On 29 April, the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) published its Final Opinion on e-cigarettes. The Preliminary Opinion, published in September 2020, had attracted significant criticism and 691 submissions to the public consultation. We hoped that the SCHEER committee had listened, and that the final Opinion would take our submissions into account, but we find ourselves greatly disappointed!
We find that many of the problems highlighted during the public consultation on the Preliminary Opinion have not been adequately addressed, or addressed at all in the final report. Important EU data has been ignored, potential harms exaggerated and there is an over emphasis on youth initiation while the impact of vaping on adult smoking cessation is virtually ignored. Despite it being well established that vaping is used as a substitute for smoking, the Commission’s request for the scientific Opinion (the mandate) had not asked the SCHEER to compare vaping to smoking. This is mentioned in the report, at page 10: “The SCHEER was asked to focus only on health impacts compared to non-smoking.” We feel that this failure of the mandate is the Opinion’s fatal flaw, and is responsible for many of the report’s shortcomings. Exposure to harmful chemicals is orders of magnitude lower when vaping in comparison to smoking, and that is what should have been examined.
There are only minor differences between the Preliminary and Final Opinion. The risks of long-term systemic effects on the cardiovascular system were downgraded from strong to moderate. The risks of local irritative damage to the respiratory tract remained moderate. The risks of carcinogenicity of respiratory tract remained weak to moderate. The risks of other long-term adverse health effects such as pulmonary disease, CNS and reprotoxic effects could not be established due to a lack of data.
Regarding the role of e-cigarettes in smoking cessation, the SCHEER concluded that the evidence was weak. This conclusion is contrary to the evidence from national surveys, observational data, randomised control trials, and the lived experience of millions of vapers across Europe. Eurobarometer 2020 found that the percentage of vapers completely switching from smoking to vaping increased by a massive 121%. The most recent Cochrane review, a meta-analysis of over 50 studies, concluded that vaping was 70% more effective than nicotine replacement therapy (NRT), Public Health England’s evidence update 2021 also found that vaping was more effective than NRT.
Evidence for a gateway effect was downgraded from strong to moderate. However, the majority of data used for the report is from the USA. Despite this issue of inappropriate use of US data being raised during the public consultation, and page 7 of the Opinion cautioning that “conclusions drawn for the US may not be directly transferable to the EU,” it still made it into the final Opinion. It is also important to note that there is no evidence of a gateway effect in the USA itself, as youth smoking there is at an all-time low. Relevant data from the EU shows that vaping here is almost exclusively among ex or current smokers: Eurobarometer 2020 shows that 98% of current vapers were smokers first. In the UK, Action on Smoking and Health (ASH) finds that “Only 0.3% of never-smokers are current vapers”. A gateway effect has been talked about for years and yet smoking rates continue to fall, isn’t it time to put the myth to bed?
It was concluded that flavours play a strong role in youth initiation. Because the focus was almost entirely on attractiveness for initiation, the importance of flavours for adults was little more than an afterthought. This distorted view of the role of flavours could lead to restrictions or bans, as suggested on page 69, which would be disastrous for consumers. In our submission to the public consultation, we provided evidence that flavours play a vital role for adults in remaining smoke free, and that adults commonly migrate from tobacco to fruit and sweet flavours. It is of paramount importance that the role of flavours in adults smoking cessation is thoroughly investigated.
During the public consultation scientists, experts, and consumers submitted mountains of evidence in support of vaping as a harm reduction tool. The majority of this seems to have been ignored. The result is that the SCHEER has produced a document that is of little use to policymakers. The risk assessment doesn’t compare relative risks with smoking, the assessment of efficacy for smoking cessation ignores vital EU data, and the discussion of flavours lacks any semblance of balance by neglecting to look at the importance of flavours to adults. If the Opinion informs policy, as it is intended to do, vapers and smokers will be the casualties in the continued demonisation of safer nicotine products. Advocacy efforts must now be redoubled in order to educate politicians and policymakers.