__We strongly believe that the proposed initiative is counter to good health policy and fails to meet the stated objectives to be part of the EU’s ‘beating cancer’ plan and to “ensuring a high level of human health protection”. Nor is it consistent with the EU’s cardiovascular health plan.
__In the face of a rapidly evolving nicotine-product marketplace, policymakers could consider differentially taxing these products [i.e. non-combustible tobacco products] to maximize incentives for tobacco users to switch from the most harmful products to the least harmful ones.
__We also recommend that the EU consider issues of fundamental justice when considering this directive. Cigarette smoking is a dependence-based activity focused on nicotine delivery.
__Tax-mandated tax increases give consumers an incentive to change behaviours. But unless policies are well crafted the choices made are not necessarily what the policy makers had in mind […] In the absence of a significant economic and informational incentive to move to lower risk alternatives [consumers may resort to] other, clearly deleterious, options to deal with the price change. Illicit trade is the most obvious and these networks are already in place and can be expected to respond to greater profit potential.