Thank you for this opportunity to follow the Irish Heart Foundation in publicly calling for a complete ban on the manufacture, sale, distribution, or free offer of disposable vaping devices under the Waste Management Act, 1996, Section 28(4)(i). Disposable vapes offer no social benefit and are addicting our youth, spoiling our environment, and interfering with our efforts to decarbonise society.

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Crucially, disposable vapes are much more likely than rechargeable vapes to be used by children. There are at least two reasons for this. First, the disposability of these products make them easier for children to conceal from their parents, thus preventing parents from intervening for the sake of their child’s health. Second, the upfront cost of disposable vapes is lower than for rechargeable vapes, making them affordable for children relying on pocket money to purchase nicotine products. This is the case even though disposable vapes are more expensive in the long run than their rechargeable equivalents, making them unattractive to adults on a stable income. It is conceivable that there would simply be no market for disposable vapes if children couldn’t buy them. 

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However, even if it was possible to prevent children from accessing disposable vapes, the environmental impact alone would justify a total ban. Vapes are an egregious source of litter across the Irish landscape, filling our rivers and rendering public parks unsafe for young families. Chemical reactions from vaping devices have caused multiple fires in UK waste plants, and it’s only a matter of time before Ireland starts seeing similar stories. At a time when Ireland is struggling to meet its environmental obligations under EU law, disposable vapes push us in exactly the wrong direction.

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Finally, disposable vape manufacturers are major consumers of critical raw materials such as lithium, copper, and cobalt. These natural resources are in finite supply on earth and are vital inputs to the production of batteries, solar panels, and other renewable technologies. The more we funnel these resources into the manufacture of nicotine products, the harder and more expensive it will be to produce the technologies needed to save us from climate disaster.

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However, a ban on disposable vapes must be managed correctly if it is to be effective.

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In America, efforts to ban vaping have been undermined by the rapid growth in demand for vaping products, leading to a profusion of illegal disposable vapes. Thus, any ban must also be complemented with regular inspection of retailers, accompanied by fines where necessary. 

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To tackle increasing demand for vaping products, we must face the reality of childhood addiction. Existing educational efforts dissuading children from consuming addictive substances should be complemented with similar resources advising on paths to addiction recovery. This would be an improvement on the status quo, wherein people are unlikely to be provided with addiction supports until they are an adult, by which point they are likely to have been addicted for years. 

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In conclusion, measures which simply aim to promote better recycling or regulation of disposable vapes are insufficient. Only a total ban, accompanied by robust efforts to tackle addiction and limit the black market, is compatible with the health of Ireland, its people, and the planet. 

Thank you for taking these comments into consideration.

Sincerely yours,

Ciarán Cuffe

Ciarán Cuffe

MEP for Dublin