A group of 26 independent scientists and public health experts from different European countries has sent a letter to the President of the European Commission, Ursula von der Leyen, and to members of the Community Executive to demand a review of the regulatory approach to tobacco and nicotine products, with the aim of aligning it with available scientific evidence.
The letter is accompanied by 131 scientific studies that were not included in the recent impact assessment report of the Directive published by the European Commission, with the intention that the Executive take this documentation into account.
The signatories express their concern about the possibility that the future European regulation starts from the premise that all nicotine products present risks equivalent to those of conventional cigarettes. In their opinion, this statement "is not supported by evidence". In this regard, they emphasize that "it is not supported by evidence to treat fundamentally different products in terms of public health risk as equals".
Experts recall that, although electronic cigarettes, heated tobacco, or nicotine pouches are not risk-free and must remain subject to strict regulation —especially to prevent their use by minors—, they cannot be equated in terms of danger to combustible tobacco. “It is equally incorrect to suggest that these products are as dangerous as smoking, or to regulate them as if they were,” they warn.
The main risk is tobacco combustion
The letter emphasizes that the main risk factor of smoking is tobacco combustion, responsible for the release of toxic substances associated with cancer, cardiovascular and pulmonary diseases, and premature mortality. In contrast, they maintain that nicotine, although addictive, is not the main cause of these harms.
In this context, the signatories argue that the evaluation of non-combustion products should be done in comparison with the continued consumption of cigarettes, and not solely against total abstinence. “The key question is not whether these products are risk-free, but whether they are more or less harmful than continuing to smoke,” they point out.
Likewise, they warn that evaluating these alternatives exclusively against "non-use" can lead to regulatory decisions far removed from the reality of millions of adult smokers, for whom the immediate alternative is not to stop consuming nicotine, but to continue smoking.
Alert for confusion between nicotine and smoke
Scientists also warn of the confusion in public debate between nicotine and smoke, and point out that this equation can mislead both citizens and policymakers. “Confusing nicotine with smoke is not a minor technical error: it misinforms the public and can lead to bad legislation,” they point out.
In relation to the protection of minors, the signatories agree that it must be a priority, although they emphasize that this objective must not replace scientific rigor nor justify policies based on incorrect premises. In this regard, they indicate that international evidence shows that youth smoking has continued to decline in countries where there are non-combustion alternatives under strict regulatory frameworks.
Warning about the goal of a tobacco-free generation
Lastly, the letter warns that the European Union's goal of achieving a "tobacco-free generation" —defined as a prevalence of less than 5% by 2040— could be compromised if regulation does not adequately distinguish between different products.
“Legislating on the basis that all nicotine products are the same risks protecting the cigarette market rather than reducing it,” conclude the experts, who urge the European Commission to adopt a regulatory approach that reflects the risk continuum between products, clearly differentiates between the effects of combustion and nicotine, and follows the comparative approach requested by the European Parliament in its resolutions.
“Europe cannot claim to ‘follow the science’ in the fight against cancer while ignoring one of the most basic scientific distinctions: the difference between smoke and non-combustion products,” the letter concludes.