WORKING PAPER

An Analysis of E-Cigarette, Heated Tobacco Product, and Novel

Tobacco Product Flavors in the Philippines: Regulatory Challenges
and Opportunities

Samantha J. Ackary
School of Government, Ateneo de Manila University

Patrik James DL. Cabrera

School of Government, Ateneo de Manila University

Alen Josef A. Santiago

School of Government, Ateneo de Manila University

Gianna Gayle H. Amul, PhD

Institute of Global Health, Faculty of Medicine, University of Geneva
School of Government, Ateneo de Manila University

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 ATENEO SCHOOL OF GOVERNMENT WORKING PAPER SERIES

An Analysis of E-Cigarette, Heated Tobacco Product, and Novel

Tobacco Product Flavors in the Philippines: Regulatory Challenges
and Opportunities

Samantha J. Ackary
School of Government, Ateneo de Manila University

Patrik James DL. Cabrera

School of Government, Ateneo de Manila University

Alen Josef A. Santiago

School of Government, Ateneo de Manila University

Gianna Gayle H. Amul, PhD

Institute of Global Health, Faculty of Medicine, University of Geneva
School of Government, Ateneo de Manila University

April 2024

This document has been produced with the help of a grant from the Department of Health (DOH),
Republic of the Philippines. The contents of this document are the sole responsibility of the authors and
can under no circumstances be regarded as reflecting the positions of Ateneo de Manila University
(ADMU) or DOH.

This working paper is a draft in progress that is posted online to stimulate discussion and critical
comments. The purpose is to mine the readers’ additional ideas and contributions for the completion of
a final document.

The views expressed herein are those of the authors and do not necessarily reflect the views of ADMU
or the DOH.

Corresponding author:

Samantha Joan Ackary

School of Government, Ateneo de Manila University
E-mail: sackary@ateneo.edu

Electronic copy available at: https://ssrn.com/abstract=4779942

Abstract

Background: E-cigarette use in the Philippines is steadily increasing. Flavored

e-cigarettes are particularly popular among the youth due to their social appeal,
esteemed novelty, innovative flavors, and pleasing sensations. Consequently, flavors
contribute to the initiation and sustained use of e-cigarettes, prompting further
exploration of the nature and extent of flavored e-cigarette products.

Results: We collected 313 e-cigarette products with 280 (88.89%) having flavor
descriptors. Out of 280 products, we identified 363 flavor descriptors. We discovered
11 categories of e-cigarette flavors: colors (18.08%), fruits (15.07%), codes (13.70%),
concept descriptors (12.05%), menthol (10.96%), beverages (9.86%), sweet (8.22%),
miscellaneous (5.48%), pop culture (3.56%), tobacco (2.47%), and nuts (0.55%).
Flavor imagery, which appears in both discreet and indiscreet forms, is used to portray
flavors through both images and graphic elements explicitly.

Conclusions: E-cigarette flavors are more diverse than ever. Policymakers can
consider restoring the previous flavor ban stipulated in the Food and Drug
Administration Administrative Order 2021-1069 to reduce e-cigarette use prevalence.
However, regulatory ambiguity still surrounds the current effectivity of the flavor ban.
Clarifying the effectivity of the flavor ban is essential and must be complemented by
actively restricting e-cigarette access from unregulated channels and rigid retailer
compliance. The introduction of standardized or plain packaging can remove appeals
associated with packaging elements, including flavor descriptors and flavor imagery.
Stricter enforcement of policy provisions such as proof-of-age verification
mechanisms and promotional merchandise giveaways require further attention from
implementing agencies.

Keywords: e-cigarette, Vape Law, flavor, Philippines

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 Definition of Terms

All terms below are defined by Republic Act No. 11900 or the “Vaporized Nicotine
and Non-Nicotine Products Regulation Act.”
Vapor Products, also Refers to the liquid, solid, or gel, or any combination
referred to as Vapor thereof, which may or may not contain nicotine, that is
Product Refills transformed into an aerosol without combustion by a
Vapor Product Device.

Vapor Product Device Refers to a device or a combination of devices used to

heat a Vapor Product, to produce an aerosol, mist, or
vapor that users inhale. These may include
combinations of a liquid solution or gel that are heated
and transformed into an aerosol without combustion
through the employment of a mechanical or electronic
heating element, battery, or circuit, and includes, but is
not limited to, a cartridge, a tank, or a device without a
cartridge or tank.

Vapor Product System, also Refers to the specific combination consisting of the
referred to as electronic Vapor Product Refill and Vapor Product Device,
nicotine or non-nicotine which, based on the information made available to the
delivery systems consumer by the provider, are intended to be used
together.

Heated Tobacco Products Refers to tobacco products that are intended to be

(HTPs), also referred to as consumed through heating tobacco, either
Heated Tobacco Product electronically or through other means, sufficient to
(HTP) Consumables or release an aerosol that can be inhaled, without
Heat-Not-Burn Product combustion of the tobacco. HTP Consumables or
Consumables Heat-Not-Burn Product Consumables may also include
liquid solutions and gels that are part of the product
and are heated to generate an aerosol. HTPs may or
may not operate by means of an HTP Device.

Heated Tobacco Product Refers to the component or combination of

Device or HTP Device components of an HTP System intended to be used in
combination with HTP Consumables that generate an
aerosol without combustion.

Heated Tobacco Product Refers to an HTP Consumable and HTP Device that
System or HTP System are intended to be used together as a system.

Refill Refers to a container for holding electronic liquid or

Nicotine Mixture.

Novel Tobacco Products Refer to all non-combusted substances in solid or

liquid form, and innovations, either made partly of

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 tobacco leaf as raw material or containing nicotine
from tobacco, intended to be used as a substitute for
cigarettes or other combusted tobacco products.

