In response to the European Commission's evaluation report on the Tobacco Products Directive (TPD), published on 2 April 2026, Quit Like Sweden, alongside Professor Marewa Glover and Dr Anders Milton, has formally submitted an evidence document to Commissioner Olivér Várhelyi, members of his cabinet, and senior officials in DG SANTE.
Our formal communication identifies a critical gap in the evaluation's treatment of non-combustible nicotine products. The evidence on their relative risk profile, their role in smoking cessation, and the real-world consequences of overly restrictive regulation deserves fuller consideration as the Commission prepares its revision.
The supporting document draws on peer-reviewed literature, including sources cited within the Joint Research Centre's own report, and points to the experience of Sweden, New Zealand, and the United Kingdom as evidence that a large-scale transition away from combustible tobacco is achievable with proportionate, evidence-informed policy.
We respectfully urge the Commission to ensure the forthcoming TPD revision draws on the full breadth of available evidence.
A CRITICAL GAP IN THE EVIDENCE: NON-COMBUSTIBLE PRODUCTS IN THE TDP EVALUATION
We write in response to the evaluation report on the Tobacco Products Directive (TPD), published on 2 April 2026, and wish to offer a constructive contribution to the evidence base as the Commission considers the direction of the forthcoming revision. We share the Commission's commitment to reducing the burden of tobacco-related disease across the European Union. It is precisely this shared objective that leads us to raise a number of concerns regarding the report's treatment of non-combustible nicotine products, and to submit the following evidence for consideration.
THE CURRENT PRODUCT LANDSCAPE
Smoking prevalence across the EU averages 24%, ranging from 8% to 37% across Member States, whilst use of non-combustible alternatives remains comparatively low, under 2% for heated tobacco products, approximately 3% for e-cigarettes, and 4% for nicotine pouches. 1
Sweden offers an instructive case study. With daily smoking prevalence now at just 3.7% 2 and nicotine use rates broadly comparable to the EU average, Sweden has seen a substantial shift in product preference, from cigarettes toward oral nicotine products such as snus and, more recently, nicotine pouches. This transition has been associated with significantly reduced exposure to harmful toxicants and with measurable public health improvements.
Eurostat data confirm that Sweden records the lowest standardised lung cancer death rate among men in the EU, approximately half the EU average, and the lowest overall standardised cancer death rate among male 3. These outcomes are broadly consistent with the body of peer-reviewed literature on tobacco-related mortality in Sweden relative to EU comparators. 4,5
We respectfully suggest that these outcomes merit serious consideration in the context of the TPD revision, as they speak directly to what proportionate, evidence-informed policy can achieve at a population level.
RELATIVE RISK OF NON-COMBUSTIBLE PRODUCTS
No tobacco or nicotine product is without risk, and we do not suggest otherwise. However, the relative risk profile of different products is an essential consideration in any regulatory framework designed to protect public health.
A systematic review and meta-analysis of nicotine product relative risk, conducted in 2022 and updated in 2025, found that, with conventional cigarettes assigned a risk score of 100, e-cigarettes, heated tobacco products, and nicotine pouches carry substantially lower combined risk scores of between 3 and 6 6. Lifetime cancer risk for heated tobacco products, e-cigarettes, and snus is estimated to be 95.5%, 96.6%, and 99.1% lower than for cigarettes, respectively. These conclusions are broadly consistent with assessments published by a number of national and international public health bodies, including sources cited within the Joint Research Centre's own report 7.
We note that the evaluation report does not give sufficient weight to this body of evidence, nor does it adequately contextualise the risk profile of non-combustible products relative to continued cigarette smoking, the realistic alternative for many users who do not achieve cessation.
SMOKING CESSATION
The evaluation report concludes that there is insufficient evidence to regard newer nicotine products as effective cessation tools. We would draw the Commission's attention to evidence that appears to contradict this conclusion, including sources referenced within the Commission's own evaluation.
