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July 2022. ETHRA submitted to European Commission's call for evidence on extending smoke free environment recommendations to included vaping products and heated tobacco products. 

European Tobacco Harm Reduction Advocates (ETHRA) is the voice of 27 million EU consumers of safer nicotine products. ETHRA is a consortium of 25 grassroots consumer associations in 17 European countries, supported by experts in tobacco control and nicotine research. We are a voluntary operation with no industry funding or conflicts of interest. Our transparency registration number is 354946837243-73.

This document is our response to the call for evidence regarding the initiative smoke-free environments - updated recommendation.

We will confine our comments to the use of non-combustible Safer Nicotine Products (SNPs), such as vapes and Heated Tobacco Products rather than combustible products, such as cigarettes and pipes.

The purpose of the Recommendation on smoke-free environments (2009/C 296/02) is to protect people in the EU from exposure to second-hand smoke, as well as to encourage current smokers to quit. The intention to extend this recommendation to Safer Nicotine Products is not based on science and is counterproductive to public health, as we explain in the nine points below.

  1. The scientific basis for updating this recommendation is flawed
  2. There are key differences between secondhand smoke and secondhand vape exposure, which policy makers should take into account.
  3. With no credible evidence to show that vaping presents a material risk to bystanders, the decision on whether to permit it should rest with property owners.
  4. Banning the use of safer alternatives to smoking in public spaces will increase smoking.
  5. Banning the use of products which people know to be safer will damage trust in public health.
  6. Eurobarometer data does not support the claim that SNPs appeal in particular to young people.
  7. Enforcement would add a financial burden to member states and risk criminalising people for bettering their own health.
  8. The evaluation study does not consider the economic impact on the vape sector or the impact on quitting rates
  9. Consumers are omitted from the targeted stakeholder consultation

Download the full submission here

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