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1. INTRODUCTION

The Philippines has suffered a high burden of tobacco use and tobacco-related
diseases. Tobacco contributes to 20% of non-communicable disease-related deaths,
where 112,00 Filipinos die from tobacco-related diseases annually (Campaign For
Tobacco-Free Kids, 2017). While tobacco use decreased from 29.7% in 2009 to
19.5% in 2021 (Cordero, 2023), the prevalence of e-cigarette use is on the rise. In the
Philippines, adults who have used e-cigarettes increased from 2.8% in 2015 to 5.7%
in 2021, and current users of e-cigarettes increased from 0.8% in 2015 to 2.1% in
2021 (Global Adult Tobacco Survey, 2017)(Global Adult Tobacco Survey Philippines,
2022). Compared to adults, e-cigarette use prevalence is more striking in younger
people who use e-cigarettes for their “social and novelty aspects” (Ween et al., 2021).
One in four students in the Philippines aged 13–15 years have used e-cigarettes at
least once in their lifetime, and one in seven currently use e-cigarettes (Serra et al.,
2023). Students are more likely to use e-cigarettes if they are boys, currently smoke
cigarettes or other tobacco products, and are exposed to secondhand smoke (Serra et
al., 2023). The gender gap in e-cigarette use in the Philippines is significant towards
younger and older males (Kundu et al., 2023)(Pan et al., 2022). Particularly in
Southeast Asia, the youth are active targets of e-cigarette flavors, trendy designs, and
point-of-sale promotions (van der Eijk et al., 2021).

Flavored e-cigarettes are gaining rapid popularity and appeal among the youth.
For many users of flavored e-cigarettes, flavors influence the initiation and continued
use of e-cigarettes (Landry et al., 2019). The popularity of flavored products is likely
due to flavors masking the taste of nicotine by simulating sweetness and perceptions
of “coolness” (Goldenson et al., 2019). Adolescents and young adults prefer fruit and
candy flavors—the most common e-cigarette flavors (Landry et al., 2019)(Soneji et
al., 2019). A study by Xiao and colleagues discovered that appealing flavors were the
most commonly reported motivation for using electronic nicotine delivery systems
(ENDS) (Xiao et al., 2019). Those who use flavored e-cigarettes tend to have greater
satisfaction and self-perceived addiction compared to those who use non-flavored
e-cigarettes (Landry et al., 2019). Studies have discovered that the youth are
diversifying e-liquid flavors by modifying e-liquids with substances such as illicit

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drugs like cannabis and cocaine (Churchill et al., 2023)(National Center for Chronic
Disease Prevention and Health Promotion (US) Office on Smoking and Health.,
2016). Youth-initiated modifications towards flavor creation were a response to
information provided by YouTube peers and to compensate for limited access to
e-cigarettes. All of these findings indicate that flavors used in e-cigarettes bring risks
that require effective and comprehensive e-cigarette regulation (Landry et al.,
2019)(Goldenson et al., 2019)(Soneji et al., 2019)(Xiao et al., 2019)(Churchill et al.,
2023)(National Center for Chronic Disease Prevention and Health Promotion (US)
Office on Smoking and Health., 2016).

Some countries have initiated policies regulating e-cigarettes and e-cigarette

flavors. As of 2021, 37 countries have banned the sale and distribution of e-cigarettes
(Global Center for Good Governance in Tobacco Control, 2021), but only a few have
imposed a flavor ban. In early 2020, the United States Food and Drug Administration
(FDA) enacted its flavor enforcement policy, restricting flavored e-cigarettes to
tobacco and menthol flavors only (Xie et al., 2022). Xie and colleagues (2022)
discovered that the FDA flavor enforcement policy prompted more mentions of
quitting vaping from Twitter users; however, another study discovered that youths
turned to brands and devices exempt from the restrictions (Hammond et al., 2022).
Finland, one of the European Union countries known for strict e-cigarette regulations,
has banned characterizing flavors in e-cigarette liquids marketing e-cigarettes (Ollila,
2019). However, enforcement of this policy is met with significant challenges,
including reluctance from e-cigarette retailers and limited resources for tobacco
control. A study by Wipfli and colleagues examined university students from 13
Asia-Pacific countries (including the Philippines, China, Malaysia, etc.) and their
perspectives on tobacco use and e-cigarette regulation (Wipfli et al., 2020). They
found that students were most likely to support campus bans and government
regulation of e-cigarettes if they were from countries with weak adoption of
MPOWER policies. Additionally, students in countries with e-cigarette bans were
least likely to experiment with e-cigarettes (Wipfli et al., 2020).

The Philippines has taken early regulatory action to control e-cigarettes.

However, the growing e-cigarette market in the country suggests that the Philippines
needs to rethink its approach to regulating e-cigarettes (van der Eijk et al., 2021). The

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Philippines’ Food and Drug Administration began regulating e-cigarette flavors in
2021 through Administrative Order (AO) 2021-1069 in compliance with Republic Act
No. 11467 and its Implementing Rules and Regulations (Food and Drug
Administration, 2022). Under AO 2021-1069, the Philippines prohibits e-cigarette
flavors other than plain tobacco or menthol. However, on July 25, 2022, the Vape
Regulation Bill was signed into law, now known as the Vaporized Nicotine and
Non-Nicotine Products Regulation Act or Vape Law. This law repeals provisions
related to health promotion stipulated in Republic Act No. 11467 by reducing the
minimum age of access from 21 years old to 18 years old, permitting the online
selling and advertising of e-cigarettes and HTPs, and lifting the flavor ban (Puyat et
al., 2023). Despite this, confusion still surrounds whether or not Vape Law has lifted
the flavor ban. Vape Law only has specific provisions for flavor descriptors,
specifically prohibiting flavor descriptors on e-cigarette packaging, advertising, and
promotion that appeal to minors. However, it does not specifically indicate the lifting
of the previous flavor ban, nor does it add more context to sustaining it if its
effectivity is still in motion. Nonetheless, these provisions, together with poor
enforcement of this regulation (Tingand, 2022), open a highly accessible gateway to
e-cigarette use, especially among the youth.

To date, no study has examined and characterized the spectrum of flavored

e-cigarette products in the Philippines. This study aims to categorize the flavor
descriptors of e-cigarette products, HTPs, e-liquid refills, and novel tobacco products
in the Philippines. Additionally, this paper aims to assess the implications of existing
e-cigarette policies on e-cigarette flavor control and regulation and how such
implications can potentially be addressed.

2. METHODS

2.1 Design

This study adopted the research design and methodology of the Tobacco Pack
Surveillance System (TPackSS) and its 2015 Field Collection Protocol, originally
developed by the Institute for Global Tobacco Control (IGTC) at the Johns Hopkins
Bloomberg School of Public Health.