A 2024 Cochrane systematic review, representing the most rigorous summary of available evidence, found high-certainty evidence that nicotine-containing e-cigarettes increase quit rates compared with nicotine replacement therapy (NRT), and moderate-certainty evidence of benefit compared with non-nicotine e-cigarettes. 8 The NHS in England formally endorses vaping as an effective quitting tool on this basis. 9
At a population level, countries that have adopted a supportive, proportionate approach to vaping regulation have seen notable declines in smoking prevalence. In the United Kingdom, smoking rates have fallen faster than in most EU Member States since vaping became widely used, with youth smoking declining to historic lows even as vaping prevalence increased. In New Zealand, smoking prevalence fell from 16.4% in 2012 to 6.8% in 2025, a decline of 58.5%, with the Ministry of Health identifying vaping as a key contributing factor. 10
GATEWAY CONCERNS AND THE WEIGHT OF EVIDENCE
We appreciate that the evaluation report and the JRC study both address the question of gateway effects, and we note that the JRC report itself acknowledges that the majority of relevant studies are observational in nature, that many explicitly caution against causal inference, and that social and socioeconomic confounders are significant. 7
Population-level evidence does not support a meaningful gateway effect. In countries with proportionate vaping regulation, the United Kingdom, the United States, and New Zealand among them, increases in youth vaping have been accompanied by declines in youth and young adult smoking rates, directly contrary to what a gateway hypothesis would predict. 11
We would suggest that this weight of real-world evidence warrants careful consideration before gateway concerns are used to justify prohibitive measures.
EVIDENCE FROM RESTRICTIVE REGULATORY ENVIRONMENTS
In Australia, following years of a highly restrictive prescription-only model, reforms introduced from 1 July 2024 confined vaping sales to pharmacies only, with significant restrictions on flavours, packaging, and purchase limits remaining in place. 12
In the Netherlands, a restrictive flavour ban introduced to address youth access concerns was followed by a doubling of youth vaping prevalence, from 3.7% to 7.6% over two years of implementation. The Netherlands' own National Institute for Public Health and Environment (RIVM) reported in a post-implementation review that 27% of those who ceased vaping as a result of the ban either increased their cigarette consumption or began smoking for the first time. These are material, documented public health harms arising from a precautionary intervention. 13,14
We raise these examples not to argue against appropriate regulation, but to illustrate that the design of regulatory measures matters considerably, and that overly restrictive approaches can produce outcomes at odds with their stated objectives.
CONCLUDING REMARKS
We respectfully urge the Commission to ensure that the forthcoming TPD revision draws on the full breadth of available evidence.
1. European Commission (2023) Special Eurobarometer 539 – Attitudes of Europeans towards tobacco and related products. Brussels: European Commission (Accessed: April 2026) [link]
2. Swedish Council for Information on Alcohol and Other Drugs (CAN) (2025) Tobacco use in Sweden 2025: National survey report. Stockholm: CAN (Accessed: April 2026) [link]
3. Eurostat (2024) Cancer statistics – specific cancers (Accessed: April 2026) [link]
4. Rodu, B. and Cole, P. (2009) 'Lung cancer mortality: comparing Sweden with other countries in the European Union', Scandinavian Journal of Public Health, 37(5), pp. 481–486 (Accessed: April 2026) [link]
5. Foulds, J., Ramström, L., Burke, M. and Fagerström, K. (2003) 'Effect of smokeless tobacco (snus) on smoking and public health in Sweden', Tobacco Control, 12(4), pp. 349–359 (Accessed: April 2026) [link]
6. Murkett, R., Rugh, M. and Ding, B. (2022) 'Nicotine products relative risk assessment: an updated systematic review and meta-analysis' [version 2], F1000Research, 9, 1225 (Accessed: April 2026) [link]
7. Perez-Cornago, A., Sarasa-Renedo, A., Jarach, C., Wollgast, J. and Maragkoudakis, P. (2026) Health outcomes associated with the use of e-cigarettes, heated tobacco products, and nicotine pouches. Luxembourg: Publications Office of the European Union (Accessed: April 2026) [link]
8. Lindson, N., Butler, A.R., McRobbie, H., Bullen, C., Hajek, P., Begh, R. et al. (2024) 'Electronic cigarettes for smoking cessation', Cochrane Database of Systematic Reviews, 1(1), CD010216 (Accessed: April 2026) [link]
9. NHS (2024) Using e-cigarettes to stop smoking (Accessed: April 2026) [link]
10. New Zealand Ministry of Health (2025) New Zealand Health Survey – smoking and vaping statistics (Accessed: April 2026) [link]
11. Mendelsohn, C.P. and Hall, W. (2023) 'What are the harms of vaping in young people who have never smoked?', International Journal of Drug Policy, 117, 104064 (Accessed: April 2026) [link]
12. Australian Government Department of Health and Aged Care (2024) Changes to vaping in Australia from 1 July 2024 (Accessed: April 2026) [link]
13. Statistics Netherlands (CBS) (2024) Leefstijl; persoonskenmerken. StatLine database (Accessed: April 2026) [link]
14. Hellmich, I.M. et al. (2025) A comprehensive evaluation of an e-cigarette flavor ban on consumer behavior and purchasing [Poster]. RIVM (Accessed: April 2026) [link]