regulering smaakjes e-sigaret

Reactie

Vraag1

For the intended restriction of flavours, the protection of youth is almost exclusively cited as an argument. It is claimed that fruity flavours or those that are based on popular sweets and desserts would primarily address children and adolescents and tempt them to consume them.

Apart from the fact that despite the variety of flavours currently available on the market, only very few young people use mobile liquid vaporisers and most of them only try them out for a short period of time anyway, a restriction would be an excessive encroachment on the personal freedom of every responsible adult consumer.

In numerous studies, adult users of mobile liquid vaporisers were found to prefer fruity and/or sweet liquids in the vast majority of cases and the successful switch was largely dependent on the variety of flavours. Thus, it can be stated that the success of e-vaping in terms of smoking cessation and tobacco harm reduction depends on maintaining the variety of flavours. Restricting the flavours would jeopardise this success and, moreover, would be disproportionate to the intended goal of protecting minors.

A restriction on flavours is a not insignificant encroachment on fundamental rights to achieve a goal that can also be realised in another way. The legal requirements for this are already met by the existing legal provisions, which comply with Recital 21 of Directive 2014/40/EU in conjunction with Recommendation 2003/54/EC through § 10.
The protection of minors is already comprehensively guaranteed, so that an aroma restriction for this purpose is obsolete. It is the duty of the state to enforce compliance with the legally regulated protection of minors instead of circumventing enforcement by a restriction that is predominantly at the expense of adult and autonomous consumers.

The Interessengemeinschaft ExRaucher pleads for the unrestricted preservation of the variety of flavours in liquids for mobile liquid vaporisers ("refill liquids for e-cigarettes").

Interessengemeinschaft ExRaucher is a non-commercial, independent consumer organisation advocating e-vaping and Tobacco Harm Reduction. https://ig.exraucher.org

Bijlage