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 Following the TPackSS protocol, our team gathered unique cigarette and cigar
packs from four cities in each region of the Philippines (National Capital Region,
Balanced Luzon, Visayas, and Mindanao) with the largest populations (Quezon City,
Antipolo City, Cebu City, and Davao City). We chose 12 neighborhoods (barangays)
for each city based on specific characteristics like population density, economic
importance, and geographical location. These characteristics served as a proxy for
socioeconomic classification, as outlined in the TPackSS protocol. Due to the
unavailability of such data from local authorities and publicly accessible sources, we
relied on proxy data.

Within each neighborhood, our team sampled six main types of vendors:
sari-sari stores (neighborhood stores), convenience stores, mall kiosks, street vendors,
supermarkets, and department stores. Our data collection process began with the
walking protocol prescribed in the TPackSS protocol. Starting from a commercial hub
in each neighborhood, our team walked for five minutes until we encountered one of
the six specified vendor types. We then purchased one of each unique pack available
for sale. Unique packs, according to the TPackSS protocol, encompass any pack with
distinct designs or features, including variations in stick count, size, brand
presentation, colors, cellophane wrapping, and inclusion of promotional items. In
subsequent neighborhoods, our team purchased one of each unique pack not already
obtained from previous vendors.

Upon completing purchases for the day, each pack was assigned a code,
photographed following TPackSS guidelines, and placed in individual ziplock bags.
We organized all photos into Google Drive folders for efficient documentation.

2.2 Coding

Following the collection of sample packs, our team utilized the TPackSS
codebook (Institute for Global Tobacco Control, 2016) to assign codes to each pack.
The codebook covers various packaging elements, including structural features like
size and shape, as well as graphic elements such as brand or flavor descriptors. Two
trained researchers conducted coding in two rounds to ensure result accuracy. A third
researcher joined the second round of coding to address any discrepancies identified
during the initial coding sessions.

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2.3 Sample

Our team collected 313 vapor products, vapor product devices, vapor product
systems, heated tobacco products, heated tobacco product devices, heated tobacco
product systems, refills, and novel tobacco products. Vapor products comprise pods or
cartridges for vapor product devices. Vapor product systems are products and devices
assembled into one unit, such as disposable vapes. HTPs include sticks or
consumables used to load heated tobacco product devices. HTP systems include the
product and device intended to be used together. Refills are containers that hold
e-liquid. Lastly, novel tobacco products included two nicotine pouches.

The inclusion criteria of this study encompass vapor products, vapor product
systems, refills, heated tobacco products, and novel tobacco products with flavor
descriptors.

2.4 Analysis

We conducted a thematic analysis using a combination of inductive and

deductive approaches. In our analysis, we identified 11 categories of flavor
descriptors: colors, fruits, codes, concept descriptors, menthol, beverages, sweet,
miscellaneous, pop culture, tobacco, and nuts. Color flavor descriptors explicitly
include colors in the flavor descriptor (e.g., “amber selection”). Fruits explicitly use
fruits as a flavor descriptor (e.g., “kiwi guava”). Codes use acronym-like words (e.g.,
STRW for strawberry). Menthol flavor descriptors are denoted by terms such as
“menthol,” “mint,” “ice,” “cool” or “frost.” Beverage flavor descriptors are
sub-categorized into soft drinks, milk, coffee, alcoholic drinks, and others. Sweet
flavor descriptors are further categorized into desserts, candy, and branded flavors.
Miscellaneous flavor descriptors denote objects, people figures (e.g., “emperor”),
adjectives (e.g., “lavacious”), or other arbitrary words or phrases. Pop culture flavor
descriptors reference public figures, slang words, fictional characters, or modern
practices (e.g., “summer fling”). Finally, nut flavor descriptors reference nutty flavors
such as almond or hazelnut.

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3. RESULTS

3.1 General Information

Our team collected a total of 315 products. Of these 315 products, 280
(88.89%) feature flavor descriptors (see Table 1). Of these 280 products with flavor
descriptors, the majority are vapor product systems (37.50%), followed by refills
(31.43%), vapor products (24.64%), heated tobacco products (5.71%), and novel
tobacco products (0.71%). 32.14% of products did not specify their manufacturer on
their packaging (see Table 4). Shenzhen RELX Technology Co., Ltd. (9.64%) and
Shenzhen Xuewe Technology Co., Ltd. (9.29%) comprise the next majority shares of
manufacturers. Most of the products (56.52%) are imported from China while
26.09% of the products are manufactured in the Philippines.

3.2 Flavor Descriptors

The team classified the 363 flavor descriptors into seven categories of flavor
descriptors: colors (18.08%), fruits (15.07%), codes (13.70%), concept descriptors
(12.05%), menthol (10.96%), beverages (9.86%), sweet (8.22%), miscellaneous
(5.48%), pop culture (3.56%), tobacco (2.47%), and nuts (0.55%) (see Table 5). Table
6 outlines key examples of flavor descriptors found in all 11 categories of this study.
Several flavor descriptors fit into more than one category, generating 363 flavor
descriptor entries across all categories.

Colors command the leading shares of flavor descriptor categories. In this

category, colors are typically used in three ways: as plain colors, as adjectives for
other words, or as nouns themselves. Plain colors include examples such as
“Emerald” or “Rainbow”. Colors are used to describe other words, with examples
being “Purple Snow,” “Red Summer,” or “Golden Slice.” Descriptive terms are the
most common method for how colors are typically used as flavor descriptors. Colors
can also be used as nouns like “Tropical Gold,” “Tangy Purple,” or “Sour Green.” For
some color flavor descriptors, their actual flavors are occasionally specified on the
packaging as well. “Sour Green” connotes “Sour Apple,” “Purple Ice” connotes
“Candy Grapes,” and “Luscious Green” connotes “Avocado Milk.”

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 Similarly, fruit flavor descriptors come as plain fruit flavors or flavors for
other food and drinks. Plain fruit flavors can span from “Mango,” “Grapefruit,” or
“Watermelon,” with some fruit flavor descriptors combining more than one fruit:
“Kiwi Guava,” “Strawberry Apple Banana,” or “Kiwi Strawberry.” Fruit flavor
descriptors also include those that describe fruit-flavored food and drinks like “Grapes
bubblegum,” “Mango Milkshake,” or “Popsicle Grapes.” Some fruit flavor descriptors
are included as a “secondary” flavor descriptor meant to connote the real flavor of the
primary flavor descriptor. For example, “Orchard Round” as the primary flavor
descriptor is “Peach Ice”; “Fucc Girl” is meant to be “Ice Strawberry Bitch”; and
“Mia Khalifa” is actually “Raspberry Ice”.

