Dear President of the Commission and European Commissioners:
We, the undersigned experts in public health, nicotine dependence and tobacco
control, write to you out of concern over the forthcoming review of the Tobacco
Excise Directive, which is expected to impose new taxes on less harmful nicotine
products.
Public health policies should use the best available scientific evidence. It is, therefore,
a matter of significant concern that recent EU public communications,
1,2
claiming that
non-combustible nicotine delivery products pose health risks comparable to
combustible cigarettes, contradict the best available scientific evidence. This position
is not only a significant departure from the foundational principle of evidence-based
public health but also undermines the European Commission’s vital commitments to
data-driven legislation and to combatting disinformation.
Smoking remains the leading cause of preventable death in the EU, with nearly
700,000 premature deaths annually. Twenty-six percent of citizens (29% among 15–
24-year-olds) still smoke.
3
Extensive scientific evidence has proven that non-combustible nicotine products
such as e-cigarettes, heated tobacco products and nicotine pouches are substantially
less harmful than cigarettes. These products have also helped millions quit smoking.
• In Sweden, where snus and nicotine pouches are commonly
used, daily tobacco use
is the lowest in the EU (<5%) and cancer incidence is 41% below the EU average,
despite overall nicotine use being similar to the EU average.
4
• In the United Kingdom
where the government encourages smokers to switch to
vaping, smoking has fallen from 17% to 12% in five years.
5
• In New Zealand, daily smoking
dropped to 7% in 2023/24, from 16% in 2011/12, while
daily vaping has risen to 11%.
6
Regulation should be guided by science.
Ideological or moral beliefs should not guide
public health policies and must not override the facts and the goal to improve the
health and lives of Europeans. Protection of minors is important, but it can be
achieved by proper implementation of the already established regulation on
advertising and sales, without hindering the public health objectives of reducing
death and disease caused by smoking.
Smokers should have access to non-combustible alternatives.
Fiscal and regulatory
provisions that discourage the switch from smoking to less risky alternatives are
unethical and protect the cigarettes trade.
Commissioners, public health in Europe stands at a crossroads: in the coming months,
the European Commission intends to advance Tobacco Products Directive and the
Tobacco Excise Directive. Implementing
a “tax-raid” on potentially life-saving
products will keep smokers smoking, will harm public health, and will set a bad
paradigm for other countries (particularly LMICs) and regions globally.