//Our Response to the EU SCHEER Preliminary Opinion on Electronic Cigarettes

The European Commission’s Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) recently published its Preliminary Opinion on Electronic Cigarettes.

The conclusions reached by the report – and, crucially, the evidence selected to arrive at these conclusions – are extremely disappointing. Rather than endorse vaping as a key component of the public health concept of tobacco harm reduction (THR), it further undermines a category that’s already been the victim of unjust media coverage over the last 12 months.

The report could therefore have further calamitous repercussions on the health of millions of adult smokers in the EU who have turned to electronic cigarettes and vaping – and the tens of millions more who may potentially yet turn – as a less harmful way of consuming nicotine compared to combustible tobacco.

Imperial Brands has submitted a detailed response to the consultation. However, to help mitigate further unwarranted damage to the category in the interim it’s important to address what both ourselves and independent THR experts like Clive Bates perceive to be key flaws in the report. These include:

• Relative vs. absolute risk: The SCHEER don’t consider the potential health impacts of vapes within the context of their primary function – of providing adult smokers with a less harmful alternative relative to continued combustible cigarette smoking. The role – and considerable evidence of success in numerous countries – of vapes in helping facilitate the public health concept of THR among adult smokers who would otherwise continue to smoke is simply not considered, let alone placed front and centre of the report. Instead, the SCHEER focuses solely on absolute risk. Although this is an important consideration when assessing potential risks for never smokers, the SCHEER must delineate relative risk (for those adult smokers who have transitioned to vaping, and perhaps more importantly those who continue to smoke and would benefit most from transitioning) and absolute risk (for never smokers). In marked contrast, the UK Committee on Toxicity’s recent report – which analysed vaping through the THR-focused lens of relative risk – reached far more progressive conclusions around vaping’s potentially pivotal role in helping facilitate THR.

• Health impacts of vaping vs. continued smoking: The SCHEER fails to consider the extensive scientific literature which demonstrates that vape aerosols contain fewer, and substantially lower levels of, harmful chemicals compared to cigarette smoke. By extension, a growing body of clinical evidence also demonstrates adult smokers’ exposure to carcinogens and toxicants found in cigarette smoke is substantially lower when they transition to vaping –similar to the levels measured in ‘cold-turkey’ quitters or Nicotine Replacement Therapy users. Looking to cardiovascular risks specifically, as raised in the SCHEER opinion, a recent and robust British Heart Foundation-funded clinical study demonstrated substantial benefits in cardiovascular measures and vascular function when adult smokers transitioned to vaping after only a month’s usage. This independent study was not even considered by SCHEER.

• Gateway: While the SCHEER flag a risk of a potential gateway from vaping into combustible tobacco usage, the real-world evidence simply doesn’t support their hypothesis. Well-regulated vape markets like the UK, US and most recently Canada continue to demonstrate historic declines in smoking rates among both adults and youth. If the SCHEER is able to present credible data to support their argument, we urge them to publish it.

Finally, it’s worth noting the SCHEER only considers data and articles published between January 2015 and April 2019. With the body of scholarly research around vaping continuing to increase exponentially, the past 18 months of rich scientific literature – much of which contributes to the argument that vaping actively helps facilitate THR – has effectively been ignored.

We acknowledge vapes have not been around for a sufficient period to generate epidemiological data, and agree more research is needed into the effects of long-term usage. However, the extended health impacts of smoking tobacco are well known, and the totality of the scientific evidence to-date indicates vapes are significantly less harmful. That’s why many public health bodies and regulators around the world advocate adult smokers transition.

Overall, we suggest the SCHEER’s Preliminary Opinion on Electronic Cigarettes lacks scientific rigour by appearing selective in terms of its references – appearing out-of-touch with the current scientific consensus on vaping. Rather than pragmatically embracing the category’s increasingly demonstrable THR potential, it instead reverts to the uncompromising ‘quit or die’ approach epitomised by the World Health Organisation with regard to cessation. Despite being pursued with zeal for decades, this approach has failed to make a significant dent in global smoking rates.

As well as being extremely disappointing in its own right, the SCHEER report may also foreshadow the upcoming revision to the EU Tobacco Products Directive.

If so, it’s another hammer blow (akin to the EU’s regulation of snus, in marked contrast to the US FDA’s approach) to the public health opportunity that THR – and categories like vaping – afford.

And the real losers? More than seventy million adult smokers across the European Union who may be discouraged from choosing lower risk alternatives to combustible tobacco.

Through our consultation response Imperial Brands will continue to engage on their behalf to ensure vaping regulation is informed and driven by substantiated research and genuine scientific consensus.

NB. Some of the content in this OpEd has also appeared in a piece on Euractiv.

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