Codes are also a common flavor descriptor in our sample. Codes are designed
to conceal the true flavor of the product to reduce appeal to minors. Codes are formed
as acronym-like structures or shortened words or phrases in our sample. For example,
acronym-like codes include “STRW,” “MCH GHM,” and “GLC.” In some cases,
these codes can be deduced (e.g., where “STRW” can indicate strawberry). In other
cases, codes are explicitly defined on the packaging (e.g., “GLC” for grapefruit lime
cocktail). Some packs with code flavor descriptors also have imagery that provides a
better idea of the true flavor (e.g., pictures of strawberries on the packaging). In
certain cases, codes may lack clear definitions; however, it is typical for retailers to
maintain a codebook that buyers can refer to in order to understand which codes
correspond to specific flavors. Meanwhile, shortened words or phrases would include
those like “Blbrry,” “GinPom,” or “Bball.”

Cohen and colleagues define concept descriptors as “terms that imply that
some type of flavor, sensation, taste, or aroma awaits the consumer” (Cohen et al.,
2021). We identified several variations of concept descriptors, with examples being
“Jungle Fusion,” “Mellow Melody,” and “Dreamy Swirl.” One product in our sample
featured four flavors in one disposable device, with flavor descriptors including
“frozen oasis, chilled dopamine,” “tropical mist,” and “bubble burst.”

Menthol is denoted through a more diverse set of keywords. Aside from

“menthol” and “mint”, words such as “ice,” “frost,” “frozen,” or “cool” typically
reference menthol flavors. It is common to see menthol flavors in tandem with other
flavors. For example, “Peach Ice,” “Frost Melo,” and “Frozen Oasis” imply certain
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flavors with menthol or a “cooling” flavor combined with it. Menthol e-cigarette
products, specifically refills, are typically characterized by neon green caps or
packaging. Plain menthol flavor descriptors include “Menthol”, “Menthol Xtra”, or
“Blue Mint”.

Beverage flavor descriptors have the most diverse set of subcategories.

Subcategories include alcoholic beverages, coffee, milk, soda, and others. Alcoholic
beverages include “Pina Colada,” “Lemon Mojito,” and “Grapefruit Lime Cocktail”.
Coffee includes “Latte Coffee,” “Choco Macchiato,” and “Mocha Latte.” Milk
includes “Oat Milk,” “Cantaloupe Milk,” and “Banana Milk Ice.” Soda includes “Ice
Cola,” Orange Soda,” and “Ribena”. Lastly, other beverage flavor descriptors include
“Pink Lemonade,” “Ginger Tea,” and “Red Bull sorbet.”

Sweet flavor descriptors are divided into dessert, candy, or branded sweets
subcategories. Dessert flavor descriptors range from “Mango Cheesecake, “Special
Halo-halo” (a cold Filipino dessert with shaved or crushed ice mixed with milk and
various local fruits and desserts), and “Ube Brazo de Mercedes,” (a traditional
Filipino meringue roll with a custard filling dusted with powdered sugar) where we
observed a mix of local and non-local desserts. Flavor descriptors such as
“Watermelon Candy,” “Grapes Bubblegum,” and “Pastillas Supreme” fall under the
candy subcategory. Lastly, branded sweets include “Melona,” “Twinkies RY4,” and
“Dynamite Candy.”

Miscellaneous flavor descriptors denote certain objects, places, or people that

do not necessarily connote a flavor, sensation, taste, or experience. Examples of these
include “Bazooka+,” “Lucid Dream,” “Granny's Fave,” “Garden’s Heart,” and “Venus
Fantasy.” For most of these flavor descriptors, no definition of their actual flavors was
specified on the box except for one: “Orchard Rounds,” which is actually “Peach Ice.”

Pop culture flavor descriptors reference certain slang words or people (both
fictional and nonfictional). Slang words include “Fucc Boi,” “Triple Favs,” (where the
actual flavors of Triple Favs are honeydew, melon, and straw), or “Petmalu” (an
anagram of the Filipino word malupit which means “amazing” or “awesome”). People
flavor descriptors include both nicknames and full names of people such as: “Black

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Mamba” (a nickname for NBA player Kobe Bryant), “Harlequin” (a fictional DC
Comics character), and “Mia Khalifa” (a former pornography personality).

Lastly, tobacco flavor descriptors range from “Virginia Tobacco,” “Brightleaf

Tobacco,” and “Richman's Tobacco,” while nut flavor descriptors range from
“Almond RY4” and “Hazelnut Brown.” Upon further research, RY4 is a common
tobacco, vanilla, and caramel blend (Vape Passion, 2018).

3.3 Flavor Imagery

Our team observed distinct uses of flavor imagery across different types of our
sample of e-cigarette products. E-liquid refills commonly feature more realistic
images of flavors through pictures of desserts, fruits, candy, or ice (see the first two
images of Figure 7 in Appendix B). Disposable e-cigarettes, categorized as “vapor
product systems,” do not usually feature images of flavors; rather, vibrant colors,
holographic/reflective accents, and three-dimensional textures are used to boost
product appeal (see image one of Figure 8 in Appendix B). Colors relate to the
product's flavor; for example, blueberry-flavored products will have blue packaging,
while menthol-flavored products will have green packaging. Product appeal is also
driven by including pictures of the device itself, offering a “sneak peek” to buyers
interested in the product.

Some e-cigarette brands also have flavor series with sub-flavors available.
One e-cigarette brand has a “Yakult series,” a probiotic drink originally from Japan.
Melon is a sub-flavor of this series where images of the Yakult drink and melons are
evident on the bottle packaging. Other e-cigarette brands have less direct flavor series.
One example is “Infinity Series,” which has flavors such as “Saucy Boy,” “Island
Breeze,” and “Tangy Purple.”

