Nicotineproducten zonder tabak

Reactie

Vraag1

1. As the director of the Institute for Addiction Research at the University of Applied Sciences Frankfurt/ Main I fully support efforts to reduce the number of smokers. Evidence tells us that we need to use all available options to reduce smoking and smoking related harm. Insisting on appealing smokers to quit and banning nicotine products will certainly not lead to a reduction of smoking prevalence to 5% .
2. The consultation document is vaguely describing e-cigarettes, tobacco heating products and nicotine pouches as “alternative to traditional tobacco products”. I think this description is missing the point. The raison d’etre for these products are to offer an alternative for smokers which cannot or will not quit. (Stöver 2021) The underlying concept is the risk continuum which has been create by Nutt et al (2014) and Abrams et al (2018) to demonstrate the different risk profiles of nicotine products. To date there is scientific consensus that when conventional cigarettes respresent 100% of the harm alternative nicotine products are on the lower end of the scale with heating products at around 10%, e-cigarettes at around 5% and nicotine pouches together with nicotine gums at circa 2%. The absence of a combustion process takes out the vast majority of the risk factors of smoking. For nicotine pouches the German Institute for Risk Assessment has explicitly confirmed this characterization (BfR 2021 & 22).
3. The risk continuum and the approach to offer alternative nicotine products to smokers is not just a theoretical approach. Sweden has a long tradition of Snus usage. Snus is used similarly to nicotine pouches, though it still contains tobacco. Despite a similar nicotine usage prevalence than other countries in the European Union “Sweden has record low smoking in the EU among men and Sweden also has record low tobacco attributable mortality. There is likely a causal effect so that the snus displacement of smoking among the men is the reason for the low tobacco attributable mortality.” (KF, 203)
4. Therefor I would strongly recommend that the Netherlands find a way to offer all available alternatives including nicotine pouches to the Dutch smokers to achieve a significant reduction in smoking reduced harm and smoking prevalence.
Literature:
- Nutt et al: https://doi.org/10.1159/000360220
- Abrams et al: https://doi.org/10.1146/annurev-publhealth-040617-013849
- BfR 2021 (attached)
- BfR 2022: https://doi.org/10.17590/20220204-105615