Regeling reguleren smaken e-sigaret


Naam European Tobacco Harm Reduction Advocates (ETHRA) (Mr D Sweeney)
Plaats Co Donegal, Ireland
Datum 26 september 2022


Wat vindt u van de concept regeling?
1. Introductory remarks
Thank you for the opportunity to comment on the proposed amendment to the Tobacco and Related Products Order, which would limit the number of approved substances allowed to make tobacco e-liquids only to 16, as specified in Article 2.12. We shall also submit these comments to TRIS.

European Tobacco Harm Reduction Advocates is the voice of 27 million(1) EU consumers of safer nicotine products. ETHRA is a consortium of 25 grassroots consumer associations in 17 European countries, supported by experts in tobacco control and nicotine research. We are mostly ex-smokers who have used safer nicotine products, such as vapes, nicotine pouches, heated tobacco products, and snus, to quit smoking and to remain smoke free. ETHRA is a voluntary operation with no industry funding or conflicts of interest. Our EU Transparency Register number is 354946837243-73.

The objective of the proposed amendment, as set out in the Integrated Assessment Framework for Policy and Regulations (IAK), is to protect public health by reducing the attractiveness of electronic cigarettes to the general population, but particularly to young people. This raises serious concerns as the amendment would amount to a de facto ban on vaping products. The consequences of removing adult access to the most popular and effective smoking cessation tool will be negative to public health. Smoking will increase, especially amongst the middle aged and elderly - those people most at risk from the health harms associated with smoking. It would destroy the legal vaping industry in the Netherlands, and we predict that the black market would flourish.

ETHRA has regularly engaged with NL ministers and parliamentarians to raise concerns(2, 3) and we also urge you to heed the warnings in ‘Regulation of e-cigarette flavours – a response’, a submission to the 2020 consultation signed by twenty-four scientific and policy experts.(4)

Please download the attached pdf for our full submission.