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Consumer Groups Submit Evidence To EU

The New Nicotine Alliance and the European Tobacco Harm Reduction Advocates have made evidence submissions to the European Union

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The New Nicotine Alliance (NNA) and the European Tobacco Harm Reduction Advocates (ETHRA) have made submissions to the European Union as part of its evidence gathering exercise that will guide its future vape legislation – the Tobacco Products Directive (TPD). The deadline for you to enter your comments is the June 17.

The problem facing the European Union was laid bare at a recent event organised by the Centre for Economic and Market Analysis. Taking place in Prague, the Czech National Drug Coordinator said the EU is going to fail to achieve its 2040 tobacco-free target as it is not recognizing the benefits of a tobacco harm reduction approach.

Jindřich Vobořil said: “If the European Commission is serious about its plans to reduce the number of smokers and the impact of smoking, it must start considering the concept of risk reduction in the area of smoking. The Czech Government has committed itself to this approach in its program statement for the upcoming [EU] Presidency. I will also promote it in relation to the ongoing evaluation of the Tobacco Products Directive, which is an effective policy to achieve a real reduction in the number of smokers of conventional cigarettes.”

The New Nicotine Alliance told the European Union: “We believe that the EU should embrace reduced risk tobacco and vaping products and incorporate them into a progressive tobacco and nicotine policy to fully derive the benefits of tobacco harm reduction across all member states. By doing so, the EU could divert many millions of smokers towards products which are orders of magnitude safer than combustible tobacco.”

Pushing the case for reduced harm approaches, the New Nicotine Alliance continued: “Vaping products have led to steep declines in smoking wherever they have been allowed to flourish. In the UK, an unprecedented and dramatic decline in smoking rates followed vaping products going mainstream in 2012. Rates plummeted from just under 21 percent in 2011 to less than 15 percent in 2020”.

The European Tobacco Harm Reduction Advocates focussed on “how the European Commission and other bodies evaluate the evidence, drawing on what we see as failures in the SCHEER report. Our main point is that the value of evidence usually depends on”:

  1. How it is evaluated. For example, is vaping risk compared to smoking or abstinence?
  2. What questions are asked and not asked? For example, how many Europeans no longer
  3. smoke because of vaping, snus, heated tobacco or other safer nicotine products?
  4. What counterfactuals are considered: will people be deterred from vaping smoke instead?

ETHRA made four key points:

  1. Smoke inhalation, not nicotine, is the primary cause of ill-health - European Union policy should focus on reducing smoking, not tobacco
  2. Tax, regulation or other interventions designed to address vaping will lead to perverse consequences
  3. Multiple lines of evidence triangulate to show that vaping products support adult smoking cessation at minimal risk
  4. A more sophisticated approach to youth uptake of safer nicotine products is necessary. There is no evidence for gateway effects, but there is accumulating evidence that safer nicotine products divert some young people from smoking and may be beneficial to young people who would be more likely to take up smoking

ETHRA has posted a detailed guide to support you in making a submission, here:


Dave Cross avatar

Dave Cross

Journalist at POTV
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Dave is a freelance writer; with articles on music, motorbikes, football, pop-science, vaping and tobacco harm reduction in Sounds, Melody Maker, UBG, AWoL, Bike, When Saturday Comes, Vape News Magazine, and syndicated across the Johnston Press group. He was published in an anthology of “Greatest Football Writing”, but still believes this was a mistake. Dave contributes sketches to comedy shows and used to co-host a radio sketch show. He’s worked with numerous vape companies to develop content for their websites.

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