Vapers Finland’s response to the EU Commission’s call for evidence for the evaluation of the legislative framework for tobacco control

Vapers Finland, a non-profit consumer association, respectfully calls on the Commission to make every effort to reduce the harm caused by smoking. This range of measures also includes replacing smoking with much less harmful alternatives.

There is strong evidence that alternative products significantly reduce smoking. In Sweden, for example, snus has already superseded smoking among males. As a result, Sweden has the lowest smoking rates in the EU and Swedish men have EU’s lowest level of tobacco-related mortality. The same trend is currently underway in most Nordic countries. The downward trend in smoking has clearly accelerated also, for example, in the United Kingdom and the United States, along with the increase in the use of e-cigarettes.

The emergence of alternative nicotine products has raised concerns that they could act as a gateway to smoking among youth. In reality, however, the increase of alternatives has not increased young people’s smoking but on the contrary, youth smoking has declined significantly faster than previously. 

In the United States, for example, youth smoking has practically collapsed, with the number of middle- and high-school smokers falling from 17% in 2009 to 1.5% in 2021. According to the 2021 National Youth Tobacco Survey, e-cigarettes are currently used by 7.5% of US youth, so also the combined number of vapers and smokers, 9%, is lower than the number of smokers alone about a decade ago.

It might be argued that it would be desirable that no one would use any kind of nicotine product. However, studies in users of nicotine products have identified a number of common denominators that predispose them to this type of risk behavior. It is therefore likely that in the absence of alternatives, the same people would smoke cigarettes.

The substitutability of cigarettes and alternatives has also been shown in a number of studies which have found that smoking is declining faster with the use of alternative products and that the downward trend will slow if the use of alternatives is reduced as a result of over-regulation (eg high taxation, ban on flavors).

The smoking-reducing effect of alternative products is also reinforced by population surveys and clinical trials, in which they have repeatedly found to help smokers quit smoking.

This smoking-eroding effect of alternative products is of major importance for public health, as they are significantly less harmful than smoking. The health risks of smoking are mainly caused by the products of combustion (carbon monoxide, tar, etc.) which are not present in smokeless alternatives. The levels of other harmful substances are also only a fraction of the amount of toxic substances in cigarette smoke.

The forthcoming Tobacco Products Directive should take into account the smoking-reducing effect of less harmful nicotine products and ensure that adult smokers have all possible means to quit and stay away from smoking. It is proportionate to prevent the availability of alternative nicotine products among youth through age restrictions. However, it is not proportionate to prevent their availability among adult smokers (ban on the sale of snus) or to significantly impair their functioning as a substitute for smoking (flavor restrictions) — 80-90% of the adult e-cigarette users use non-tobacco flavors and consider them important for success in quitting smoking.

For the above reasons, it is high time to lift the ban on the sale of snus, and adult consumers must be guaranteed access to flavored e-cigarettes. Since low-risk alternatives are most likely to reduce public health expenditure by replacing high-risk smoking, there is also no justification for imposing an excise duty on them.

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