Dear Mrs. Anderson,
I am writing to you as a scientist who has been involved in nicotine and tobacco dependence for almost 30 years now (first PhD thesis on the subject in France), to alert you on the content of the proposed updated European Tobacco Products Directive, that may cause more death and disease that it intends to do.
The new Directive on Tobacco products proposes to regulate all nicotine containing products, including e-cigarettes. It would do this by classifying most products as medicines. While a ‘light touch’ approach protecting the consumer (by controlling the quality of e-cigarettes and e-liquids) would be beneficial to public health, an excessively restrictive regulation, as currently proposed in the updated Directive (making mandatory for e-cigarette companies to apply for market authorisation similar to medicines), would deny smokers a much safer alternative to smoking cigarettes, while cigarettes would still be almost unregulated and easily accessible.
Should I remind you that tobacco kills more than 70,000 people in France, more than 500,000 in Europe, and more than 5 millions in the world each year. In France, a recent report from the Cour des comptes (http://www.ccomptes.fr/Actualites/A-la-une/Les-politiques-de-lutte-contre-le-tabagisme) has criticised the government about its tobacco control policy which failed to reduce efficiently tobacco smoking in our country (in English here: http://www.france24.com/en/20121213-france-told-hike-prices-stub-out-smoking), resulting in an increase in smoking prevalence between 2005 and 2010. While this may be true also in other European countries, probably due to a strong lobbying of the tobacco industry, it is not in the UK, where an efficient tobacco control program has considerably reduced the number of smokers during the last decade.
A recent ASH briefing on e-cigarettes states that : ‘Electronic cigarettes, also known as electronic nicotine delivery systems (ENDS), are designed to look and feel like cigarettes… A typical e-cigarette consists of three components: a battery, an atomiser and a cartridge containing nicotine. Most replaceable cartridges contain nicotine suspended in propylene glycol or glycerine and water. The level of nicotine in the cartridges may vary and some also contain flavourings… When a user sucks on the device, a sensor detects air flow and heats the liquid in the cartridge so that it evaporates. The vapour delivers the nicotine to the user. There is no side-stream smoke but some nicotine vapour is released into the air as the smoker exhales.’ (http://ash.org.uk/information/facts-and-stats/ash-briefings).
In Europe like in many countries, e-cigarette regulation is not well defined. In France, e-cigarettes with less than 10 mg nicotine per cartridge, or e-liquids with less than 20 mg/ml can be sold without authorisation (for higher doses or concentrations, the medicines regulatory authority, ANSM, requires the companies to apply for a market authorisation (http://ansm.sante.fr/S-informer/Points-d-information-Points-d-information/Cigarette-electronique-Point-d-information).
The current situation is fully satisfying the e-cigarette users. However, the proposal for the updated Tobacco Product Directive would impose a limit of 2 mg per cartridge, or 4 mg/ml for e-liquids. For a pharmacologist, this means that those concentrations would not allow smokers to obtain sufficient blood nicotine levels to reverse the effects of withdrawal, and means that smokers would have to continue smoking in order to obtain the nicotine they need, due to their dependence on nicotine.
Yet, the main interest of the e-cigarette is that it allows the user (called a vaper) to rapidly quit smoking, as testified on the numerous internet forums they have created (which is a new phenomenon never seen before among smokers). In these forums, vapers use a signature that very often includes the number of cigarettes they have not smoked since they started to use an e-cigarette. Considering that what kills in tobacco smoke is not nicotine, which sustains dependence but does not cause harm, but the more than 7,000 other substances, including carbon monoxide and oxidant gases, which are harmful for the cardiovascular system, and cancer causing substances, using an e-cigarette allows the user to avoid all these deadly substances at once, but the nicotine they need to reduce their withdrawal symptoms.
It would be damageable, because of a too stringent regulation, to stop this phenomenon which could lead to the vision expressed by Michael Russell in 1991, a pioneer in tobacco dependence research: ‘It is not so much the efficacy of new nicotine delivery systems as temporary aids to cessation, but their potential as long-term alternatives to tobacco that makes the virtual elimination of tobacco a realistic future target. … Such products should be actively promoted on the open market to compete with tobacco products. They will need health authority endorsement, tax advantages and support from anti-smoking movement if tobacco use is to be gradually phased out altogether.’
Since the Environment, Public Health and Food Safety Committee is supposed to meet shortly to discuss the new Tobacco Products Directive, I would be pleased to provide you with more detailed information, and would welcome the opportunity to discuss these issues with you in person. Meanwhile, I hope you will be able to consider these suggestions, and confirm your support.
Jacques Le Houezec, PhD
Consultant in Public Health, Tobacco dependence
Honorary Lecturer, UK Centre for Tobacco Control Studies, University of Nottingham, England.