The team also observed iconography on e-cigarette products, which is

specifically common for menthol-flavored products. Several packs featured ranking
for the level of “coolness” provided by the product. These levels would appear as
shaded bars depending on the coolness level from “low” to “high.” A similar
iconographic feature was observed in some packs to indicate the level of sweetness,
richness, and intensity of a certain product.

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3.4 Marketing Strategies

E-cigarette products are quickly innovating to make their products more

appealing and unique to consumers. For example, several of our sample products were
designed to offer more than one flavor in one product. One device allows consumers
to switch between four flavors (with flavor descriptors “frozen oasis,” “chilled
dopamine,” “tropical mist,” and “bubble burst”) through a simple switch on the top of
the product. Several products are also uniquely designed; for instance, devices come
in various shapes, such as milk cartons or drink bottles, even if they are not
beverage-flavored.

Other marketing tactics such as free branded lanyards, pamphlets, promo

deals, taglines, social media plugs, and scratch-off stickers are common tactics used
by retailers to market e-cigarette products.

3.5 Observations on Implementation

While collecting our samples, our team observed mixed levels of compliance
with regulations on flavor descriptors for e-cigarette packaging.

One indication of this is the inconsistency in presenting flavor descriptors. For

example, for several packs, it was evident that the original flavor descriptor printed on
the packaging was covered with a sticker or paper to conceal the true flavor
descriptor. In image four of Figure 1 from Appendix B, the original flavor descriptor
“Avocado Milk” is concealed by a paper labeled “Luscious Green.” Such labeling
may inadvertently seem to comply with the prohibition of “unduly appealing” flavor
descriptors under Vape Law. However, not producing updated packaging showcases
careless compliance.

We also found sticker labels with the true flavor of the e-cigarette placed on
top of the packaging, despite having an inconspicuous flavor descriptor printed on the
original packaging. In some instances, the packaging of an e-cigarette device will
feature an “unduly appealing” flavor descriptor, but upon checking the device, there is
a different flavor descriptor. For example, in one disposable e-cigarette sample, its
packaging indicated “BBALL” as the flavor descriptor, but the flavor descriptor
indicated on the device was “Butterball.”

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 When purchasing e-cigarettes, it was common for our team to come across
codebooks for coded e-cigarette products. Codebooks are booklets or laminated
menus of available e-cigarette flavors provided to the buyer by the sales
representative. In one encounter with a local e-cigarette retailer, the salesman shared
with our team that codes are used to comply with DTI regulations on flavor
descriptors and remove appeal to minors. With that, codebooks provide a loophole for
e-cigarette retailers to continue selling flavored products while still complying with
Vape Law requirements.

4. DISCUSSION

According to the World Health Organization (WHO), the global e-cigarette

market is rapidly growing, consisting of diverse products and flavors that are
“aggressively marketed targeting children and young people” (World Health
Organization, 2023a). In response to this, in December 2023 they issued a
recommendation for governments to regulate e-cigarettes in line with tobacco
products and to ban all flavors (Reuters, 2023)(World Health Organization, 2023c).
The DOH is likewise cognizant of the public health harms of e-cigarettes. However,
they recognize that “stronger implementation” is still required to further prevent and
reduce e-cigarette use, especially among the youth (Montemayor, 2024). Given the
mixed implementation of flavored e-cigarette regulation (Puyat et al., 2023), there is
still a significant opportunity to strengthen flavored and non-flavored e-cigarette
regulation.

4.1 Challenges with product innovation

Flavors are known to increase satisfaction and enjoyment of e-cigarette use

(Soule et al., 2016). Our findings confirm that the e-cigarette industry is continuously
innovating flavors beyond traditional tobacco or menthol flavors. Some flavor
categories partly respond to conflicting regulations surrounding flavored e-cigarette
products.

Flavor categories discovered in this study such as fruits, sweets, and menthol
typically appeal to youth or young adults. Pang and colleagues (2020) discovered that
young adult males find fruit-flavored e-cigarettes more appealing, while young adult
females find both fruit- and menthol-flavored e-cigarettes more appealing (Pang et al.,
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2020). Goldenson and colleagues (2016) confirmed that young adult e-cigarette users
prefer sweet flavors over non-sweet or flavorless e-cigarettes (Goldenson et al., 2016).
Schneller and colleagues (2019) concluded that the youth are more likely to use
non-tobacco e-cigarette flavors such as fruit and candy (Schneller et al., 2019). In our
study, tobacco was ranked tenth in frequency, while fruit and candy ranked second
and seventh, respectively. This high ubiquity of youth-appealing flavors such as fruit
and candy warrants concern for public health—especially when contextualized in
common youth and adolescent perceptions of e-cigarettes.

For example, youths who are ever and current e-cigarette users are more likely
to perceive flavored e-cigarettes as less harmful than non-flavored e-cigarettes
(Cooper et al., 2016). Adolescents are more likely to be interested in trying menthol,
candy, or fruit-flavored e-cigarettes and to view these flavors as less harmful than
tobacco-flavored e-cigarettes (Pepper et al., 2016). Additionally, certain flavors, such
as menthol or ice-hybrid flavors can lead to more frequent vaping and nicotine
dependence among adolescents and young adults (Katz et al., 2022). This is
dangerous considering that nicotine is particularly strong in children and young adults
(Bhalerao et al., 2019).

Nonsmoking young adults report greater liking and intent to try sweet- and
fruit-flavored e-cigarettes (Garrison et al., 2018). However, flavored e-cigarettes are
also appealing to current smokers looking to cut down on smoking (Soule et al.,
2016). A 2019 study by Chen and colleagues found that young adult smokers who use
e-cigarettes to reduce smoking enjoy fruit, candy, dessert, or menthol/mint e-cigarette
flavors (Chen et al., 2019). The same study discovered that young adult smokers
perceive e-cigarette flavors as conducive to decreasing smoking habits due to
“increased e-cigarette use frequency and duration.”

