Nicotineproducten zonder tabak


Naam Swedish Association of Snus Manufacturers (Secretary General Patrik Strömer)
Plaats Stockholm, Sweden
Datum 5 januari 2023


Wat vindt u van het concept-wetsvoorstel?
It seems that cigarettes are not being banned. This raises questions about the purpose of the proposed legislation.
First, nicotine pouches are not regulated on a EU level, nor are they banned. Howevere, NP have been on the market in Sweden for several years, with an industry regulation earlier and since August 1st 2022 in the Swedish legislation. These products are put on the market, legislated and hence a part of the single market. If NL wants to raise trade barriers, it is a serious breach of the basic principles in the EU.
Second, such bans can be allowed if there is a purpose to protect health or environment. As long as cigarettes are allowed, this is not the case.

The ban on nicotine pouches are simply not a good proposal.

If we consider the reality, it is probably best to take a look at Sweden. This country ha by far the lowest smoking prevalence of all countries in the EU and also the lowest risk of disease and premature death. During tha last couple of years, two generations have become practically smokefree (<5% daily smokers), 16-29 and 30-44.
The correlation is clear. NP replaces cigarette smoking. While no scientific study has been made, common sense among the population shows that NP is NOT a gateway, but an exit and probably a stop sign.

NP should not be banned, but responsibly regulated. It is the tar, not the nicotine that poses danger to public health. By allowing smokers to become former smokers, as in Sweden, the overall improvement of public health can increase. Even if smoking rates decline in the developed world, countries with products that replaces smoking have much better outcome. If you really want to tackle the problems associated with smoking, you could easily copy+paste the Swedish legislation. Age limit, health warnings, limited marketing, and list of ingredients in the same way as food legislation is a proper way to regulate.