Respond to the SCHEER consultation

: Published: 30 September 2020

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 authors fail to examine vaping in the European context. There is a heavy reliance on US data yet relevant European data is ignored, despite the purpose of the Opinion being to report on the effectiveness of TPD2, which is a European directive. Various WHO communications are referred to, but WHO communications are rarely evidence based. The conclusion that e-cigarettes are a gateway to smoking can only be an opinion, as this theory is not supported by evidence. Indeed, there is published peer-reviewed evidence that points to vaping being a route away from smoking. The report is written from the biased perspective that vaping is a net harm and defaults to assuming harm where no evidence is available. Some references are misrepresented as showing effects that they do not even measure, or show. The approach to flavours is very questionable.

The conclusions drawn in the abstract and summary are not supported by what is stated in the body of the report. This report is an abuse of science and will cause harm if left unchallenged.

ETHRA Partners are now reading the report closely and planning their submissions to the consultation. What follows is information about the consultation process.

The public consultation

FOR FULL DETAILS PLEASE VISIT THE PUBLIC CONSULTATION PAGE (LINK)

It is really important for the Commission to see that this report will affect real people and anyone who supports safer alternatives to smoking should respond to the consultation. It may look like a big task but in fact you do not even need to read the whole report – if you are short of time you could just comment on the Abstract, which is on a single page (page two). Every minute you can spend on this will be a minute well spent. Please respond in as a polite, respectful and as relevant a manner as possible. This is important so that contributions are not excluded.

Key points for submitting

● The consultation closes on 26 October 2020 at 23:59 CET
● You MUST use the template supplied to upload your contribution.
● Only submissions directly referring to the content of the opinion and relating to the issues that the opinion addresses will be considered.
● You will need to upload evidence - as a file - to support your submission
● Comments must be submitted separately for each chapter or section that you wish to comment on.
● The dropdown menu for selecting the chapter or section is the full table of contents from the report
● You must indicate the line numbers for the text which your comment refers to
● The comment for each selected chapter / section cannot be more than 3800 characters.
● Comments must be in English
● Use polite and respectful language

Please contact your member organisation or ETHRA if you have any questions or comments.