Flavors are likewise dangerous due to their rewarding and reinforcing value
(Audrain-McGovern et al., 2016). With this notion, together with having little
knowledge of the nicotine concentrations in their e-cigarettes (Pepper et al.,
2016)(Chen et al., 2019), smokers who use flavored e-cigarettes are at risk of
increased abuse liability (Audrain-McGovern et al., 2016). Additionally, since
nicotine is a gateway drug (Kandel & Kandel, 2014), using e-cigarettes that have
nicotine can lower the threshold for addiction to other drugs, such as opioids (Drazen
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et al., 2019). Given that there were 1.7 million Filipinos taking drugs in 2019 (Junio,
2021), 14.4 million adults currently smoking tobacco in 2021 (Global Adult Tobacco
Survey Philippines, 2022), and 10.8% of students currently smoking tobacco in 2019
(Global Youth Tobacco Survey Philippines, 2021), it is crucial to enforce
comprehensive policies that protect the collateral interests of the public against the
harms of e-cigarette use.

4.2 Challenges with implementing the Vape Law: Policy loopholes

In addition to analyzing the diverse flavors available in our sample, our team
also observed several gaps and loopholes in enforcing the Vape Law. For example,
under Vape Law, flavor descriptors proven to be unduly appealing, particularly to
minors, are prohibited, specifically if they “include a reference to a fruit, candy brand,
dessert, or cartoon character.”

Our team observed that this provision is yet to be fully complied with. We
discovered flavor descriptor categories such as fruit, sweet, and pop culture with
specific reference to fruits, candy brands, desserts, and cartoon characters. Slang
words, a subcategory of pop culture, also reference phrases that are appealing to
minors yet are not specified as such under Vape Law. Other categories likewise appeal
to certain demographics; for example, alcoholic beverages or coffee can appeal to
adults who consume such beverages. On the other hand, people references such as
basketball icons (e.g., “Black Mamba”) can evoke Filipinos’ characteristic love for
basketball.

Some categories of flavor descriptors take advantage of loopholes discovered

in Vape Law. For instance, e-cigarette companies circumnavigate “unduly appealing”
flavor descriptors by using colors and codes as flavor descriptors. These two
categories of flavor descriptors comprised the leading frequencies in our sample;
however, these two categories do not necessarily reduce the appeal of e-cigarette
products. Colors play a vital role in boosting the appeal of e-cigarette products
(Khambayat et al., 2023)(Pokhrel et al., 2015). Additionally, flavor descriptor codes
are undermined by codebooks that buyers can peruse to decipher the flavor of a coded
e-cigarette product. These color and code flavor descriptors are also usually sweet or
fruity flavors concealed purely by the descriptor itself.

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 The ambiguity of Vape Law’s repealing clause also lends space for mixed
interpretations of the law. The repealing clause is phrased as a catch-all statement that
repeals all “laws, decrees, rules and regulations” that govern vaporized nicotine and
non-nicotine products or their devices, and novel tobacco products. With no mention
of specific policies or regulations, the common interpretation of this provision could
be that all previous policies such as the e-cigarette flavor ban stipulated in AO
2021-1069 are void. Despite this, e-cigarette businesses have not caught up from the
ban of flavors of AO 2021-1069 to the ban of unduly appealing flavor descriptors of
RA 11900. This is evidenced by the flavor categories such as fruits, sweets, or pop
culture that we discovered in this study.

Another notable loophole is the lack of regulation on the e-cigarette device

and system itself. Through our observations, uniquely shaped devices in the form of
energy drinks, juice boxes, or milk cartons are very common. This has direct
implications for children and the youth, two demographics who typically drink these
variations of beverages. With no regulation on device variations in Vape Law, there is
ample room for the e-cigarette industry to subtly target younger audiences.

Lastly, the use of freebies and promotional tactics such as branded lanyards or
social media handle plugs directly violate the prohibition of promotional merchandise
under the Vape Law. Promotional merchandise can be viewed as a form of “brand
stretching” or “trademark diversification” where brand names are used on
non-tobacco or non-e-cigarette products (Campaign For Tobacco-Free Kids, n.d.).
Unfortunately, these promotional items continue to circulate in e-cigarette businesses
and can give more attention to the novelty and appeal of flavored e-cigarettes.

4.3 Opportunities to regulate flavor imagery

Our team observed that flavor imagery is tied closely with flavor descriptors.
It is common for e-cigarette products to feature inviting, attractive, and appealing
images that reference specific flavors. This is significantly concerning since flavor
imagery is not regulated by Vape Law.

There are several implications of the lack of regulation on flavor imagery.

Flavor imagery not only entices consumers but disrupts other health interventions on
e-cigarette packaging. For example, a 2018 study by Garrison and colleagues found
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that sweet and fruit e-cigarette imagery on ads is known to interfere with warning
labels (Garrison et al., 2018). The same study also examined cue-reactivity, which is
the physiological, psychological, or cognitive responses related to reward anticipation
(Science Direct, n.d.). The study found that cue-reactivity is greater for sweet or fruit
flavors than for tobacco flavors. Images also affect harm perceptions and promote
appeals (Soule et al., 2019).

4.4 Opportunities for a flavor ban and regulations on accessibility

A study conducted by the FDA in the U.S. discovered that young e-cigarette
users have a higher tendency to use flavored e-cigarettes compared to adult e-cigarette
users (Campaign For Tobacco-Free Kids, 2023). In the Philippines, a study by the
Philippine Pediatric Society found that varied flavors—along with online accessibility
and misconceptions of harm—are leading reasons why youth use e-cigarettes (Vital
Strategies, n.d.). As such, policy regulations must cater to both young and adult
populations—especially to the former.

Amendments to Vape Law may be necessary to clarify the nature and extent
of prohibited flavors in e-cigarettes. This can include further defining which flavor
descriptors are banned or prohibited. Flavor descriptors such as colors and concept
descriptors must be banned as they can be appealing. In particular, the use of colors
for packaging designs and as flavor descriptors must be closely regulated to reduce
any consumer biases accompanied by color preferences. Code flavor descriptors and
the availability of codebooks, which actively circumnavigate the potential consumer
appeals, should be accounted for in these potential amendments.

