Every minute you can spend on this will be a minute well spent

The SCHEER Preliminary Opinion on electronic cigarettes, an important element in the TPD evaluation, has now been published. There is a public consultation for the Opinion, which ends on 26th October.

We are concerned by the report and fear it will be used to argue for harsher restrictions in the EU TPD, including e-liquid flavour bans.

Our first reading of the Preliminary Opinion leaves us with the impression that it is heavily biased and has huge flaws. Here are some of our general observations:



The Tobacco Products Directive (TPD) regulates the manufacture, sale and marketing of most safer nicotine products (as well as combustible tobacco products) across the EU.

The TPD is the most comprehensive regulatory framework for safer nicotine products worldwide and is also the only regional framework. This gives the TPD global as well as regional significance because (1) regulators worldwide look to it as a legislative model; and (2) the EU is a powerful player in WHO FCTC and COP (Conference of the Parties),which has global affect. The tobacco control field does not operate in silos and so there is considerable overlap and inter connectivity between tobacco control activity and actors, at global, regional and national levels.



ETHRA was invited to participate in the current review of the TPD, by responding to an online stakeholder questionnaire and taking part in a follow up telephone interview. We have written notes summarising the views we put forward in the interview, together with some background evidence.

  • Consumers, the most important stakeholders and the group most directly affected by the TPD, were overlooked in the review process.
  • Failure to regulate vaping and other safer nicotine products appropriately is a win for the incumbent combustible tobacco trade and could trigger more smoking.

*** UPDATE: since sending our letter earlier today we have had an assurance that we will be included in forthcoming stakeholder consultations ***

Jason Blackeye unsplashedPhoto by Jason Blackeye on Unsplash

The Tobacco Products Directive (TPD) is the European directive which places limits on the sale and merchandising of tobacco and tobacco related products in the EU. Many of us consumers remember the drama around the last TPD, when we mobilised ourselves and successfully prevented the most damaging proposals from being adopted.   

That feels like such a short time ago but five years have already passed since TPD came into force, and the evaluation report is due in May 2021 (see Article 28 in the TPD).  The TPD may be reviewed or adapted, depending on the proposals in the report.

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