EU SCHEER opinion on vaping products is flawed01.01.21
Fontem Ventures believes the conclusions reached by the European Commission’s Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) Preliminary Opinion on Electronic Cigarettes, published in October 2020, are extremely disappointing. The report is important because it could influence the future direction of vaping regulation in the EU, and thus impact the lives of more than an estimated 70 million European smokers and vapers.
Fontem Ventures parent company Imperial Brands has submitted a detailed response to the consultation. This submission identifies flaws in the report including:
- Relative vs. absolute risk: The SCHEER report does not 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. Instead, the SCHEER report focuses solely on absolute risk. Although this is an important consideration when assessing potential risks for never smokers, the committee should also have addressed relative risk i.e. the relative risk of vaping for existing adult smokers and in relation to continuing to smoke cigarettes.. In marked contrast, the UK Committee on Toxicity’s recent report – which analysed vaping through the lens of relative risk – reached far more progressive conclusions around vaping’s potentially pivotal role in helping facilitate harm reduction.
- Health impacts of vaping vs. continued smoking: The SCHEER failed 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 Gateway argument, we urge them to publish it.
It’s also 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, the past 18 months of rich scientific literature has effectively been ignored.
We acknowledge vaping products have not been in use for a sufficient period to generate epidemiological data, and agree more research is needed into the health impact 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.
Through its consultation response Fontem Ventures’ parent company Imperial Brands will continue to engage with the European Commission on the behalf of Europe’s smokers and vapers to ensure vaping regulation is informed and driven by substantiated research and a genuine scientific consensus.