European Tobacco Harm Reduction Advocates
ETHRA
European Tobacco Harm Reduction Advocates promotes discussion and the exchange of information and potential actions to reduce exposure to tobacco-related harm.
ID: 354946837243-73
Lobbying Activity
Response to EU cardiovascular health plan
16 Sept 2025
Our submission is on behalf of the European Tobacco Harm Reduction Advocates (ETHRA). ETHRA is the voice of 27 million EU consumers of safer nicotine products (SNPs). The safer nicotine products we use include vapes, nicotine pouches, snus, and heated tobacco products. ETHRA is a consortium of 24 grassroots consumer associations in 17 European countries, supported by experts in tobacco control and nicotine research. We are a voluntary operation with no industry funding or conflicts of interest. Our transparency registration number is 354946837243-73. Focus policy on reducing tobacco smoking. Our focus is on the cardiovascular implications of tobacco and nicotine use. Our submission is focused on the cardiovascular (CVD) risks arising from smoking and the potential positive role of nicotine-containing smoke-free alternatives to smoking. We believe that most actions related to CVD (e.g., diet, exercise, and medical practice) should be undertaken at the member state level, and that the European Union does not have a strong mandate to address most of the behavioural and metabolic risks and remedies for CVD. The EU does, however, play a substantial role in tobacco and nicotine policy through the Tobacco Products Directive, the Tobacco Advertising Directive, the Tobacco Excise Directive, and the Council Recommendation on Smoke-Free Environments. It is essential, therefore, that its approach to tobacco and nicotine is grounded in sound science. Unfortunately, this is not currently the case. The CVD risks arise primarily from smoking tobacco. Smoking is a significant modifiable risk factor for ischemic heart disease and stroke. According to the Global Burden of Disease (GBD) study, 156,444 CVD deaths were attributable to smoking and secondhand smoke exposure in the European Union in 2021. These deaths equate to 29.5% of the 529,826 smoking-attributable deaths and 9.5% of the 1,654,602 CVD-attributable deaths in the EU in 2021. Smoking is not the most significant behavioural risk factor at the population level (compared to diet), but for individuals who smoke, it is their most critical and modifiable risk factor. Please see the attached file for our full submission.
Read full responseResponse to Revised recommendation on smoke-free environments
19 Jul 2022
European Tobacco Harm Reduction Advocates (ETHRA) is the voice of 27 million EU consumers of safer nicotine products. ETHRA is a consortium of 25 grassroots consumer associations in 17 European countries, supported by experts in tobacco control and nicotine research. We are a voluntary operation with no industry funding or conflicts of interest. Our transparency registration number is 354946837243-73.
This document is our response to the call for evidence regarding the initiative smoke-free environments - updated recommendation.
We will confine our comments to the use of non-combustible Safer Nicotine Products (SNPs), such as vapes and Heated Tobacco Products rather than combustible products, such as cigarettes and pipes.
The purpose of the Recommendation on smoke-free environments (2009/C 296/02) is to protect people in the EU from exposure to second-hand smoke, as well as to encourage current smokers to quit. The intention to extend this recommendation to Safer Nicotine Products is not based on science and is counterproductive to public health, as we explain in the nine points below.
1. The scientific basis for updating this recommendation is flawed
2. There are key differences between secondhand smoke and secondhand vape exposure, which policy makers should take into account.
3. With no credible evidence to show that vaping presents a material risk to bystanders, the decision on whether to permit it should rest with property owners.
4. Banning the use of safer alternatives to smoking in public spaces will increase smoking.
5. Banning the use of products which people know to be safer will damage trust in public health.
6. Eurobarometer data does not support the claim that SNPs appeal in particular to young people.
7. Enforcement would add a financial burden to member states and risk criminalising people for bettering their own health.
8. The evaluation study does not consider the economic impact on the vape sector or the impact on quitting rates
9. Consumers are omitted from the targeted stakeholder consultation
Read full responseMeeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and Philip Morris International Inc. and
18 May 2022 · Videoconference - Stakeholder event to gather views on the upcoming revision of the tobacco taxation directive
Response to Tobacco taxation – revision of EU rules
15 Dec 2020
ETHRA is a group of 22 consumer organisations in 16 European countries, representing approximately 27 million consumers across Europe. We are mostly ex-smokers who have used safer nicotine products (SNP), such as vaping products, heated tobacco, nicotine pouches and snus, to quit smoking, remain smoke free, and vastly improve our health. Combustion is the main cause of harm from smoking. SNP carries a significantly lower risk to health as no combustion is involved. This distinction in relative risk must be reflected in any decisions on taxation. People switching from high-risk deadly combustible products to very low risk SNP should be incentivised, not punished. It is imperative that consumers are consulted throughout the evaluation of the Tobacco Tax Directive.
Read full response