iQOS and HeatSticks – the full picture

Oliver Kershaw Comment 38 Comments

About the Author

Oliver Kershaw

Founder of e-cigarette-forum.com and co-founder of vaping.com

[this article was edited post-publication to correct two points relating to Swedish Match’s MRTP application and PMI’s PMTA]

The last couple of weeks has seen some significant buzz concerning iQOS, the new Heat-Not-Burn tobacco system from Phillip Morris. From what’s publicly available it appears PMI will sell iQOS in the US from early 2017. But what does it mean? Who is it for? What are the wider political and commercial ramifications? What relevance does it have in a market that’s already big on vaping?

iQOS Overview

If you’ve not heard of iQos and HeatSticks, let me get you up to speed quickly. iQOS is a small battery-powered unit into which the user inserts a mini cigarette (HeatStick or “HEET”). iQOS then heats this at a precise temperature. The HeatSticks consist of familiar brands from the PMI/Altria stable such as Marlboro, although exactly how PMI plan on branding them is not yet clear: it appears the HeatSticks themselves are now referred to as “HEETs”.

There’s no or little combustion from HEETs; instead, the user inhales a tobacco and nicotine-infused vapor rather than smoke. The Heatsticks themselves are a highly engineered product, with a proprietary blend of tobacco/flavorings/excipients that produce a vapor when heated.

iQOS has been available in some countries for some time now, most notably Japan, where PMI claim it has taken around 2.2% (PDF) of the smoking market already. It’s worth pointing out, however, that nicotine-containing vaping products are not available in Japan, so this is in part pent-up demand being satisfied.

Nevertheless, PMI’s chief André Calantzopoulos is very bullish about the product, albeit with a slight hedge where he talks about PMI’s “other platforms.” Excepting their e-cig, Mark 10, it’s not clear if these other products are yet available.

Why Heat not Burn?

Vapers will be extremely skeptical about these products, largely because of the type of vaping products the tobacco industry has promoted historically. Mark10, Vuse, Logic and Blu are not well-liked products by the vaping user-community. Indeed, some have suggested malfeasance on the part of the majors for promoting products which are not as satisfying as products available in independent channels.

Others point out that the tobacco industry’s entry into the vaping market was an inevitability, and that they are not incentivised to develop great products, even as they are incentivised to dominate their existing channels. There’s another factor at play too: British tobacco major Imperial Brands owns patents which they claim cover all vaping products currently on the market.

Also, big corporations run slowly whereas innovation in the vaping market has happened at great speed. New products have hit the shelves almost weekly, produced by small, agile players responding to market demands and innovating accordingly. Much of this has been generated by the fantastically competitive manufacturing world of Shenzhen, China, where over 100 factories operate in the vaping space. It’s simply not possible for mainstream retailers to be part of this unique market.

In all, then, it’s not surprising that the TI isn’t doing vape properly. But I don’t believe one should discount PMI’s overall intentions based on these commercial realities. After all, does anyone believe that the tobacco industry wants to kill its users? To me it’s a no-brainer that the tobacco industry will wish to create products that satisfy the following criteria:

  • They own the intellectual property.
  • The product is inexpensive to make
  • But that only they can make it
  • The product is easy to use
  • and is as similar as possible to their existing products

iQOS checks all these boxes in a way that vape does not and cannot.

I’d go further and say that the commercial opportunity for PMI is quite profound for additional reasons.

Firstly, PM can argue, and already is arguing in some jurisdictions, for lower excise taxes based on the lessened harm compared with cigarettes. Cigarettes have “sin taxes” added to dissuade consumers from use (and, of course, to create government revenues). The tobacco industry has done very well out of these taxes by using a stalking price-rise strategy. They add a small wholesale price increase at the same time governments apply the larger tax increase; consumers don’t notice, and the additional revenues more than cover the losses due to fewer cigarettes sold.

The opportunity for PMI, then, is to undercut their competitors’ cigarette products, while at the same time realizing more revenues per “stick” (to use tobacco industry parlance). Indeed, PM makes great hay out of the recent “end of cannibalisation” of their brands in Japan, and the capture of smokers of competitor brands. I don’t imagine Japan Tobacco (the world’s 4th largest tobacco company by revenues) are happy!

Is there a place for iQOS?

