Regeling reguleren smaken e-sigaret
Reactie
Naam
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Counterfactual Consulting (Mr Clive Bates)
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Plaats
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London
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Datum
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26 september 2022
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Vraag1
Wat vindt u van de concept regeling?
The proposed “whitelist” approach to ingredients will amount to an almost complete ban on commercially viable vaping products. It will assist the continued dominance of the cigarette.
The impact on public health depends on how current users and future potential users will respond to the measure. The government cannot just assume they will become abstinent. Simply removing one appealing aspect of one product category does not address the deeper drivers of nicotine, tobacco or substance use. So, the likely responses will be to switch to other forms of nicotine use, including smoking, or other forms of substance use. Alternatively, users may try to secure the same vaping experience by other means. They can do this by using food or aromatherapy flavours, buying illicitly manufactured flavoured products, importing flavoured products from outside the Netherlands, or creating homemade flavours for personal use or selling to family and friends. Each of these options is worse than the status quo. There is no credible assessment of how these pathways will play out. If there were, it would show that even minor increases in smoking would destroy any conceivable health justification for this intervention.
The proposal is unworkable and should not proceed.
To add further weight to this argument, I have included a detailed submission from January 2021 made by twenty-four experts in tobacco and nicotine policy opposing outright or effective bans on flavoured tobacco products. The analysis remains valid, and subsequent data will if anything, strengthen the conclusion.
Bijlage