David Clinton

Any single suicide is an unspeakable tragedy. But public health officials should be especially alarmed when the numbers of suicides among a particular population spike. Between 2019 and 2023, the suicide rate across Canada fell from 12.3 per 100,000 to 9.5 per 100,000. U.S. numbers aren’t that different (although they’re heading in the other direction).

Holding public officials and institutions accountable using data-driven investigative journalism.

Against this context, the suicide rate among active Canadian military personnel is truly alarming. Data included in a 2021 Report on Suicide Mortality in the Canadian Armed Forces (CAF) showed that the three year moving average annual rate for suicides in all services of the CAF was 23.38 per 100,000 – around twice the national rate. Which, of course, is not to ignore the equally shocking suicide rates among military veterans.

This isn’t specific to Canada. All modern military communities have to worry about numbers like those. Officials in the Israel Defense Force – now hopefully emerging from their longest and, by some measures, costliest war ever – are struggling to address their own suicide crisis. But there’s a significant difference that’s probably worth exploring.

Through 2024, 21 active duty IDF soldiers took their own lives. This dark number has justifiably inspired a great deal of soul searching and, naturally (it being Israel), finger pointing. But the real surprise here is how low that number is.

It’s reasonable to estimate that there were 170,000 active duty soldiers in the IDF during 2024 and another 300,000 active reservists. If you count all of those together, the actual suicide rate is just 4.5 per 100,000 – which is less than half of the typical civilian suicide rate in Western countries!

Tragic. But hardly an epidemic. Those soldiers have all lost friends and faced battlefield conditions that I, for one, find impossible to even comprehend. And those 300,000 reservists? They’ve been torn away from their families, businesses, and normal lives for many months. Many have suffered devastating financial, social, and marital pressures. And still: we’re losing them at lower rates than most civilian populations!

Is there any lesson here that could help inform CAF policy?

One obvious difference is sense of purpose: IDF members are fighting for the very existence of their people. They all saw and felt the horrors of the October 7 massacres and know that there are countless thousands of adversaries who would be happy do it again in a heartbeat¹. And having a general population that overwhelmingly supports their mission can only help that sense.

But there are some other factors that could be worth noting:

• The IDF is unusual in that it subjects all potential conscripts to mandatory psychological screening – resulting in many exemptions.
• Small, stable units are intentionally kept together for years. In fact, units are often formed from groups who have known each other since their early school years. This cohesion also helps with post-service integration.
• Every IDF battalion has a dedicated officer trained in brief interventions and utilization rates are high.

Is there anything here that CAF officials could learn from?

From the Brownstone Institute

  Roger Bate  

A walk through a dozen convenience stores in Montgomery County, Pennsylvania, says a lot about how US nicotine policy actually works. Only about one in eight nicotine-pouch products for sale is legal. The rest are unauthorized—but they’re not all the same. Some are brightly branded, with uncertain ingredients, not approved by any Western regulator, and clearly aimed at impulse buyers. Others—like Sweden’s NOAT—are the opposite: muted, well-made, adult-oriented, and already approved for sale in Europe.

Yet in the United States, NOAT has been told to stop selling. In September 2025, the Food and Drug Administration (FDA) issued the company a warning letter for offering nicotine pouches without marketing authorization. That might make sense if the products were dangerous, but they appear to be among the safest on the market: mild flavors, low nicotine levels, and recyclable paper packaging. In Europe, regulators consider them acceptable. In America, they’re banned. The decision looks, at best, strange—and possibly arbitrary.

What the Market Shows

My October 2025 audit was straightforward. I visited twelve stores and recorded every distinct pouch product visible for sale at the counter. If the item matched one of the twenty ZYN products that the FDA authorized in January, it was counted as legal. Everything else was counted as illegal.

Two of the stores told me they had recently received FDA letters and had already removed most illegal stock. The other ten stores were still dominated by unauthorized products—more than 93 percent of what was on display. Across all twelve locations, about 12 percent of products were legal ZYN, and about 88 percent were not.