The thrust of PMI’s investor-facing marketing has centered around the notion that smokers don’t like vape products; that they need a tobacco product that’s as similar as possible to the cigarette. Perhaps unsurprising coming from the tobacco industry, but how much truth is there to it?

Despite being the founder of the world’s most influential vaping website, I’ve never been chauvinistic about vaping. It may or may not prove to be (long term) the biggest disruptor to the cigarette ever seen. It’s possible vaping may serve as a precursor to other products that do the job better. Certainly, if you ask most committed vapers whether they’d countenance the use of a product like iQOS, they’d be, at the minimum, skeptical.

Simultaneously, it’s crucial to acknowledge that many tobacco users already perform tobacco harm reduction by substituting chew, dip, and snus; products that are vastly less harmful than cigarettes.

My view has always been that smokers should have access to a wide range of nicotine products, and ones that are designed to be attractive to smokers. In other words, not just a small selection of pharmaceuticals aimed at those smokers who’ve already decided to be “patients” in need of “treatment,” but a good range of attractive nicotine products for those who want them.

An abstinence-only culture dominates Tobacco Control in the US, and this culture is fundamentally in conflict with the notion that nicotine can ever be consumed safely by large numbers of people.

And they will almost certainly be thinking about the following….

Replacement smokers?

Without wishing to go too deeply into the culture war between tobacco control and tobacco harm reduction proponents, there’s a huge elephant in the room. What is the role of harm-free or harm reduced nicotine?

Most vaping companies are still reasonably small-scale concerns with few shareholders and a short term (but non-the-less committed) vision of their business. The vast majority of vape shops are owner-operated entities. Some are driven purely  by the wish to help convert smokers, others are looking for a tobacco company acquisition, but few are planning on creating century-spanning corporations dealing in a sustainable nicotine market. While some may consider these players to be cynical get-rich-quickers, others might take a more nuanced view that it’s no bad thing for nicotine companies to plan for (or accept) their future obsolescence in one way or another. It’s a horrible irony that it’s this sector which the regulations will destroy.

On the other hand, the tobacco industry is one of the world’s largest and most profitable, and whose revenues lubricate the global financial system. They have to stay in business and cannot plan for their obsolescence.

One of the current proposals being hotly promoted by US tobacco controllers is to de-nicotinize cigarettes. The 2009 Smoking Act contains provisions that allow the FDA to remove most (but not all) nicotine from cigarettes. The theory is that by doing so, fewer people will become hooked, and those that are hooked will find it easier to quit.

In conversation, I’ve found proponents of this strategy to be somewhat ambivalent about the role of non-smoked nicotine products such as vaping. Some are absolutely pro the idea of smokers “moving onto vaping.” Sadly, the follow-on – that smokers should then be allowed to choose from a diverse market in these products – is rarely accepted.

The history of the tobacco industry is replete with examples of highly malfeasant corporate behavior. Some of these (see the so-called “7-dwarves” video) have left such a huge imprint on our culture that they’re somewhat totemic.

The notion of the “replacement smoker” (PDF) is one such example. Internal correspondence had one RJR executive describing the marketing of cigarettes to adolescent smokers as fulfilling the need to create replacement smokers, thereby perpetuating the corporate tobacco interest.

What does the corporate model of the tobacco industry look like in a harm reduction future?

Well, as I’ve outlined above, in the short to medium term, very profitable. A small shift from smoked tobacco to heat-not-burn can transfer the “government share” of revenues to the seller through excise changes. Longer-term, it’s unclear. Will these products “create replacement iQOSers”? Is nicotine a compound with such utility that more people will choose to use it if safer products are available?

In some scenarios, this could be a new dawn for the tobacco industry. Nicotine could end up being used by more people than currently yet with far fewer health problems associated. Indeed, it’s conceivable that these new products are so safe, that it’s not possible to even detect any negative health effects in the population.

In other scenarios, the products further denormalise smoking to the extent that “replacement smokers” decline faster than ever.

Next stage – the politics, the regulations, and the science

PMI has announced that it will apply for Modified Risk Tobacco Product (MRTP) approval with an initial submission to FDA by the end of this year. MRTP is another provision created by the Tobacco Act that allows companies to make a “modified risk” statement about their product versus cigarettes. First, though, they must persuade the FDA that such a statement is an accurate assessment of scientific fact.