Additionally, stricter enforcement is critical to ensuring the success of

effective e-cigarette regulations. Through our data collection process, our team
observed several gaps and loopholes in implementing the Vape Law. For example,
most e-cigarette retailers possess a codebook that allows the buyer to see what flavors
certain codes pertain to. No retailers that our team purchased from asked for forms of
identification during purchase. Flavor imagery continues to remain unregulated
despite its instrumental role in e-cigarette appeal. With these existing gaps, it is
possible for minors not only to gravitate toward flavored e-cigarette products but to
also easily access them. One way to prevent this is by focusing on age-verification

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interventions. lax age-verification enforcement may be contributed by retailers
believing there is little to no risk of noncompliance as a result of irregular law
enforcement compliance checks (Schiff et al., 2020). Age-verification mechanisms
can be strengthened by educating retailers on these non-compliance consequences and
investing in advanced age-verification technologies. This must be accompanied by
routine and regular enforcement compliance efforts. At present, compliance is hinged
only on private citizens who are mandated to forward non-compliance complaints to
the DTI. However, a task force or dedicated group of enforcers is highly ideal to
ensure that age verification and other legal requirements are fulfilled.

Our recommendations are guided by the direction of the WHO in regulating

e-cigarettes. The WHO recommends several policy options to regulate e-cigarettes,
catering to existing interventions implemented by countries (World Health
Organization, 2022a)(World Health Organization, 2023a)(World Health Organization,
2023c). For countries such as the Philippines that permit the sale, importation,
distribution, and manufacture of e-cigarettes, regulations must be strengthened to
reduce the appeal and harm of e-cigarettes. Such interventions include taxation, a
flavor ban, and limiting the concentration and quality of nicotine.

Taxation is the most effective measure to reduce the use of e-cigarettes.

Increasing the excise tax on e-cigarettes can reduce the affordability of these products,
especially for the youth (World Health Organization, n.d.). At present, the Philippines
imposes a 12% VAT on the sale and importation of e-cigarettes (National Tax
Research Center, 2014). However, according to the WHO, excise taxes are ideal as
they “raise the relative price of tobacco and nicotine products compared to other
products and services” (World Health Organization, n.d.). An excise tax imposition,
specifically on an ad valorem basis, can further limit e-cigarette consumption,
discourage initiating e-cigarette use, and subsequently prevent e-cigarette-related
diseases (National Tax Research Center, 2014).

Another way forward is to introduce plain packaging—forcing the industry to

remove logos, colors, brand images, or promotional information on packaging other
than brand names and product names displayed in a standard color and font style
(World Health Organization, 2022b). It can be an effective method to eliminate
packaging as a marketing tool, to reduce the attractiveness and appeal of flavored
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e-cigarette products, and to increase the noticeability and effectiveness of health
warnings. This, in turn, eliminates the deceptive appeals that come with e-cigarette
products through flavor descriptors and imagery.

Lastly, and most crucially, there is a pressing need for the seamless integration
and effective communication of subsequent e-cigarette flavor regulations. Initially, the
FDA's AO 2021-1069 banned all e-cigarette flavors except tobacco and menthol, but
subsequent legislation such as Vape Law has caused ambiguity. While Vape Law's
repealing clause purportedly overturned certain regulations, including the flavor ban,
it lacks clarity on reinstating or removing the ban and any new flavor-related
restrictions. E-cigarette businesses may argue that flavor bans contradict Vape Law,
which primarily regulates specific flavor descriptors rather than outright bans.
Consequently, many businesses have interpreted Vape Law as nullifying the FDA's
flavor ban, leading to concerns about potential misinterpretations and adverse public
health consequences. Moving forward, clear and explicit language in future
regulations is essential to remove ambiguity, prevent loophole exploitation, and
safeguard public health interests.

In clarifying the existence of a flavor ban, a flavor ban must be characterized

by the complete ban of flavored products together with flavor descriptors and flavor
imagery. Multiple studies have confirmed that e-cigarette users are more likely to quit
or significantly reduce using e-cigarettes under a flavor ban (Chen et al., 2019)(Yang
et al., 2020)(Yang et al., 2023). However, a flavor ban has to be complemented by
strict implementation. Evidence shows that while flavor bans can reduce e-cigarette
use, poorly regulated accessibility to e-cigarette products (Yang et al., 2020)(Yang et
al., 2023) together with retailer non-compliance (Yang et al., 2020) can hamper these
efforts.

4.5 Limitations of the Study

Due to budgetary constraints, our team was unable to purchase all unique
e-cigarette products from each retailer we visited. This constraint is also amplified by
the high diversity of product variations offered by retailers. However, we ensured the
representation of our sample by closely following the TPackSS protocol and
prioritizing buying unique products from retailer to retailer. Additionally, this study

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did not delve into consumer perceptions and preferences of e-cigarette flavors in the
Philippines. Future studies can explore consumer perceptions and consumer behavior
to further inform existing e-cigarette control and regulations.

5. CONCLUSION & RECOMMENDATIONS

Our study characterized 11 categories of distinct e-cigarette flavors amongst a sample

of 280 vapor products, vapor product systems, refills, heated tobacco products, and
novel tobacco products. These 11 categories, in order of frequency, are colors, fruits,
codes, concept descriptors, menthol, beverages, dessert/sweet/candy, miscellaneous,
pop culture, tobacco, and nuts. Multiple flavor descriptors fit into more than one
category, lending 363 flavor descriptors across all categories. Our team observed
implementation gaps in Vape Law throughout the data collection process such as the
availability of codebooks for coded e-cigarette products and no retailers asking for
identification during purchase. Local e-cigarette flavors are diversifying which
demands stricter regulation for the protection of public health, especially among
children and the youth. Restoring the flavor ban stipulated in AO 2021-1069 can
dramatically decrease the availability of flavored e-cigarette products. However, a
flavor ban must be accompanied by the restricted availability of e-cigarette products
from unregulated channels together with rigid retailer compliance with prevailing
flavor ban regulations. —

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 Appendix A

Table 1. Sample breakdown of products with and without flavor descriptors

Products Count Percentage

With flavor descriptors 280 89.46%
Without flavor descriptors 33 10.54%
Total 313 100.00%

Table 2. Type of product for samples with flavor descriptors

Type of product Count Percentage

Vapor Product System 105 37.50%
Refill 88 31.43%
Vapor Product 69 24.64%
Heated Tobacco Product 16 5.71%
Novel Tobacco Products 2 0.71%
Total 280 100.00%

Table 3. Type of store

Type of store Count Percentage

Mall Kiosk 142 50.71%
Street Vendor 108 38.57%
Convenience Store 23 8.21%
Supermarket 3 1.07%
Sari-Sari Store 2 0.71%
Market Stall 2 0.71%
Total 280 100.00%

