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RESPONSES OF THE GREEK NGO "NOSMOKE.GR" TO THE PUBLIC CONSULTATION DOCUMENT CONCERNING THE REVISION OF THE TOBACCO PRODUCTS DIRECTIVE 2001/37/EC

PREPARED FOR THE EUROPEAN COMMISSION, HEALTH AND CONSUMERS DIRECTORATE GENERAL
By
Mr Alexandros Foteinos, President, ‘NOSMOKE.GR’
Dr Lambros Lazuras, Scientific Advisor, "NOSMOKE.GR"

15/10/2010


I) INTRODUCTION

The members of the Greek NGO ‘NOSMOKE.GR’ have carefully reviewed the Public Consultation Document concerning possible revisions of the Tobacco Products Directive 2001/37/EC. In general terms we agree with the problem definitions and the available options, but also feel that there is room for improvement in particular areas, so that the tobacco control efforts of the Member States are harmonized and effectively tap the tobacco epidemic. Specific comments and recommendations on the areas of possible change of the Directive are presented in more detail as follows.

II) AREAS OF POSSIBLE CHANGE – ‘NOSMOKE.GR’ SPECIFIC COMMENTS AND RECOMMENDATIONS

1. Scope of the Directive

NOSMOKE.GR agrees with the problem definition in this area, and recommends that Option 2 (Extend the scope of the Directive) addresses the problem most effectively. We do not have any further recommendations, however, there is one issue concerning the marketing and use of ENDS by the public. Specifically, if ENDS are intended to be used as cigarette supplements that will help smokers quit their habit (much like the claims regarding the use of ‘Snus’) their purpose and marketing rules should be changed as appropriate. That means that ENDS should be explicitly marketed as smoking cessation aids, and their marketing should be guided by the directives and ordinances applied to other pharmaceutical products used for the same purpose (i.e., smoking cessation). If ENDS are finally marketed as smoking cessation aids, then their effectiveness should be examined rigorously following the standard clinical trials procedures, and the findings from the clinical trials studies should be reported back to the scientific community for further scrutiny and replication.

2. Smokeless Tobacco Products
NOSMOKE.GR agrees with the problem definition in this area, and recommends that Option 3 (Ban on all types of smokeless tobacco products) addresses the problem most effectively. We do not have any further recommendations to make.

3. Consumer Information
NOSMOKE.GR agrees with the problem definition in this area, and recommends that Option 3 (Introduce generic or plain packaging) addresses the problem most effectively. Nonetheless, we believe there are complementary measures to be taken so that Option 3 is more effectively applied. In particular, we recommend that:
a) Any information regarding ‘light’ cigarettes is removed from cigarette packages, so that the only text used for marketing purposes is the label of the specific brand. However, in compliance with Option 3 the brand name should be colourless.
b) In addition to text warning regarding the harmful effects of tobacco use, additional text should be added on packages that will remind smokers of the smoking bans in public places (e.g., “It is forbidden by the law to smoke in closed public places”). This reminder would be more relevant to Member States where smoking bans in public places are not yet implemented, or have been implemented very recently and smokers strongly oppose them (e.g., Greece). This measure will help Member States harmonize their practices in reducing exposure to SHS in public places, and will greatly benefit countries under accession, where smoke-free policies are not yet aligned with EU practices and the mandates of the FCTC.

4. Reporting and Registration of Ingredients
NOSMOKE.GR agrees with the problem definition in this area, and recommends that Option 3 (Introduce fees and sanctions) addresses the problem most effectively. We do not have any further recommendations to make.  

5. Regulation of Ingredients
NOSMOKE.GR agrees with the problem definition in this area, and recommends that Option 3b (Establish a negative common list of tobacco ingredients) addresses the problem most effectively. Nevertheless, we believe that there is one issue that needs to be addressed in the Revised Tobacco Products Directive that has not been tapped in the available options of the Public Consultation Document. Specifically, having a negative common list does not preclude the possibility that the ingredients in the positive list are used. This is problematic and may potentially hinder efforts to reduce tobacco consumption for the following reason. The purpose of using attractive substances (even if they are listed on the positive list) is to increase the purchase of tobacco products. If packages are intended to be colourless and out of sight in public venues, then the tobacco industry could use its last marketing strategy available (i.e., regulation of ingredients) to continue promoting tobacco products in order to recruit new smokers (typically adolescents and young people). In a few words, if a positive list is allowed to be used, the tobacco industry may provide substances that will make tobacco products more attractive and perhaps more addictive, and this obviously hinders the scope of the Tobacco Products Directive. Therefore, the recommendation of NOSMOKE.GR regarding the regulation of ingredients is that only a common negative list is used, and that the tobacco industry is not allowed to use any substance to make tobacco products more attractive and addictive.

6. Access to Tobacco Products
NOSMOKE.GR agrees with the problem definition in this area, and recommends that Option 3 (Extend the scope of the Directive) addresses the problem most effectively. We do not have any further recommendations to make.