SPAIN CONSULTATION ON FLAVOURS BAN

Attention of: Ministry of Health, Spain

We are following with great interest the initiatives you are taking to reduce smoking in Spain, and we would like to contribute to the public consultation for the “Comprehensive Tobacco Prevention Plan 2024-2027”. In view of the new legislation with the aim to further reduce the smoking rates, we would like to bring the following to your attention.

SCOHRE is an International scientific Association of independent experts on Smoking Control & Harm Reduction, who seek an open and constructive dialogue to help come up with a new approach to smoking control policies. We believe that smoking cessation and smoking prevention is the primary goal of our societies, and that the adoption of harm reduction policies may be considered as the 3rd pillar for tobacco control together with smoking cessation and smoking prevention to secure to a healthier future particularly for the younger generations.

Despite all efforts for the implementation of the Framework Convention on Tobacco Control (FCTC), smoking is still a major public health issue; the number of smokers exceeds 1 billion; we count more than 8 million premature deaths every year from smoking-related diseases; the number of smokers is growing.

It is agreed that although nicotine is addictive, it only plays a minor role in smoking related mortality, and it has been successfully used as a medication in smoking control and smoking cessation. Smoking cessation and prevention remain the two most impactful and cost-effective interventions in medicine but have been unable to prevent the smoking epidemic. We believe that smoking control strategies should be reshaped to include harm reduction, and alternative lower risk products should be encouraged, besides the traditional smoking cessation and smoking prevention measures.

In an era of technological innovation, new approaches continuously emerge based on safer alternatives than cigarettes. For those smokers who for various reasons will not otherwise give up smoking completely, switching to less harmful products will have a tremendously positive effect. Novel tobacco products and Nicotine Delivery Systems such as electronic cigarettes, heated tobacco products and nicotine pouches could be considered as lower-risk alternative to smoking with mounting scientific evidence that shows reduced exposure to toxicants compared to smoking.

SCOHRE supports the restriction of child-friendly flavours, bright-coloured packaging or whatever makes these products attractive to youth. Candy flavours ban could be an acceptable alternative to protect youth appeal. Nonetheless, we believe that a universal flavours’ ban should be reconsidered. Flavours could help adult smokers to switch to vaping products, which are documented as lower risk products in comparison to cigarettes. By unconditionally banning all flavours, it will be harder for smokers in Spain to quit cigarettes and switch to lower risk vaping products. Spain has a large number of smokers (almost 20% of the population are daily smokers) and, comparatively, a small number of vapers (2,2% of adults vape regularly), and it appears that a switch of even a small proportion of smokers to vaping may considerably benefit public health.

Vaping is a stepping stone to quitting for many smokers. However, in the event that smoking cessation is not achieved, evidence shows reduced exposure to toxicants compared to smoking and consequently a benefit for our society.

Banning products that facilitate smoking cessation costs lives, including among the parents and grandparents of those youth people purport to care about. It also spurs illicit markets with all of the problems they cause. It will also make it more likely those youth will instead smoke cigarettes, be exposed to more second-hand smoke, be in households that are financially strained due to continued expenditures on cigarettes and be more likely to be subjected to cigarette cased fires.