August 2023. ETHRA wrote to members of SANT in anticipation of the presentation of the Rapporture's Draft Report on non-communicable diseases. We highlighted that 'tobacco use' was erroneously identified as a risk fact, when it should be smoking. We also outlined the import role safer nicotine products can have in reducing smoking and NCD prevalence.
Dear Committee member
I write on behalf of the European Tobacco Harm Reduction Advocates (ETHRA). ETHRA is the voice of 27 million EU consumers of safer nicotine products (SNPs). The safer nicotine products we use include vapes, nicotine pouches, snus and heated tobacco products. ETHRA is a consortium of 24 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.
We read the recently published Subcommittee on Public Health Draft Report on non-communicable diseases (NCDs) with great interest. The report notes the huge health burden of NCDs, causing 90% of all deaths in the EU. It also notes that preventative measures which address the main risk factors in the development of NCDs can dramatically reduce the prevalence of deadly diseases such as cancer, cardiovascular disease, and COPD.
Given the importance of the report and the work of the SANT Subcommittee we are concerned that ‘tobacco use’ rather than smoking has been identified as a risk factor for NCDs (section E, page 4). In fact, it is the inhalation of the toxic byproducts of combustion that causes the harms from smoking, including the development of the NCDs, not simply tobacco use. Clarity and accuracy are vital when it comes to effective policy, so it is important that the report reflects that smoking is one of the four main preventable risk factors.
Reducing smoking prevalence is essential if the EU is to reach the WHO’s Sustainable Development Goal (SDG) target 3.4, which aims to reduce premature deaths from four key NCDs by one- third by 2030. Encouraging smokers to transition to a non-combustible safer nicotine product can be an effective way to reduce smoking prevalence and achieve this goal.
We welcome section 5a (NCD prevention) of the draft report which states: “follow up on the scientific evaluations of the health risks related to electronic cigarettes, heated tobacco products and novel tobacco products including the assessment of the risks of using these products compared to consuming other tobacco products.” However, as safer nicotine products are substitutes for combustible tobacco, risk assessments must compare the use of SNPs with smoking, not with ‘consuming other tobacco products’.
We would also like to highlight the importance of applying the EU’s core principles relating to the internal market, proportionality, and non-discrimination in policymaking. We believe rigorous application of these foundational principles would change the current approach to safer nicotine products. These principles justify risk-proportionate regulation with a critical distinction drawn between combustible (harmful) and non-combustible (far less harmful) products.
Safer nicotine products are a popular and effective means of smoking cessation so it is important that Committee members assess the potential public health benefits. Consideration should also be given to the potential unintended consequences of restrictive regulation. These unintended consequences could include an increase in smoking and the development of black markets.
Having a wide range of safer nicotine products that are accessible and appealing to smokers will be an effective strategy to drive down smoking prevalence and reduce NCDs.
ETHRA remains at the disposal of the European Parliament and would be delighted to supply any further information which you might require. We look forward to hearing from you.
Damian Sweeney
On behalf of ETHRA and partners.