Submissions to the EU call for evidence; Smoke-free environments.

The consultation period for this proposed amendment has just closed. This proposal aims to amend the current smoke-free environments act to extend its coverage to emerging products and its scope to additional outdoor spaces (e.g. schools & playgrounds). Once again the EU commission is out of step with the huge support for harm reduction among its citizens. The Call for Evidence on the legislative framework for tobacco control received 24,000 replies, mostly from ordinary citizens who overwhelmingly support reduced-risk products.

This current proposal is another step in the commission’s misguided attempt to treat all nicotine products the same as combustible cigarettes without any regard for the huge difference in the harm caused.

Our submission is reproduced below.

EU Call for evidence: Smoke-free environments – updated recommendation

Thank you for this opportunity to contribute to the ‘EU Commission; call for evidence towards updated recommendations on smoke-free environments ’.

 Public engagement with policy is an important part of any legislative process.

We are the New Nicotine Alliance Ireland, a consumer-led tobacco harm reduction group. Our mission is to represent the interests of the 200,000 users of smoke-free nicotine products in Ireland and to further the cause of harm reduction in tobacco control policy. We are not connected with or funded by either tobacco interests or e-cigarette interests.

The commission has proposed extending smoke-free policies such that they would include smoke-free products such as E-cigarettes and Heat not Burn tobacco products. The obvious problem with this is the current smoke-free policy is designed primarily to protect people from tobacco smoke. E-cigarettes produce no smoke and as such are already smoke-free. The secondary function of smoke-free policies is to encourage smokers to quit. Removing this advantage of e-cigarettes removes an incentive to quit.

Extending smoke-free coverage to smoke-free products is counterproductive

Including smoke-free products in this would be problematic for the following reasons.

There is no justification for their inclusion as the policy is intended to primarily protect people from tobacco smoke and secondly to encourage smokers to quit. Adding smoke-free products will not protect people from smoke and will reduce the appeal of smoke-free products to current smokers and reduce quitting. This would be a retrograde step, considering smoking is still the single most preventable cause of cancer. This proposed change to smoke-free environments is a part of Europes beating cancer plan, in that context reducing quitting is exactly what we must not risk.

Allowing the use of smoke-free products in smoke-free environments will not renormalize smoking, instead, it normalizes, not smoking, Use of smoke-free products has already contributed to an acceleration of smoking reduction rates. This should not be lost in the rush to achieve a tobacco-free Europe, while smoked products still account for all of the harm from tobacco consumption.

It creates a false equivalence between combustible products and products which produce no smoke. This is misleading to both smokers who may switch and the general public.

Not to mention the anomaly of exposing non-smokers to environmental tobacco smoke if e-cigarette users are obliged to share space in smoking areas.

The evidence base in favor of extending smoke-free coverage is lacking

There is no evidence base for this extension of policy. The commission cites the July 2021 WHO Report which contains no comparison between the aerosol of smoke-free products and combustible cigarettes. It assumes any exposure is detrimental without any evidence of this.

The commission also cites the Scientific Committee on Health, Environmental and Emerging Risks opinion on e-cigarettes. This is a widely criticized opinion that claims to show low to moderate evidence of risk from secondhand exposure while at the same time admitting no evidence exists. It then hypothesizes on third-hand exposure to nicotine.

The correct action would be to leave the issue of the use of these products to managers and proprietors, who take the interest of their customers into account. Without any real evidence of harm, this is not a matter of legal enforcement, rather it’s a matter of etiquette.

Smoking remains the most deadly form of nicotine consumption, anything that reduces that must not be hindered. Anything that might risk impeding the reduction in smoking must be rejected.

As there is no compelling evidence of any risk to bystanders, there is no compelling reason to include smoke-free products in any extension of smoke-free policies.

The commission should instead concentrate on reducing the health toll of combustible tobacco use and offer guidance as to the relative risk of all categories of products.

We thank you for your time

The New Nicotine Alliance Ireland (Charity number 20204637)

Contact details;

086 8505931

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