In an unexpected move before the Employment, Social Policy, Health and Consumer Affairs Council on the 21st of June, Denmark has issued a position paper advocating for a ban on nicotine pouches, or a de facto ban, by proposing a ban on flavors. The effort appears to be supported by Belgium and the Netherlands. The paper urges the European Commission to take action, suggesting initiatives should include a ban on flavors in nicotine products, a limit on nicotine content, and, where necessary, a ban on certain products.

While there is a consensus on the need for regulation to protect the underaged, it is remarkable to see a position paper that highlights smoking tobacco  as a prime cause of premature death in the EU, conclude that the reasonable response is to ban other products such as reduced-risk alternatives.

The Nordic Nicotine Pouches Alliance (NNPA) agrees with the direction for some of the proposed measures, but the sweeping statements about bans and a lack of proportionality lead us to perceive this proposal as a triple threat rather than a sensible starting position for negotiation. A flavour ban would effectively end the viability of nicotine pouches, as they do not have any inherent flavour, unlike tobacco, which always retains a flavour. While we advocate for a nicotine cap, a cap set too low would also eliminate any incentive for smokers to use the product, removing nicotine pouches from being a viable alternative to smoking cigarettes. It is unclear whether the final call for a ban on certain products is directly aimed at nicotine pouches, but given the support from Belgium and the Netherlands, both of which have banned nicotine pouches, we consider this a real and present danger.

There is a significant oversight in that the stringent proposals will not mitigate the risk of underage tobacco use and will be at best counterproductive, additionally leaving approximately 80 million adult smokers across Europe without safer alternatives. The NNPA’s push for regulatory reforms recognizes the potential of nicotine pouches as a harm reduction tool, providing a critical counterpoint to Denmark’s approach.

Nicotine pouches, distinct from conventional smoking, offer a smoke-free alternative that could dramatically reduce the health risks associated with tobacco combustion. The Swedish example, where smokeless nicotine products have contributed to one of the lowest smoking rates in Europe, demonstrates the potential benefits of such alternatives. Unlike traditional smoking, these products do not produce tar or carbon monoxide, two of the most harmful constituents of cigarette smoke. While the proposal is clear in its intention to safeguard the underage, it exhibits a one-eyed approach by disregarding vital broader concerns. The absence of viable alternatives for current smokers could result in a significant public health dilemma. Denmark’s efforts to safeguard its youth from nicotine addiction are commendable, but their proposals are unfortunately no more than a simplistic response to a complex issue, and a more balanced approach is necessary to avoid directly harmful consequences.

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