Tobacco and Vapes Bill

Written Evidence by Submitted Richard Crosby, UK Director of Considerate Pouchers to the Tobacco and Vapes Public Bill Committee (TVB26).

Introduction I am writing as the UK Director of Considerate Pouchers , an organisation dedicated to promoting harm reduction through nicotine pouches. Our focus is on reducing smoking-related harm while ensuring consumer safety and fostering innovation in the nicotine product market. With extensive experience analysing regulatory changes, I am uniquely positioned to provide insights into the implications of the Tobacco and Vapes Bill.

This Bill represents a significant opportunity to advance public health goals by creating a smoke-free generation. However, it is crucial to balance these objectives with measures that ensure accessibility and affordability for adult smokers seeking less harmful alternatives.

Opportunities in Harm Reduction Nicotine pouches, included under the definition of 'nicotine products' in the Bill, offer a valuable tool for harm reduction. Sweden’s example highlights their potential: smoking prevalence is at 5.6%, the lowest in Europe, largely due to the widespread use of snus and similar products ( Public Health Agency of Sweden ). This has resulted in some of the lowest tobacco-related mortality rates globally.

In the UK, where smoking prevalence is approximately 13.3% ( ONS ), nicotine pouches can build on the success of vaping and further reduce harm. Their discreet nature, lack of combustion, and harm reduction potential make them a vital tool in achieving a smoke-free UK.

Concerns About Over-Regulation While proposals such as age restrictions, vending machine bans, and retail licensing are positive steps, over-regulation risks limiting adult access to reduced-risk products. For example:

· Affordability and Accessibility: High regulatory costs could increase product prices, disproportionately affecting low-income smokers seeking alternatives.

· Promotion Restrictions: Banning free samples and heavy discounts may reduce consumer awareness. Responsible promotion is essential to inform smokers of safer alternatives and encourage their transition.

Flavour restrictions also warrant careful consideration. Evidence suggests that access to diverse flavours increases the appeal of reduced-risk products and aids smoking cessation. For instance, a systematic review in Nicotine & Tobacco Research found higher quit rates among users of non-tobacco, non-menthol flavoured products ( Oxford Academic ). Marketing guidelines, as seen in Sweden, can prevent appeal to minors while preserving harm reduction benefits for adults.

Recommendations

1. Proportionate Regulation: Ensure measures like licensing and promotion restrictions are implemented to protect consumers without stifling accessibility or innovation.

2. Flavour Availability: Allow a wide range of flavours for adult use while enforcing strict marketing standards to avoid appeal to minors.

3. Supportive Framework: Foster an environment encouraging competition and innovation, similar to Sweden’s model, to maximise public health benefits.

Conclusion The Public Bill Committee’s call for evidence is an essential opportunity to shape a regulatory framework that protects consumers, promotes harm reduction, and fosters industry innovation. I would welcome the opportunity to provide additional insights or oral evidence to support this important discussion.

Sincerely,

Richard Crosby 
UK Director, Considerate Pouchers

Sources

1. Public Health Agency of Sweden. "Sweden achieves the lowest smoking prevalence in Europe, 5.6%, through snus and harm reduction." Link .

2. Office for National Statistics. "UK smoking prevalence stands at 13.3%." Link .

3. Harm Reduction Journal. "The potential of new nicotine and tobacco products as tools for cessation." Link .

4. Oxford Academic. "Associations Between E-cigarette Use and E-cigarette Flavours With Quit Success." Link .

December 2024