Posted 4th September 2020 by Dave Cross
The Tobacco Products Directive (TPD) regulates the manufacture, sale and marketing of most safer nicotine products. It has been implemented to varying degrees across Europe and underpins the UK’s current legislation. It is generally believed that the UK will end up conforming with a sizeable part of TPD3. The European Tobacco Harm Reduction Advocates (ETHRA) organisation has released a summary of what we know about it so far.

ETHRA exists to link the actions of nicotine user groups from across the continent. It believes that access to reduced harm products is a basic human right and that legislators should recognise the value of flavours and having a wide choice of products.

The organisation points out, as was recently highlighted by Clive Bates during his New Nicotine Alliance webcast, the TPD is seen globally as a legislative model, something that countries have treated as a pick’n’mix counter as they have developed their approaches.

ETHRA mourns the fact that the TPD currently prohibits the sale of “the safest harm reduction product”, snus, leaving vape products and heated tobacco products covered.

The current TPD, commonly known as TPD2, is undergoing revision, but “frustratingly, it is difficult to find information on how the TPD application report is being produced and so here we present what we know. We will update this article as information becomes available,” says ETHRA.

The organisation states: “Consumers … will appreciate that the report is examining some highly controversial topics in vaping: youth initiation, influence on smoking cessation and flavours. Two member states, Denmark and the Netherlands, are currently legislating to restrict e-liquid flavourings and flavour bans are already in place in several other member states.


“Who are the scientific and technical experts who are assisting the Commission, with this evaluation - which is likely to affect consumer lives worldwide?  What are the data sources for the report?  What questions are being asked?  What is the role of member states?  Where are consumers in all this?

While ETHRA has been able to track down information on a product perception study, those responsible for compiling a survey on scientific opinion is clouded in mystery. “A core working group was formed – referred to here. We cannot find any information on who the Working Group members are.”

There is much that is unclear about this hugely important Scientific Opinion on e-cigarettes, especially with regards to who is involved in writing this report and what the opportunities for engagement will be. It is ominous that the consultation, initially referred to as ‘a public consultation’ was most recently described as ‘minimum consultation’.”

ETHRA’s extensive work stretches to over 2,000 words and is essential reading for anyone interested in how Europe may influence our vaping – and tobacco harm reduction around the world - in future.


  • “What do we know about the TPD application report?”, ETHRA – [link]
  • New Nicotine Alliance’s Webcast with Clive Bates – [link]

 Dave Cross
Article by Dave Cross
Freelance writer, physicist, karateka, motorbikes, and dog walker
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