ETHRA Responds To SCHEER Final Opinion on Vaping

Posted 18th May 2021 by Dave Cross
The European Tobacco Harm Reduction Advocates (ETHRA) consumer organisation has responded to the publication of the SCHEER Final Opinion on Vaping. The SCHEER document will be used to form the next version of Europe’s Tobacco Products Directive. It was roundly panned by all those working to promote tobacco harm reduction and the use of vaping to combat tobacco related disease and death.

SCHEER’s Final Opinion (1) was published at the end of last month and ETHRA (2) says it is, “greatly disappointed”.

We find that many of the problems highlighted during the public consultation on the Preliminary Opinion have not been adequately addressed or addressed at all in the final report.  Important EU data has been ignored, potential harms exaggerated and there is an over emphasis on youth initiation while the impact of vaping on adult smoking cessation is virtually ignored.

“Despite it being well established that vaping is used as a substitute for smoking, the Commission’s request for the scientific Opinion (the mandate) had not asked the SCHEER to compare vaping to smoking. This is mentioned in the report, at page 10: ‘The SCHEER was asked to focus only on health impacts compared to non-smoking.’ We feel that this failure of the mandate is the Opinion’s fatal flaw and is responsible for many of the report’s shortcomings. Exposure to harmful chemicals is orders of magnitude lower when vaping in comparison to smoking, and that is what should have been examined.”   

The initial Opinion paper drew 691 submissions during the public consultation phase, but the committee has appeared to have ignored all of them as there are minimal difference between it and the Final Opinion.

Regarding the role of e-cigarettes in smoking cessation, the SCHEER concluded that the evidence was weak. This conclusion is contrary to the evidence from national surveys, observational data, randomised control trials, and the lived experience of millions of vapers across Europe.  Eurobarometer 2020 found that the percentage of vapers completely switching from smoking to vaping increased by a massive 121%. The most recent Cochrane review, a meta-analysis of over 50 studies, concluded that vaping was 70% more effective than nicotine replacement therapy (NRT), Public Health England’s evidence update 2021 also found that vaping was more effective than NRT.”

Pure Eliquids

SCHEER still argues there is moderate evidence for a gateway effect, something that Public Health England has called a “myth”.

It was concluded that flavours play a strong role in youth initiation.  Because the focus was almost entirely on attractiveness for initiation, the importance of flavours for adults was little more than an afterthought. This distorted view of the role of flavours could lead to restrictions or bans, as suggested on page 69, which would be disastrous for consumers.”

ETHRA said that this final draft is of “little use to policymakers”, but it appears that this was its aim so it could support emotive rather than evidence-based legislation. Europe is simply not listening.


  1. Opinion on electronic cigarettes -
  2. The European Tobacco Harm Reduction Advocates -

 Dave Cross
Article by Dave Cross
Freelance writer, physicist, karateka, dog walker
Eternal Vape