In April 2026, the European Commission’s Joint Research Centre (JRC) published its report entitled “Health outcomes associated with the use of e-cigarettes, heated tobacco products, and nicotine pouches”[1], as part of the evidence base for the revision of the Tobacco Products and the Tobacco Advertising Directives.
According to the JRC, “several of the examined sources recommend a precautionary approach” towards these products “due to the concerning associations with short- and medium-term health outcomes”, with “long-term follow-up necessary to accurately estimate their health risks”.
This conclusion may now do more than inform the debate. It may define the problem, shape the regulatory options, frame proportionality, and narrow the space of Member States to regulate different product categories according to their risk profile.
That is too much weight for this report to carry, especially given its demonstrable limitations.
Imperial Brands has identified five serious limitations in the JRC Report.
Taken as a whole, they show it cannot serve as a sound scientific basis for the regulation of e-cigarettes, heated products, and nicotine pouches.
To be clear, we acknowledge that public health reports that synthesise primary peer‑reviewed evidence are potentially robust and valuable components of the evidence base.
However, the JRC Report relies on these secondary interpretations without undertaking a transparent or systematic synthesis of the underlying primary literature itself. This creates a risk of layered interpretation, where conclusions are derived from an interpretation of existing interpretations, rather than from direct engagement with the primary evidence.
We believe that an approach like this can affect the balance and accuracy of conclusions, particularly where the inclusion of relevant public health reports and review publications is incomprehensive.
The warning signs are already visible. Numerous independent scientists and academics have challenged the direction of the debate through Call for Evidence responses, public letters, and reactions to Commissioner Várhelyi’s statement that these products are “one hundred per cent” as harmful as traditional cigarettes[2].
The EC’s upcoming Impact Assessment should therefore not treat the JRC report as a ready-made comprehensive evidentiary foundation. It should test it against the wider body of peer-reviewed science on e-cigarettes, heated products, nicotine pouches, relative risk and tobacco harm reduction.
The problem is not a lack of evidence. It is whether the Commission is prepared to engage with evidence that challenges its pre-determined political direction.
This can – and should – be addressed in the Impact Assessment.
Our suggested limitations in the JRC Report are as follows:
The JRC Report does not always carry the caution of its sources into its own conclusions.
In several places, the report uses evidence that is limited, mixed, or inaccurate – while this is often presented in a more established way than it actually is.
The problem is visible in at least three instances:
The European Parliament should not be asked to scrutinise policy options built on scientific certainty the evidence does not suggest.
The JRC Report gives significant attention to potential risks from e-cigarettes, heated products, and nicotine pouches.
The missing question is how those risks compare with continued cigarette smoking.
While millions of adults in Europe continue to smoke, millions have also switched to non-combustible alternatives.
The report does not give this comparison enough focus, and therefore lacks significant contextualisation in terms of relative risk.
This represents a gap, visible in at least three key instances:
Member States’ competence to regulate smokeless products according to their own evidence, experience, and public health outcomes should not be narrowed by an evidence base that has not comprehensively evaluated relative risk, real-world experience, and national epidemiological findings.
The JRC Report gives limited relevance to real-world and population-level evidence.
That is a serious gap.
While the report refers to some datasets, including Eurobarometer, it does not fully reflect smoking trends in countries where non-combustible alternatives have been widely adopted, including Sweden, or where access to such products has been regulated proportionately, like Greece and the Czech Republic.
Real-world evidence matters because it shows what actually happens outside a controlled study setting and accounts for consumers’ behaviours in their everyday life.
A report that gives limited attention to population-level trends across multiple countries, cannot fully assess the role of smokeless products in the context of tobacco harm reduction.
The JRC Report ultimately draws broader conclusions than its evidence base can robustly support.
While it cites 47 references, only 34 are used to inform the assessment, with the remainder confined to the introduction. Within this subset, primary peer‑reviewed research is limited to just 8 studies. The majority of the evidence base therefore comprises institutional reports, summaries, and secondary interpretations rather than original scientific research.
In a rapidly evolving field, this represents a constrained evidentiary foundation for policy-relevant conclusions affecting tens of millions of consumers.
The report itself acknowledges that some sources lack methodological transparency or rely on expert judgement to interpret findings. In this context, the absence of explicit triangulation and critical appraisal of the full evidence base limits confidence in the strength and objectivity of the conclusions drawn.
Additionally, the source selection is incomplete. The report uses an evidence cut-off of November 2024. Yet relevant and recent authoritative publications falling within that cut-off were not included. For example;
The JRC Report uses labels such as “sufficient”, “moderate”, and “limited” to describe the strength of evidence linking product use to health outcomes.
But it does not clearly explain how those labels were assigned and graded.
That is a material weakness.
Without a transparent grading and balanced interpretation, triangulation, and critique of the broader existing science, it is difficult to know whether the report’s conclusions reflect the strength of the evidence, or the interpretations placed on it.
For more Imperial Brands content around the Tobacco Products Directive Evaluation & JRC Report, see this blog.
[1] PEREZ CORNAGO, A., SARASA RENEDO, A., JARACH, C., WOLLGAST, J. and MARAGKOUDAKIS, P., Health outcomes associated with the use of e-cigarettes, heated tobacco products, and nicotine pouches, Publications Office of the European Union, Luxembourg, 2026, https://data.europa.eu/doi/10.2760/0061469, JRC146139. Available here.
[2] Euractiv. (2025, December 18). EXCLUSIVE: EU health chief 100% convinced new products as harmful as cigarettes.
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