To date, only one company has attempted to gain MRTP approval. Swedish Match spent an estimated $50million on research and submitted over 100k pages of scientific testimonial for their General Snus range of oral tobacco products. Despite overwhelming evidence that (all) snus is vastly safer than smoking the application was rejected by the approval committee (TPSAC) and the process is still ongoing. So far, the  politics have won over the science.

Gaining MRTP status might sound like a huge effort for not much payoff: the ability to state something that’s self-evidently true. But Harm Reduction is, fundamentally, a communication intervention, and currently, the law forbids this communication. The small informational concession from a successful MRTP application could see a sea-change in smoker behavior at the macro level. The question is whether the politics is so poisoned that it will ever be allowed to happen.

PMI: It’s almost as if they planned this!

One thing’s for sure, though: no-one has prepared for this moment better. For over a decade PM has been conducting research, developing novel methods for assessing health effects and refining their iQOS platform. In all, over $3bn has been spent on this project. PMI’s MRTP submission to the FDA is said to contain over two million pages, and the timing here is insanely good… so good it’s almost like they convened the forces of the universe themselves:

In August this year, new “deeming regulations” came into play. FDA now deems vaping products and other novel non-smoked tobacco products to be Tobacco Products and to fall under their regulatory jurisdiction. No new products are allowed on the market from August 8th, and all the goods currently on the market may remain for two years while their manufacturers apply for PMTA.

 

[Edit – since publishing, I have been informed that the following paragraph is based on incorrect information, and that PMI will not be marketing iQOS until such a time as they have received premarket authorisation, possibly some time in 2017/2018]

And guess what? According to PMI, iQOS was sold in 10 US cities on August 8th this year. They are now free to sell their product for two years while anyone else who was not on the market must gain preapproval.

The PMTA process is so onerous that few vaping companies are expected to make it through. There’s a huge question mark as to what is on the market in two to three year’s time to satisfy existing consumer demand. PMI will be there waiting.

BAT, Reynolds and JTI?

So far, not a peep has been heard from other tobacco companies on their plans for new tobacco products in the US market. BAT are making moves to acquire Reynolds American, facilitated by economic conditions caused by Brexit. BAT has unique research capabilities and R&D, and already has a technology sharing agreement with Reynolds. It’s conceivable that BAT or Reynolds also “grandfathered” some novel products on August 8th, but so far no public statements have been made to this effect.

The regulatory advantage to PMI, according to current information, is that they have a head start which could prove to be a critical window in which they can seek to dominate. Some business theorists would state that first-mover advantage is a myth,  but I’m not sure this applies here: Heat-not-Burn is not new whereas this regulatory paradigm certainly is.

The long term?

So, the long-term question is: can PM make such inroads with their new technology as to be the disruptors and long-term winners in a market that has been forged by the emergence of vaping?

Well, this takes us back to the question posed at the beginning. What is the market for iQOS in a nation that already has vape?

I’ll leave you with a few quotes from people I know who’ve used iQOS.

“I’m worried about using it because it’s too similar to smoking and I worry that I’ll go back to smoking”

“I’m back on vaping because I can’t get hold of the damned things”

“I went back to vaping because I was getting through 3 packs per day and it was too expensive”

“Nice product – fits well inside my pocket, but it’s not as satisfying at the real thing”

So, a mixed bag so far. Prediction’s a mug’s game – but I’d rather see iQOS emerging as part of the story, and not the whole story.

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  • Leo Nicholson

    Also, tobacco companies are always “enhancing” their products by elevating nicotine levels to increase addition.

    • Well, cigarettes are a highly engineered product, no doubt. But I think the “elevating nicotine” bit is a bit of a myth. From my understanding, the principal manipulation is the addition of compounds which change the PH of the tobacco and thus make the smoke easier to inhale. This leads to enhanced addictive potential as nicotine is absorbed much more readily via the pulmonary system.

      Interestingly, vape companies have performed similar manipulations for years, particularly for higher strength liquids so that they’re less harsh on the throat when inhaled.

      • “vape companies have performed similar manipulations” can you please provide a citation? This sounds like a rumor. E-liquids are vegetable glycerin and optionally propylene glycol as a carrier for flavoring agents and nicotine. There are some flavoring agents and nicotine carried by vegetable glycerin, but propylene glycol is more common, generally works better, and provides the throat hit that some ex-smokers crave. That’s it. Vape companies do not mess with this, the ingredients are simple. If you have a citation, great, but you should also be clear those doing this are an incredibly small minority if any are doing this at all.

