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ETHRA was encouraged to receive an invitation from the European Commission’s DG SANTE to a virtual meeting entitled "New tobacco and nicotine products in tobacco control policies," which took place on Thursday 10 February. The meeting’s objectives were not clear, but it offered consumer organisations an opportunity to express their views on safer nicotine products.

 

A total of 11 organisations participated with each being allocated 5 minutes to give a presentation to the Commission. This was all done under the watchful eye of the European Network for Smoking and Tobacco Prevention (ENSP) and Smoke-Free Partnership (SFP), who were invited as observers for the meeting. The consumer perspective was well represented, with ETHRA partners Aiduce, ANPVU, Sovape, and NNA Sweden in attendance, as well as INNCO.

The meeting turned out to be quite informal and was mostly taken up with presentations, with no time for discussion. DG SANTE, in its opening remarks, made a point of stressing that this meeting is not part of any consultation on the future regulation of safer nicotine products. However, the presentations from consumer organisations were good and very informative. As the revisions of the Tobacco Products Directive and Tobacco Excise Directives are well underway, we hope DG SANTE and the observers from ENSP and SFP take the information provided and our views and concerns into account. We await our invitation to participate as observers in meetings between ENSP and SFP and the Commission.

We were informed that minutes of the meeting will be uploaded in due course. For now, you can read ETHRA’s contribution below, and our supporting document to the Commission is here.

 

ETHRA presentation to Commission meeting

Hello and thank you for this opportunity to speak. I’m Damian Sweeney, Chair of NNA Ireland, and partner with the European Tobacco Harm Reduction Advocates (ETHRA)

ETHRA is a Europe-wide consumer network with partners in most EU countries.

We aim to represent the consumer interest in low-risk alternatives to smoking – which are vapes, heated tobacco products, nicotine pouches and snus.

We support consumer protection regulation, but we oppose regulation that makes these products more difficult to access, more expensive, or less effective as alternatives to smoking.

We are listed in the Transparency Register and do not take money from tobacco, vaping or pharma sources. ETHRA is run on a voluntary basis.

We would like to make four brief points to contribute to the meeting.

First , we are genuinely pleased to be invited to this stakeholder meeting. Consumers are the stakeholders most directly affected by EU action in the area, and it’s crucial that we’re involved in the conversation.

Given the high risks of smoking, smokers need the widest possible range of safer nicotine products to transition out of smoking. Any regulation which prevents that, will literally be life-threatening. So, the stakes are high for Europe’s 27 million consumers of safer nicotine products and also for the many smokers who might switch to these products in future.

Respectfully, we hope consumer views will be taken seriously in the development of any new policies in this area.

Second, we need a common understanding of three critical findings.

  • Combustion is the key factor, as that’s what causes the harms from smoking. Safer nicotine products don’t involve combustion and are, beyond any reasonable doubt, much less risky than smoking. We know this through studies showing that exposures to toxicants in blood, saliva and urine are much much lower and close to that of non-users for many toxicants.
  • We know that safer nicotine products help adults quit smoking. This is supported by evidence from multiple sources; such as Randomised Control Trials, observational studies, population data trends and thousands of user testimonials.
  • Safer nicotine products and cigarettes are economic substitutes. If the safer products are over regulated or restricted it will inevitably increase smoking.

That brings us to our third main point. The challenge of regulating safer nicotine products is really about avoiding unintended harmful consequences.

● Making the safer products less appealing, less accessible, less affordable, will lead to more smoking, and a higher burden of disease
● Banning the products people want to use will not make them disappear - a ban just changes how they are supplied. And not in a good way.

Let me give an example. Flavours are a key part of the consumer experience, whether you use vapes, nicotine pouches, heated tobacco products or snus. All these products are flavoured in some way.

So, if you are thinking of banning most vaping flavours, then you can expect fewer smokers to switch to vapes, more vapers to relapse to smoking, an unregulated black market to develop, and it will give a big boost to the cigarette trade.

Fourth and finally, we really do welcome regulation in this area.

But what we need is smart regulation.

Regulatory controls on tobacco or nicotine products should always be proportionate to risk. That means being much tougher on cigarettes than smoke-free alternatives.

We now have a range of innovations that really can help Europe beat cancer.

So, we have a choice:

We can have excessive regulation that protects the cigarette trade, prolongs the smoking epidemic, and increases Europe’s burden of cancer.

Or, we can have a market that breaks the stranglehold of the cigarette trade, improves public health, and helps European citizens take action to drive down cancer.

Thank you for your attention.

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