ETHRA Comments on TPD Report

Posted 15th July 2021 by Dave Cross
Advocacy coordination group European Tobacco Harm Reduction Advocates (ETHRA) has provided a commentary on the report about the application of the European Union’s Tobacco Products Directive (TPD). The European Commission published its Report on the application of the Tobacco Products Directive at the end of May (1). The Commission’s report looks at how well the current TPD has done and use that to help form future legislation in the form of TPD3, the next iteration of the TPD.

The EC note: “The TPD has aimed to reduce tobacco consumption by 2% within five years of its transposition. Based on the latest Eurobarometer, smoking prevalence among those aged 15+ fell from 26% in 2014 to 23% in 2020 – a drop 5 of 3 percentage points since the TPD came into force, equivalent to 12.5%. Youth smoking rates fell to 20% in 2020 from 25% in 2014, after peaking at 29% in 2017.”

While this sounds positive, it ignores the impact safer nicotine products have had on achieving this result – worse, it attempts to make out that the bureaucrats would have done even better were it not for those pesky vapers.

However,” it continues, “the uptake of emerging products, especially e-cigarettes, is growing among young people. This is worrying given the aim to protect the youth.”

ETHRA says: “The Commission failed to recognise the dramatic fall in combustible tobacco consumption as a positive, and instead highlighted that youth use of e-cigarettes is growing. This dangerous and misguided focus on nicotine use, rather than combustible tobacco use, signals the direction the Commission intends to take.”

The consumer body says that Section 7 of the report, concerned with “emerging products” such as heated tobacco and nicotine pouches, raises concerns that the TPD in its current form does not sufficiently regulate them.

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ETHRA adds that the Commission suggests, “that flavours present a challenge as they are particularly appealing to young people – failing to mention that flavours play a pivotal role for adults to quit smoking and remain smoke free, which is supported by Eurobarometer data.”

Section 8, applicable to vape products and refill containers, “relies heavily on the deeply flawed SCHEER report”.

It is claimed that flavours such as fruits and candy strongly influence youth initiation and can act as a gateway to smoking. Once again, the fact that the majority of adults use fruit and sweet flavours is ignored.”

Once again, evidence that Europe is determined to see vaping as something to be strictly controlled rather than looking to the UK’s success and embracing it. We have to hope that the TPD3 will not power a new wave of anti-vape attacks here at home.


  1. REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS On The Application Of Directive 2014/40/EU Concerning The Manufacture, Presentation And Sale Of Tobacco And Related Products COM/2021/249 Final -
  2. ETHRA’s commentary -

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