New Paper Reports Inaccuracies In E-Liquid Nicotine Labels
A new paper by Barrett H. Raymond and other researchers at Brigham Young University reports that the stated nicotine content of some American-made e-cigarette liquid is not as accurate as it should be. While benefiting consumers was clearly not the goal of this research, it is still a small contribution toward consumer protection.
The authors’ method for selecting which liquids to analyze was odd, but was sufficient to allow the researchers to choose non-obscure products despite their minimal understanding of vaping. The brand and flavor of the the liquids tested, though not the retailer they were purchased from, are identified in the paper. The method used to measure the nicotine concentration, while not perfectly precise, seems sufficient to support their major observations (assuming there were no big lab errors, something that is always a possibility).
The paper reports substantial quantities of nicotine in several of the samples that were labeled zero-nicotine. It is uninteresting that 26 of the 35 liquids labeled as zero-nicotine contained traces of nicotine. Trivial cross-contamination is almost inevitable in manufacturing, and this is inconsequential for vapers. (Trace cross-contamination is why useful allergen statements on foods state whether potential allergens touch the same equipment or are present in the facility, but this only affects people with very sensitive allergies.) What is interesting is that 6 of the 10 samples from two manufacturers had concentrations ranging from 6 to 24 mg/ml. These were probably labeling errors rather than huge manufacturing errors (e.g., zero-nicotine labels were put on bottles from a batch of 6 mg/ml liquid). But either way, it is a failure to provide consumers what they thought they were getting.
The researchers also tested 35 bottles labeled 18 mg/ml, and for 10 they reported nicotine quantities that differed from that by more than 20 percent. There was nothing quite so dramatic as “zero nicotine” liquid that really contained more than 20 mg/ml but, again assuming the analysis was accurate, the results represents quite a bit of deviation.
The authors conclude that incorrect nicotine concentration “poses a significant risk to consumers” and “supports the recent regulation changes enacted by the US Food and Drug Administration.” Both of these are false. These errors in concentration mean that someone is not getting the vaping experience they want, but pose no risk. The FDA regulations do nothing to protect consumers from faulty or mislabeled products, and there is no indication the FDA has any interest in developing the capacity for testing and enforcement.
These conclusions, along with the introduction and discussion, show that the authors know very little about the topic. They present a scattered collection of random facts and popular falsehoods about vapor products and vaping. Most striking, they refer to the substrate in e-liquid as ethylene glycol, a toxic chemical found in antifreeze, as opposed to propylene glycol. This is a glaring error that is sufficient to show that they (and everyone who reviewed the paper) lack even a casual familiarity.
Still, they could recognize the low-hanging fruit of testing nicotine concentrations. Their profound ignorance about the subject matter calls everything about this paper into question. But it does not necessarily mean the independent lab they employed did bad work or that they transcribed the results incorrectly.
The authors should have done more robust research. It would have been trivial to buy and test more than one bottle of each liquid variety, and retest the samples that differed dramatically from the label. Despite the nonexistence of the supposed risk, the reported errors are still serious accusations that should not be based on a single lab test. Good scientists, and good consumer protection researchers, follow up on the anomalies they find, rather than just reporting them. They could have sought samples from multiple retailers and batches to try to determine if problems were just one-off or if they persisted.
All that aside, if these results are even mostly correct, they suggest that it is not rare for vapers to not get the nicotine concentration they expected. Presumably manufacturers, retailers, and especially consumers would all agree that the reported rate of error represents more error than they expect.