Proposals for EU Tobacco Control. Another Bureaucratic Power Grab.

A week before the Global Forum on Nicotine https://gfn.events/ in Warsaw, an annual gathering for people in the tobacco space, a comment was made on the evaluation of the EU Tobacco Products Directive (2014/40/EU) https://health.ec.europa.eu/tobacco/evaluation-legislative-framework-tobacco-control_en that was published in April. Since this document is the foundation for policy formulation, we would like to make a number of observations on a text that purports to be objective, yet strays continually towards an anti-tobacco orthodoxy that has implicitly set the final goal of achieving a ‘tobacco-free’ society above the principle of scientific or evidence-based policy making. 

 

Let us note first of all the tone of the directive, which revolves around risk and therefore fails to address the attractions, benefits and pleasures tobacco provides to the billions of daily consumers world-wide. Within the EU, an estimated 24% of adults consume tobacco products, but they are not given much space in the document. The findings and suggestions for policy change are made on their behalf. 

 

The most egregious error throughout the document, echoed by tobacco-prohibition advocates everywhere,, is the iniquitous conflation of smoking-related diseases with tobacco. The well-established “link between smoking and lung cancer“ that manifested in 2022 in “smoking [being] responsible for approximately 20% of cancer cases in the EU, causing at least 16 different types of cancer and contributing to over 80% of all lung cancer deaths, accounting for over 250,000 deaths from trachea, bronchus and lung cancer” is elliptically extended to the consumption of any tobacco product per se. 

 

This is sneaky, as it extends the argument from the well-proven health damage done by a particular form of tobacco delivery – the cigarette – to tobacco products per se. There is no acknowledgement that chewing tobacco, vapes, and even pipe smoking are not associated with any of the different bronchial conditions. It is not mentioned once in the report that the causal factor of these conditions is the inhalation of tobacco smoke.

 

Such information would allow consumers to make informed decisions about their patterns of use and policymakers to provide an environment where the freedoms of individuals are respected and play into the consideration of policy goals. Instead, the report seems to incline towards the pre-determined goal of increasing prohibitions of the new technical developments that are framed as not an opportunity but a risk. 

 

The intention of clamping down on novel products is further revealed by the claim that ”e-cigarettes have not proven effective for smoking cessation. “This flies in the face of a large number of studies and the lived experience of tens of millions of ex-smokers.” 

 

The authors seem to have traded objectivity for the ‘precautionary’, meaning repressive, approach chosen by the principals. The architects of tobacco policy at the EU, as in other international institutions, have shifted from the pursuit of reducing harm to reducing tobacco. The goalposts have shifted, and the objective of cutting down cancer rates is subordinated to reducing tobacco products. It is no longer about extending lives and quality life years to achieving a ‘tobacco-free generation’ by 2040, with a key benchmark of a smoking prevalence of less than 5%.

 

Significantly, the one country where this has been achieved, Sweden, is not mentioned. Instead, the highlight figures on nicotine pouch use is that “almost 13% of 16-29-year-olds in Sweden used nicotine pouches daily”, followed by a discussion of risks. Moreover, “Nicotine pouches are not proven tools for smoking cessation.”

 

Instead of celebrating this dramatic reduction in cigarette use in Sweden, which is the first European country to be classified as “smoke free” but the WHO, the report castigates the country as a risk for its neighbours.

“A significant proportion of young people in Finland, Estonia and Denmark are exposed to the health risks of snus, which is produced in Sweden and designed to appeal to young people through flavoured variants, slim sachets and brightly coloured packaging.” Perhaps young people are using snus as a low-risk alternative to conventional tobacco products? The refusal to make the causal relationship between low rates of smoking and high availability of snus – a product prohibited in every other EU member state – is indicative of the wider intent of the tobacco control community in the EU. 

 

Public health, the well-being of actual and potential tobacco consumers, has been sacrificed for a different goal. By invoking a vision of a ‘tobacco-free’ Europe, the tobacco control experts have inscribed themselves into the administrative machinery for another 15 years. Administrative self-interest has sadly replaced any concern for public health and wellbeing.