Papers & Letters: 2021

The divide in public health – are we trying to abolish nicotine?

December 2021: Global
Magazine Article
My article in Tobacco Reporter explores the fundamental divide in public health between those seeking a ‘nicotine-free society’ and those seeking to transform the market for the legal recreational drug nicotine.

Amicus briefs filed in litigation against the FDA

November 2021- February 2022: United States
Legal Filing
Seven briefs filed in US Federal appellate courts in cases challenging FDA’s regulation of vaping products. Briefs by me, David Abrams and David Sweanor. The briefs challenge FDA’s reasoning regarding flavoured vaping products.

Controversies over tobacco harm reduction – a briefing

November 2021: Philippines
I provided a briefing addressing eight controversial statements in advance of the Senate discussion of the Philippines Vaporized Nicotine Products Regulation Act. The briefing is here: Responses to statements in the Philippines’ debate on nicotine vaping and heated tobacco products

100 experts write to WHO demanding a change of direction

October 2021: WHO / Global
Letter from 100 specialists in tobacco science, policy and practice – regarding tobacco harm reduction and WHO.

What should ‘sustainability’ mean for the tobacco industry?

September 2021: Global
Magazine Article
For the Long Haul: Sustainability, strategy and survival in the tobacco market. My take in Tobacco Reporter on the long-run concerns that should be front of mind for tobacco companies.

Arguments against banning flavours

August 2021: Canada
Consultation Response
Response to Health Canada consultation on banning flavoured e-cigarettes.

Why EVALI was not caused by nicotine vaping

July 2021: United States / Global
Academic Paper
The outbreak of lung injuries often known as “EVALI” was nothing to do with nicotine vaping.

Shaping the EU Tobacco Excise Directive

June 2021: European Union
Consultation Response
With my input, European Tobacco Harm Reduction Advocates (ETHRA) submitted to the European Union’s public consultation on updated rules for tobacco taxation, which aimed to harmonise taxation to include safer nicotine products.

Interview on harm reduction and risk communication

June 2021: United States
The main change in the United States will come as the Food and Drug Administration approves more vaping, heated tobacco and other smoke-free products as “appropriate to the protection of public health”. We should hope that this will re-establish the competitive pressure against the cigarette trade and restore the confidence of consumers that has been lost through misinformation about risks.

Policy proposals to meet England’s smoke-free 2030 goal

May 2021: United Kingdom / England
Policy proposals to meet England’s 2030 Smoke-free goal. In my capacity as Public Health Adviser to the consumer group, the New Nicotine Alliance (NNA), I helped draft a set of policy proposals to meet the government’s goal of reaching ‘Smoke-free” status (

Meeting England’s 2030 smoke-free goal

May 2021: United Kingdom / England
Consultation Response
Response to the All-Party Parliamentary Group on Vaping – Achieving a smoke-free 2030 inquiry.

WHO’s rogue campaign against tobacco harm reduction

May 2021: WHO / Global
Response to WHO for World No Tobacco Day 2021.

Expert statements on tobacco harm reduction

May 2021: WHO / global
Expert statements on tobacco harm reduction World No Tobacco Day 2021. Wide-ranging comments on tobacco harm reduction and WHO. Comments on vaping and tobacco harm reduction from expert stakeholders.

The future of vape retailing

April 2021: United Kingdom
Discussion of future of vaping and battles ahead mainly from the retail perspective with Tom Gockelen-Kozlowski: Clive Bates interview: Fighting for vape’s good name

Why the ban on snus makes no sense if we are trying to beat cancer

April 2021: European Union
Snus Forum interview on Europe’s Beating Cancer Plan. It is absurd to use a plan supposedly aimed at “beating cancer” to protect the cigarette trade.

The arguments against restricting nicotine strengths

March 2021: Canada
Consultation Response
Canada’s proposal to limit e-liquid strengths to 20mg/ml will do more harm than good and has no supporting evidence. Canada’s proposal and regulatory impact analysis.

Response to UK consultation on regulation

February 2021: United Kingdom
Consultation Response
My brief response to UK consultation on the regulations implementing the Tobacco Products Directive. See my response here – a PDF print-out of my responses to the online consultation.

What is wrong with the WHO Framework Convention on Tobacco Control?

February 2021: WHO / Global
Response to UK All-Party Parliamentary Group inquiry into The Framework Convention on Tobacco Control and Conference of the Parties (COP)

Arguments against a flavour ban

January 2021: Netherlands
Consultation Response
Response to Dutch consultation on proposed e-cigarette flavour ban and other anti-vaping measures.
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