The OCSA represents over 6,000 Ontario family run convenience stores in every community. Tobacco is our largest customer category; representing 40-60% of daily sales. Convenience stores have a high reliance on tobacco sales as we sell 95% of all tobacco in Ontario and speed of service is an expectation of all customers. Our industry wants to work with government on the implementation of this initiative as well as to foster a cooperative relationship with regard to rules and regulations going forward. Some recommendations can be found below.

A) Allow retailers to receive tobacco with an exterior overwrap on the carton in the present colors in order to help distinguish the products from storage and facilitate replenishment behind the sales floor covers. This will also assist us to distinguish between illegal and legal products. Once opened (never viewed by customers) all products would be plain packaging compliant in the sales areas. This will assist in the receiving of orders, inventory counts (back room) and replenishing of stock for all staff.
B) Allow for a removable transparent overwrap on packages that would assist staff in product selection from behind the flaps (speed of service) that can easily be removed prior to the sale to customers. It is very difficult to distinguish the over 150 SKUs being sold from behind the covers and many times the customers assists clerks in selecting the right formats.
C) Increase the enforcement on contraband tobacco and the illegal production of untaxed cigarettes to minimize the possibility of illegal factories producing and distributing counterfeit tobacco products for resale with no taxes. The RCMP have declared that there are over 50 illegal tobacco production facilities in Ontario and Quebec on aboriginal reserves. Contraband tobacco in Ontario accounts for 30% of all cigarette sales in Ontario and needs to be addressed in conjunction with plain packaging.
D) Grant the family run businesses a two (2) year window of adjustment to allow for a change to their business models, training and educating of staff and the sell through of all inventory. These allowances have been historically granted in Ontario with the covering of tobacco (back wall, out of sight out of mind) and now the elimination of Menthol cigarettes in Ontario (both included two-year adjustment windows). Small business does not have the clout with tobacco manufacturers and this would leave many with non-salable inventory with little hope of a credit.
E) Consider adult products like cigars, pipe tobacco and other related customer products exempt from plain packaging legislation as the transition would be expensive and target the adult smokers instead of the intended objectives.