UK OPEN PUBLIC CONSULTATION

“Smoke Free Generation”

Attention of: Department of Health and Social Care, UK

We are following with great interest the initiatives you are taking to reduce smoking in the UK, and we would like to congratulate you for your efforts to address the issue based upon scientific evidence. Your pioneering initiatives, such as “Swap To Stop” and “Smoke Free Generation”, are discussed in many scientific fora on Tobacco Harm Reduction. We perceive them as pathbreaking practices for other governments to evaluate. In view of this new legislation aiming to further reduce the smoking rates, besides vaping, the non-combustible tobacco products may be considered as an option, since there is mounting scientific evidence that they contribute to tobacco harm reduction.

The SNUS case in Sweden provides compelling evidence that nicotine is not responsible for most of the detrimental effects of smoking¹. Sweden is the only EU country and one of the few countries globally where snus has been used for decades by most nicotine users. Smoking rates have fallen from 15% to 5.6% over the past 15 years², since smokers in Sweden were provided an alternative that led to lower death rates from cardiovascular disease, lung cancer, and other cancers, compared to the rest of Europe¹.

Furthermore, snus has received an MRTP order by the FDA (FDA Authorizes Modified Risk Tobacco Products | FDA), i.e. it may be advertised as a lower risk product versus smoking cigarettes. The approved claim is: “Using General Snus instead of cigarettes puts you at a lower risk of mouth cancer, heart disease, lung cancer, stroke, emphysema, and chronic bronchitis.”

Moreover, in Article 1 – Use of terms of the FCTC, it is explicitly stated (d) “tobacco control” means a range of supply, demand and harm reduction strategies that aim to improve the health of a population by eliminating or reducing their consumption of tobacco products and exposure to tobacco smoke. Most novel products are aligned with the principles of harm reduction, defined in article 1 of the FCTC, and UK Public Health was the pioneer that first implemented “Swap To Stop”. In line with this, you may consider Heated Tobacco Products (HTPs), as another lower-risk alternative to smoking with mounting scientific evidence that shows reduced exposure to toxicants compared to smoking.

We are sharing your concerns about the rise in vaping among children and youth, and we support your proposals to restrict child-friendly flavours and bright-coloured packaging.

The change of law you are attempting is pathbreaking but bears risks and it should be complemented with other measures that deter “prohibition” repercussions, i.e., illegal trade. Prohibition has not always resulted in the desired outcome. The USA national prohibition of alcohol (1920–33) – the “noble experiment”, is considered a failure and although we believe that you have taken this into consideration, we are in doubt whether prohibition of smoking cigarettes may result in the anticipated outcome. For this reason, we responded “Don’t know” in the questionnaire “Legislation to create a smokefree generation”. SCOHRE shares your vision of a “Smoke Free Generation” in the coming years and aspires to contribute to a new approach to smoking control policies.

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1. The Global Burden of Disease Study by LM. Ramström (2020)
2. Swedish snus and public health, Lakeville 2021