        • Untrue.

          PAX use nicotine salts to alter the PH balance of e-liquid in their Juul device. A number of e-liquids have adjusted PH for similar reasons, the first (of which I’m aware) being Vermont Vaper, starting in around 2010 (from memory). The fundamental purpose here is to make the nicotine easier to inhale, although Juul claim their formulation enhances the uptake as well (I’m skeptical, except in the trivial sense that if you can inhale it deeply, your lungs can absorb it better).

          Cigarettes have their PH adjusted through the addition of ammonia. Try inhaling a cigarette versus inhaling an (untreated) cigar. You’ll see the difference.

          It will take you 5 minutes googling to corroborate this.

          • This still sounds like a minority of companies. You’re spreading FUD about a non-issue for must people who vape with standard e-liquid, not “special devices.”

            Also, terrible advice to suggest smoking cigarettes or cigars.

      • haruspex

        Most vape companies do not do this. Do not spread FUD about standard vaping.

  • Alan Selk

    The snus MRTP application is still very much in play. It was rejected by a non-binding advisory board, but the FDA has yet to come to a final decision, even though it is long overdue.

    I could be wrong on this as I haven’t been keeping a close watch on it, but last I heard it is still very much in play.

    • You’re correct. See Joe’s exposition above. I’ll edit the original text. Thanks.

  • Bob Bridges

    Seems to me that iQOS is very similar to vaping and it’s the big companies trying to elbow out the innovative small guys. I should think it will fail on cost and complication! Not sure what is happening in the UK since leaving the EU but so far our government have been reasonable and sensible since. Whether they will still insist on the EU tobacco directive, remains to be seen! Not that it will worry me too much as I make my own liquid and my only worry is where to get the nicotine and I shall go to Eastern European or far Eastern countries to source that if necessary.

    • I have a slightly different view of this. These big tobacco companies are bound to get involved in reduced risk products – it is inevitable. It is where their customers are heading, and just important, where their competitors are after market share. And actually it is a good thing if they sell less dangerous products. What will really elbow out the smaller guys is regulatory overkill, of the type now introduced by FDA and favoured by many in tobacco control.

      What I would hope for is a market that looks a bit like the market for beer – some mega-corps like AB InBev and SAB Miller, but with a healthy tier of of mid-sized regional or national brewers, and a long tail of highly diverse craft breweries. Despite its intoxicating qualities, a new beer is not subject to the kind of authorisation regime FDA will inflict on ‘craft’ liquid makers.

      In the UK (and all EU) it is much easier to put iQOS on the market than in the US because there is just a notification regime. I’d expect it to be out in the next few months in the UK. A good thing in my view – widens the range of non-combustion alternatives to smoking.

      • Jim McDonald

        “What will really elbow out the smaller guys is regulatory overkill, of the type now introduced by FDA and favoured by many in tobacco control.”

        Yes, but regulatory overkill is favored by the tobacco industry too. It’s what allowed Altria and Reynolds to gain the advantage they now have in the cigarette market, and it’s an environment they’ve adapted to very well. It was Reynolds that gave the FDA the blueprint (in their comments on the first iteration of the deeming rule) for how to wipe out open systems. I’d be a lot more sanguine about what happens in a free market for reduced-harm tobacco products if there *was* a free market. But it’s very much a market of regulatory gamesmanship, which the little vapor industry can’t play.

        • Thinking about the last (weird) week…. PM are normalising the “10%” as acceptable relative-risk, Imperial have explicitly pushed back on this, BAT are doing so implicitly (see attached picture). iQOS is a bit of a problem for BAT, not necessarily on competitive terms, but because it makes their science look ludicrous. Why bother making your products totally safe if your competitor’s happy to put a product on the market which may have dramatically reduced but detectable health effects?

          And, why bother making your product totally safe if the cost is that you are unable to offer more than half a dozen flavors?

          The UK is a low-priority market for PM, so they can go hell for leather in using it as the iQOS proving ground and f*ck with BAT on their home turf. This is all going to be very interesting. I hope the public health crowd don’t get too upset.

    • And to be clear, nicotine can be acquired from non-tobacco sources. Vaping needs to be regulated separately from tobacco when no tobacco products are in use.

  • Jim McDonald

    That’s the best vaping essay I’ve seen in a long time — and it’s not about vaping! Great, Oliver.

