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April 2024. ETHRA submitted to Spain’s Draft Royal Decree amending Draft Decree 579/2017. The Draft Royal Decree aims to introduce a vape flavour ban and plain packaging for vaping products. 

Thank you for the opportunity to comment on the Draft Royal Decree. Our submission is on behalf of the European Tobacco Harm Reduction Advocates (ETHRA), of whom Spanish consumer association Anesvap is a partner.

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 have read with interest the Government’s Draft Royal Decree amending Draft Decree 579/2017. As people with lived experience of using safer nicotine products to quit smoking and remain smoke free, we have serious concerns that severely restricting flavours in vaping products will be detrimental to public health.

One of the main aims of the proposal is to prevent youth use (Ficha Consulta publica, page 3). While we agree that preventing youth use is important, it shouldn’t come at the expense of restricting adult access to vaping products or discouraging smokers who could significantly improve their health by switching to a vastly safer product.

The public consultation document correctly highlights the serious health impacts associated with smoking but fails to acknowledge that non-combustible nicotine products pose a small fraction of the risk of smoking. It also fails to recognise that vaping is proven to be an effective means of smoking cessation for Spanish citizens.

Smoking prevalence in Spain is currently 33.1%, an astonishing 10 percentage points higher than the EU average. It is clear from the data that Spanish citizens who smoke should have more options to help them quit smoking, not fewer. A vape flavour ban would remove the most popular and effective means of smoking cessation from the market and prolong smoking and smoking associated disease and premature death.

Our full submission is available to read and download here