Just received this sensible declaration from e-cigarette businesses, which I understand has just been sent to MEPs, in advance of the ENVI discussion today. In my view it is more constructive and credible than the one sent by TVECA on Monday.
Update: the premier American trade association, Smoke Free Alternative Trade Association (SFATA), representing 64 American-based and international companies have made their views clear via a statement circulated to MEPs. It’s a good assessment of the issues.
Joint Declaration of the E-cigarette Industry – the Regulation of E-cigarettes under the Tobacco Products Directive
Changes made to Article 18 in trilogue arguably render it a new Directive and we note public health advocates of e-cigarettes and consumer groups are proposing that the European Commission should recommence the process and start a new consultation process on Article 18.
For the European e-cigarette industry, the specific problem issues within the current text are:
- Nicotine limits – as the key scientists in the field of tobacco and e-cigarettes have identified in their 16 January 2014 declaration (attached), a 20mg/ml nicotine content is proven as insufficient for smokers using e-cigarettes as a substitute for cigarettes
- Advertising ban – preventing consumers from finding out about products products recognised as safer than cigarettes and the industry from informing them in a responsible manner
- Pharmaceutical style product standards – requirements for consistent dosing (same puff always delivers the same amount of nicotine), pharmacokinetic testing, leak free refilling and post-market pharmacovigilance – which appear to be copied from medicinal regulation and are not achievable for the majority of existing products
- Refillables – provision to extend ban across EU if three Member States apply a ban
- National Governments’ ability to ban cross border sales and maintain status quo to classify e-cigarettes as medicinal products
As a responsible industry, we remain committed to constructive engagement with the European Commission and Parliament to correct these issues in a mutually satisfactory manner. While a swift adoption of the TPD is regarded as an imperative, as an industry we believe it’s critical to have appropriate and proportional regulation and policy implementation capable of realising the public health benefits offered by e-cigarettes as a safer alternative to cigarettes.
We believe most of the above issues can be addressed by the prompt adoption of agreed Industry Standards (to ensure standards of product quality & safety) and an Advertising Code (to ensure all advertising is responsible and targeted only at smokers) – both of which are being progressed by the industry and are close to being finalised.
Electronic cigarettes Ltd
Gower Enterprises Ltd
House of Liquid
JAC Vapour Ltd
Liberro (UK) Limited
Mirage Cigarettes Ltd
Nome Dell Azienda
ROK Premium Electronic Cigarettes
SMOKO Premium Electronic Cigarettes
The Electronic Cigarette Company
Victory Electronic Cigarettes Corp
VIP Electronic Cigarettes
VT Wholesale Ltd
The organisers of this declaration are open to additional signatories from e-cigarette companies (meaning manufacturers and importers – I don’t think this one is aimed at retailers). If your firm is interested, the organisers can be contacted via this form.
[contact-form to=’[email protected]’ subject=’Signing the joint declaration of e-cigarette companies’][contact-field label=’Your name’ type=’name’ required=’1’/][contact-field label=’Your company name’ type=’text’ required=’1’/][contact-field label=’Your position’ type=’text’ required=’1’/][contact-field label=’Email’ type=’email’ required=’1’/][contact-field label=’Website’ type=’url’/][contact-field label=’Request to sign declaration – email will be sent to the organisers’ type=’textarea’ required=’1’/][/contact-form]