health team are gathering information about the feasibility of such 
an approach and a query has come up (see below) about which VLNCs are available and the 
OFFICIAL 
technical feasibility of mandating such products.
 
THE 
My understanding is that:
1. The only (?) available VLNCs at the moment are a range of varying concentration products 
UNDER 
(including 0.4mg/ml) produced as 'Spectrum' by the company 22nd Century in the US using 
low nicotine level tobacco plants. However, these products are currently mainly (wholly?) 
available for research purposes and are not for sale to the general public. I am not sure if 
'Magic' low nicotine cigs are still available in Europe - I think these were produced by 22nd 
Century as well.
2. Other very low nicotine cigarettes (Next, Quest) have been produced in the past by major 
RELEASED 
tobacco companies but these were not successful within a market where nicotine-containing 
cigs etc were still available and none of the big tobacco companies currently produce such a 
product commercially. I was not aware that Pall Mall Slims Silver, or Virginia Slims 
Superslims etc are VLNCs.
3. It is perfectly feasible for cigarette and other tobacco products to be made with a minimal 
level of nicotine concentration through the use of genetically engineered low nicotine plants 
(or I believe that nicotine can be extracted/degraded from tobacco). Note, genetically 

engineered products could be an issue in the NZ context. 
Would you be able to respond with your expert views on these points and perhaps be available to 
talk to the Ministry or Minster's team. If you can't help could you suggest anyone who we could 
approach (e.g. Neil B, Dorothy H, Tracy Smith?)
Thanks very much.
Richard
ACT 1982
From:  Sally Stewart <[email address]>
Date: Monday, 15 February 2021 at 3:43 PM
To: Richard Edwards <[email address]> INFORMATION 
Cc: Carolyn Shivanandan <[email address]>
Subject: wondering if you can help with our understanding around very low nicotine cigarettes 
Kia ora Richard, we’re wondering if you can help us better get our heads around VLNC or if you 
can suggest who can. The background is that Chris Bullen suggested to the Minister that these 
only exist in research contexts, which we didn’t think was right. The Minister asked us to follow 
up (and also answer the question about whether it’s technically feasible – which it clearly is). 
Carolyn has been doing some digging around and her note is copied below. Are you – or can you 
think of someone – we can talk with to better understand the various options on the market 
internationally.
RELEASED UNDER THE OFFICIAL 
Ngā mihi
Sally

There is evidence that very low nicotine cigarettes are available, or can be manufactured 
internationally.  (e.g. Spectrum / Moonlight,  Next, etc.) Research quoted in the ASPIRE report 
talks about 0.4mg/g as being the level of Nicotine needed to have an effect. This is significantly 
lower than cigarettes currently on the market in New Zealand.    
There are also a variety of products seemingly marketed overseas by main stream tobacco 
companies that might meet the nicotine levels that are being discussed? For example Pall Mall 
Slims Silver, or Virginia Slims Superslims (which apparently has 0.1mg of nicotine). This is a 
link to a Victorian govt spreadsheet with testing information with various examples -  
https://www2.health.vic.gov.au/Api/downloadmedia/%7B2B981D89-5DC2-4630-9335-2F8B3E
ACT 1982
AC1DFE%7D   
It would be helpful to understand if any work has been done comparing the nicotine levels in 
these types of cigarettes with what has been proposed in experimental settings. There seems to 
be different ways to measure – mg/cigarette, mg/g, and just mg, and perhaps different ways to 
test and present data more broadly so I am wondering if it is not as straight forward as it would 
INFORMATION 
seem?  
Sally Stewart lManager, Tobacco Control Programme l s 9(2)(a)
Population Health and Prevention, Ministry of Health lwww.moh.govt.nz 
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Sent by: 
To: [email address]
denis.choiniere@canada.c
cc:
a
bcc:
17/04/2021 12:06 am
Subject: VLNC
 
1982
Hi! Sally
ACT 
 
Here are some  references, in case you do not have them.
 
Denis
INFORMATION 
 
1)      Report: Consultation on Tobacco Addictiveness Reduction Measures, Berlin, 
Germany, 15–16 May 2018, 
OFFICIAL 
https://www.who.int/tobacco/publications/prod regulation/meeting-report-tobacco-addictiveness
-reduction-measures/en/
THE 
 
2)      Advisory note: global nicotine reduction strategy, WHO Study Group on Tobacco 
Product Regulation
UNDER 
https://www.who.int/tobacco/publications/prod regulation/nicotine-reduction/en/
 
3)      FCTC COP5, Report of the WG on Articles 9 and 10, ANNEX 3: BACKGROUND 
PAPER ON TOBACCO ADDICTIVENESS REDUCTION
,  
https://apps.who.int/gb
RELEASED  /fctc/PDF/cop5/FCTC COP5 9-en.pdf (see also section “corrigenda”, for 
corrections to this Annex, in  https://www.who.int/fctc/cop/cop7/FCTC COP 7 8 EN.pdf)
 
De : Choiniere, Denis (HC/SC) 
Envoyé : 2021-04-15 15:58

À : 'Sally Stewart' <[email address]>
Objet : VLNC
Hi! Sally
My colleague Mathew Cook and I were quite involved in the COP working group on articles 9 
and 10, especially on the aspect of addictiveness reduction. I am sure he would be pleased to join 
me in a chat with you in the coming weeks.
ACT 1982
Best,
Denis
INFORMATION 
De : Sally Stewart <[email address]> 
Envoyé : 2021-04-15 15:49
À : Choiniere, Denis (HC/SC) <[email address]>
Objet : RE: Menthol Ban
Thanks again Denis, this is interesting.
Did you do some work on denicotinising cigarettes? If you did, it might be useful to chat 
sometime in the coming weeks.
Regards
RELEASED UNDER THE OFFICIAL 
Sally
From: Choiniere, Denis (HC/SC) <[email address]> 
Sent: Friday, 16 April 2021 1:55 am
To: Sally Stewart <[email address]>


Cc: Brendon Baker <[email address]>
Subject: Menthol Ban
Hi! Sally,
Geoff Fong (University of Waterloo) sent me these documents, which could be of interest to you.
ACT 1982
Best,
Denis
****************************************************************************
Statement of confidentiality: This e-mail message and any accompanying
attachments may contain information that is IN-CONFIDENCE and subject to
legal privilege.
INFORMATION 
If you are not the intended recipient, do not read, use, disseminate,
distribute or copy this message or attachments.
If you have received this message in error, please notify the sender
immediately and delete this message.
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