    • That’s really kind of you Jim.

      Question – if it’s not vaping, what is it? Needs a new name and I don’t thing the back-of-the-envelope “HEETing” is going to cut it 🙂

      • Jim McDonald

        I’m not getting involved in that, but I’ll just mention that e-smoking is still available.

  • Thank you, Oliver–very thoughtful overview.

    My only factual quibble is your characterization of the MRTP process for Swedish Match (disclosure: I have lost hundreds of dollars on wagers on the outcome of this decision through timing out!): while the TPSAC did vote to deny SM the MRTP order, TPSAC is NOT the final stage of the process. They are an “advisory” committee and they offer advice (when asked); they don’t make decisions.

    I still remain hopeful that FDA CTP will issue an order allowing SM to make modified risk claims, but I fear that many more moons will pass before this happens. And that is too bad on a host of levels, IMO.

    We are living in interesting times!

    Joe

    PS – here’s to hoping I will see you on 17 Nov at the Royal Society! #LuckyJoe

  • Thanks Oliver – very interesting…

    iQOS is very unlikely to appear in the U.S. market in early 2017. It will need a Pre-Market Tobacco Application (PMTA) approval from FDA and PMI/Altria will need to show it meets the ‘public health test’. This is not a trivial barrier for a novel technology, given that no-one really knows how it will work in the U.S. marketplace. In addition PMI has said that it will apply for an MRTP to make claims about reduced exposure or reduced risk. The PMTA paperwork is a subset of the MRTP and can be determined separately by the FDA and earlier. But that could take years to determine.

    The best source of technical information on this product is http://www.pmiscience.com. The iQOS is known as ‘Platform 1’ on this web site. But it also shows that there are four platforms in PMI’s product pipeline – two are heat-not-burn tobacco, including the iQOS, and two are ‘e-vapor’ products.

    We are likely to see iQOS appearing in Europe much sooner (it is already in Italy). It comes under article 19 of the TPD (Novel tobacco products). This is a notification regime rather than an authorisation regime. All PMI has to do is file the right paperwork and the product can go on the market.

    • Thanks Clive. I’m now hearing that the information that iQOS was on the market in 10 cities on August 8th is not correct and so you are right, they will have to apply for the PMTA prior to marketing.

      Very strange, I was pretty certain it was a PMI source that stated this, but I will have to check. Kind of ruins my “masters of the universe” thesis!

      Regarding the “platforms” – two heat not burn, one e-cigarette product and the nicotine pyruvate technology PMI acquired from Jed Rose some years back, no?

      Very frustrating they’ve not marketed nicotine pyruvate. I had an ECF member who tried it around 2010 stating that it was exceptional – far superior to the then vaping technology.

  • Bill Godshall

    My apologies for inaccurately stating (two weeks ago) that iQOS was on sale somewhere in the US on 8/8/2016, which I presumed was the case after reading two confusing news articles stating PMI/Altria would launch iQOS nationwide in the US in 2017 (as FDA’s deeming rule has prohibited any new products from being introduced since 8/8/16 unless/until FDA approves a PMTA).
    https://www.bloomberg.com/news/articles/2016-10-05/philip-morris-s-cigarette-alternative-could-reach-u-s-in-2017
    http://www.cspdailynews.com/category-news/tobacco/articles/philip-morris-readies-iqos-us

    Those same articles also stated that iQOS was being sold in 10 undisclosed cities, but its now clear that none of those cities is located in the US.

    Altria has subsequently clarified that the MRTP application for iQOS would be submitted before the end of 2016, and that a PMTA for iQOS will be submitted to FDA in the first quarter of 2017.
    http://www.altria.com/Media/Press-Releases/Pages/PressReleaseDetails.aspx?reqID=2216476

    Since the TCA requires FDA to act on PMTAs within 6 months after submission, FDA could approve (or reject) the iQOS PMTA in the third quarter of 2017.

    And since the TCA requires FDA to act on MRTP applications within 12 months of submission, FDA could approve (or reject) the MRTP for iQOS in November or December of 2017.

    It’s also possible that PMI/Altria could amend their MRTP application or their PMTA (perhaps due to suggestions/pressure from FDA), which could allow more time for FDA consideration.

    PMI scientists have been telling me about iQOS (but not that name) for the past five years (every time I ask them why hasn’t PMI begun selling vapor products), and have insisted that it is superior to vapor products.