Table 4. Manufacturer distribution

Manufacturer Count Percentage Country

Not specified 90 32.14% Unknown
Shenzhen RELX
27 9.64% China
Technology Co., Ltd.
Shenzhen Xuewe
26 9.29% China
Technology Co., Ltd.
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 Denkat Trading
14 5.00% Philippines
Corp.
Shenzhen Tardigrade
8 2.86% China
Technologies Inc.
Shenzhen Dispo
6 2.14% China
Technology Co., Ltd.
P.T. Hanjaya
Mandala Sampoerna 6 2.14% Indonesia
Tbk.
Milson Tech. 6 2.14% China
China Tobacco
Hubei Industrial Co., 6 2.14% China
Ltd.
YME Technology
4 1.43% China
Limited
Shenzhen Nevoks
4 1.43% China
Technology Co. Ltd.
Shenzhen Galaxy
Fenghua Technology 4 1.43% China
Co., Ltd.
Shenzhen EHPRO
4 1.43% China
Technology Co., Ltd.
Philip Morris
4 1.43% Switzerland
Products S.A.
Genome Flavor
4 1.43% China
Technology
Flava Corporation 4 1.43% China
Amyooz (HK)
4 1.43% China
Limited
4:20 O'CLOCK 4 1.43% Philippines
United Castle
International Co., 3 1.07% Hong Kong
Ltd.
Shenzhen YXC
3 1.07% China
Technology Limited
Shenzhen IVPS
3 1.07% China
Technology Co., Ltd.

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 Shenzhen
Aixingwang
3 1.07% China
Electronic
Technology Co., Ltd.
DVMYL Juice 3 1.07% Philippines
Creamy Creations 3 1.07% Philippines
Cholo's Vape Juice
3 1.07% Philippines
Manufacturing
ZCrew International
2 0.71% Philippines
Inc.
vookbar 2 0.71% China
Vipo PH Ventures
2 0.71% Philippines
OPC
VIP Bros 2 0.71% Philippines
Shenzhen Genome
Flavour Technology
Co., Ltd., Shenzhen 2 0.71% China
Lost Vape
Technology Ltd.
Silvisworks
2 0.71% Philippines
Philippines
Shenzhen Genome
Flavour Technology 2 0.71% China
Co., Ltd.
Shenzhen Danmoo
2 0.71% China
Technology
Shenzhen
Cahngneng Huike 2 0.71% China
Technology Co., Ltd.
Master Vapor 2 0.71% Philippines
Japan Tobacco
2 0.71% Japan
International
Dongguan Vandy
2 0.71% China
Technology Co., Ltd.
Bengbu Qiwu
Electronics 2 0.71% China
Technology Co., Ltd.

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 ShenZhen
WeiYiKang
Technology Co., Ltd. 1 0.36% China
and Yousi
Technology Co., Ltd.
Shenzhen Uwell
1 0.36% China
Technology Co., Ltd.
Shenzhen Goldwin
1 0.36% China
Technology Co., Ltd.
Liquido
1 0.36% Philippines
Manufacturing
Imirable (Shenzhen)
1 0.36% China
Technology Co., Ltd.
Fruttakool Vape
1 0.36% Philippines
Juice Manufacturing
Ethereal Fumes Vape
1 0.36% Unknown
Juice Manufacturing
Drizzle E-Juice
1 0.36% Philippines
Manufacturing
Total 280 100.00%

Table 5. Flavor descriptor categories breakdown

Flavor Descriptor Count Percentage

Colors 64 17.63%
Fruits 55 15.15%
Codes 51 14.05%
Concept Descriptor 40 11.02%
Menthol 39 10.74%
Beverages 36 9.92%
Dessert/Sweet/Candy 30 8.26%
Miscellaneous 25 6.89%
Pop Culture 12 3.31%
Tobacco 9 2.48%
Nuts 2 0.55%
Total 363 100.00%

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Table 6. Flavor descriptor category samples

Flavor Descriptor Subcategory Examples

Tangy Purple
Tropical Gold
Colors Amber Selection
Crimson Combo
Luscious Green
Strawberry Apple Banana
Passion Fruit Sunrise
Fruity Lychee Ice
Kiwi Guava
Sour Apple
MCM (Mocha Cookie Milkshake)
BBall (butterball)
Codes SIC
GinPom
CADOAVO
Jungle Fusion
Mellow Melody
Dreamy Swirl
Concept Descriptor
Frozen oasis, chilled dopamine,
tropical mist, bubble burst
Rich Roast
Menthol Menthol Xtra
Menthol Plus
Mint
Cool Fresh
Spearmint Intense
Menthol Minty Spears

Ice Ice Fresh

Ice Mango
Alcoholic beverage Pina Colada
Lemon Mojito
Grapefruit Lime Cocktail
Beverages
Coffee Latte Coffee
Choco Macchiato
Mocha Latte

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 Milk Oat Milk
Cantaloupe Milk
Banana Milk Ice

Soda Ice Cola

Orange Soda
Ribena

Others Pink Lemonade

Ginger Tea
Red bull sorbet
Dessert Mango Cheesecake
Ube brazo de mercedes
Special Halo-halo

Candy Watermelon Candy

Dessert/Sweet/Candy Grapes bubblegum
Pastillas supreme

Branded sweets Melona

Twinkies RY4
Dynamite Candy
Bazooka+
Lucid Dream
Miscellaneous Granny's Fave
Garden's Heart
Venus Fantasy
Slang words Petmalu
Fucc Boi
Pink OG
Pop Culture
People Harlequin
Black Mamba
Mia Khalifa
Virginia Tobacco
Brightleaf Tobacco
Tobacco
Classic Tobacco
Richman's Tobacco
Almond RY4
Nuts
Hazelnut Brown

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 Appendix B (see gallery through this link)

Figure 1. Color flavor descriptors

Figure 2. Fruity flavor descriptors

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Figure 3. Code flavor descriptors

Figure 4. Concept descriptors

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Figure 5. Menthol flavor descriptors

Figure 6. Beverage flavor descriptors

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Figure 7. Sweet flavor descriptors

Figure 8. Miscellaneous flavor descriptors

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Figure 9. Pop culture flavor descriptors

Figure 10. Tobacco flavor descriptors

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Figure 11. Nut flavor descriptors

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