The illegal share wasn’t uniform. Many of the unauthorized products were clearly high-nicotine imports with flashy names like Loop, Velo, and Zimo. These products may be fine, but some are probably high in contaminants, and a few often with very high nicotine levels. Others were subdued, plainly meant for adult users. NOAT was a good example of that second group: simple packaging, oat-based filler, restrained flavoring, and branding that makes no effort to look “cool.” It’s the kind of product any regulator serious about harm reduction would welcome.

Enforcement Works

To the FDA’s credit, enforcement does make a difference. The two stores that received official letters quickly pulled their illegal stock. That mirrors the agency’s broader efforts this year: new import alerts to detain unauthorized tobacco products at the border (see also Import Alert 98-06), and hundreds of warning letters to retailers, importers, and distributors.

But effective enforcement can’t solve a supply problem. The list of legal nicotine-pouch products is still extremely short—only a narrow range of ZYN items. Adults who want more variety, or stores that want to meet that demand, inevitably turn to gray-market suppliers. The more limited the legal catalog, the more the illegal market thrives.

Why the NOAT Decision Appears Bizarre

The FDA’s own actions make the situation hard to explain. In January 2025, it authorized twenty ZYN products after finding that they contained far fewer harmful chemicals than cigarettes and could help adult smokers switch. That was progress. But nine months later, the FDA has approved nothing else—while sending a warning letter to NOAT, arguably the least youth-oriented pouch line in the world.

The outcome is bad for legal sellers and public health. ZYN is legal; a handful of clearly risky, high-nicotine imports continue to circulate; and a mild, adult-market brand that meets European safety and labeling rules is banned. Officially, NOAT’s problem is procedural—it lacks a marketing order. But in practical terms, the FDA is punishing the very design choices it claims to value: simplicity, low appeal to minors, and clean ingredients.

This approach also ignores the differences in actual risk. Studies consistently show that nicotine pouches have far fewer toxins than cigarettes and far less variability than many vapes. The biggest pouch concerns are uneven nicotine levels and occasional traces of tobacco-specific nitrosamines, depending on manufacturing quality. The serious contamination issues—heavy metals and inconsistent dosage—belong mostly to disposable vapes, particularly the flood of unregulated imports from China. Treating all “unauthorized” products as equally bad blurs those distinctions and undermines proportional enforcement.

A Better Balance: Enforce Upstream, Widen the Legal Path

My small Montgomery County survey suggests a simple formula for improvement.

First, keep enforcement targeted and focused on suppliers, not just clerks. Warning letters clearly change behavior at the store level, but the biggest impact will come from auditing distributors and importers, and stopping bad shipments before they reach retail shelves.

Second, make compliance easy. A single-page list of authorized nicotine-pouch products—currently the twenty approved ZYN items—should be posted in every store and attached to distributor invoices. Point-of-sale systems can block barcodes for anything not on the list, and retailers could affirm, once a year, that they stock only approved items.

Third, widen the legal lane. The FDA launched a pilot program in September 2025 to speed review of new pouch applications. That program should spell out exactly what evidence is needed—chemical data, toxicology, nicotine release rates, and behavioral studies—and make timely decisions. If products like NOAT meet those standards, they should be authorized quickly. Legal competition among adult-oriented brands will crowd out the sketchy imports far faster than enforcement alone.

The Bottom Line

Enforcement matters, and the data show it works—where it happens. But the legal market is too narrow to protect consumers or encourage innovation. The current regime leaves a few ZYN products as lonely legal islands in a sea of gray-market pouches that range from sensible to reckless.

The FDA’s treatment of NOAT stands out as a case study in inconsistency: a quiet, adult-focused brand approved in Europe yet effectively banned in the US, while flashier and riskier options continue to slip through. That’s not a public-health victory; it’s a missed opportunity.

If the goal is to help adult smokers move to lower-risk products while keeping youth use low, the path forward is clear: enforce smartly, make compliance easy, and give good products a fair shot. Right now, we’re doing the first part well—but failing at the second and third. It’s time to fix that.

Author

Roger Bate

Roger Bate is a Brownstone Fellow, Senior Fellow at the International Center for Law and Economics (Jan 2023-present), Board member of Africa Fighting Malaria (September 2000-present), and Fellow at the Institute of Economic Affairs (January 2000-present).