    Its pretty clear that the biggest threats facing iQOS are the same threats that have faced vapor products, dissolvables, snus and other low risk alternatives in the US (i.e. FDA, CDC, DHHS funded activists, Legacy, Big Pharma funded CTFK, ACS, AHA, ALA, AAP, etc., left wing Democrats, and the liberal news media).

    That’s probably why PMI/Altria chose to seek FDA PMTA approval of iQOS (before marketing it in the US), as doing so can prevent anti vaping agencies, organizations, activists, politicians and news outlets from falsely claiming iQOS:
    – is target marketed to addict nonsmoking children,
    – is a gateway to cigarette smoking,
    – is renormalizing cigarette smoking, and
    – may be just as harmful as cigarettes.

    • Cheers Bill. Also, I’m now informed it would have been covered by the existing Smoking Act and couldn’t have been marketed prior to 8/8 without PMTA in any case.

  • Troll killer

    I live in the town where this product was researched and sold the first time around , about 1990, it flopped then. They are just rehashing an old idea. Peeps stated it does not satisfy and it still smell like a ciggy

    • I suppose another way to look at it would be that they’ve been working on this a long time and have the funds to get it right second time round? I don’t know… we shall see.

  • John Songer

    This seems somewhat a spin-off of the Eclipse cigs. The Ones where you light the tip (charcoal if I remember) and it heats the tobacco. Thing is, it still will produce the tar right? It is still essentially just hot tobacco correct? I see this as just some ploy to strike another blow at our lifestyle. Nicotine doesn’t cause cancer, it’s tar and the other chemicals you only get from actual tobacco that causes it. IMO, this is a doomed product as I believe it’s still going to produce same chemicals the cig would, just possibly at lower levels (much as Eclipse cigarette did after claiming it wouldn’t).

    • Spin off? Perhaps – the tobacco companies tried Heat-not-burn and it failed, but I think largely because they didn’t support it and further develop it at the time.

      Mixed picture about Eclipse and Premier – one of the brands was marketed with the oh-so-tempting proposition: “you’ll hate it at first but then you’ll love it.” Thing was, this proved to be the case!

      iQOS is a different in that it uses an electrically powered heat probe to do the work. I guess this makes it more controllable.

      Interestingly there is a new generation HnB product which does resemble Eclipse/Premier (Eclipse-a-like?) in the PM pipeline: Currently referred to as “platform 2”. So, after 30 years, they’re back in the game!

      As far as tar is concerned: there will be some toxins, but far fewer as most are produced through the burning of tobacco.

    • ChrisPrice4

      BAT published some lab work about 6 months ago that showed HnB had a 90% toxic exposure reduction compared with a regular cigarette. I tend to believe the substance of their report.

      This being the ‘full monty’ HnB ‘cigarette’, you’re still getting carbon monoxide / fuel exhaust in the 10% exposure remaining – so anything with a separate exhaust path or no fuel exhaust at all, such as an electronic model, is going to show an even greater reduction in toxic exposures; a 95% reduction or better, perhaps.

      5% of the health impact of cigarettes (if that is equal to the toxic exposure of course – a bit of a leap) is still a hell of a lot, which is why it is clearly impossible for vaping to be anywhere near that sort of damage potential. It still gives 5,000 deaths a year if smoking causes 100,000: an impossibly large number for any new and unprotected product to survive.

      But there are a lot of ‘ifs’ in all that, of course.

      • The PMI investor report also concludes 90% reduction of HPHCs – but I’m not sure this translates into anything meaningful absent of biological testing.

        Also, do note that 5% of the harm doesn’t necessarily translate into mortality. Something can still cause harm but not kill. So, one might attribute a 5% harm to a device which causes an overall lessening of quality of life (e.g. reduction in lung functioning), rather than gross overall disease.

  • emtee

    So, this is basically the same as when I put my rolling tobacco inside my Firefly 2? In which case i pretty much know how vaped leafs taste and smell like 😉

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  • Carl Ebrahim

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  • No, moving away from tobacco entirely is the correct move. I prefer that vaping be regulated separately from tobacco products. It is unfortunate that the FDA has lumped them together. Vaping does not require any tobacco products and yes is being regulated in the same manner, which is wrong.

  • haruspex

    This seems like the death rattle of the tobacco industry.