The European Cancer Organisation (ECO) has responded to the European Commission’s public consultation on the revision of the Tobacco Products Directive (TPD) and Tobacco Advertising Directive (TAD), calling for EU rules that are both stronger and built to last.
The response builds on ECO's recommendations in its earlier contribution to the Commission’s Call for Evidence on this file, and has been developed in line with guidance from the Smoke Free Partnership.
The revision comes at a critical moment for European tobacco control: the existing framework has not kept pace with changing markets, consumption patterns, and digital marketing practices, most notably the rapid growth and diversity of novel tobacco and nicotine products. Their uptake, particularly among young people, risks sustaining tobacco and nicotine addiction in yet another generation. Adolescents who use e-cigarettes are almost 4 times more likely to eventually use tobacco cigarettes.1 This undermines the goal of Europe’s Beating Cancer Plan of a tobacco-free generation by 2040.
With Europe facing a major burden from tobacco-related cancers, EU legislation must protect new generations not only from cigarettes, but from the wider market of addictive tobacco and nicotine products.
As outlined in ECO’s response, the revision of the TPD and TAD must:
Products currently outside the scope of the legislation, as well as all future products, must be brought within the EU regulatory framework. ECO supports the use of technology-neutral definitions and a regulatory mechanism allowing the European Commission to respond quickly to scientific, technical and market developments. Such measures can help avoid a situation in which new products exploit regulatory gaps simply because they did not exist when legislation was originally drafted.
ECO supports prohibiting flavoured e-cigarettes and nicotine pouches, and restricting flavour descriptions and imagery, product appearance and other design features that can make nicotine products more attractive. Instead, health warnings, plain or standardised packaging, and prohibiting misleading elements that encourage consumption are all valuable measures.
In addition, the response supports limits on nicotine concentration and dose, stronger ingredient requirements, mandatory child-resistant packaging, and a ban on disposable e-cigarettes, as well as EU action addressing digital promotion of tobacco and nicotine products by both corporate and individual actors.
These measures will be particularly important to curb the appeal that flavours, packaging, product design, and digital promotion may have, especially for younger generations.
The legislation should also support cessation, including through the use of leaflets carrying quitting information.
Finally, the revision offers an opportunity to establish stricter, more harmonised rules across member states. ECO supports EU-wide plain packaging requirements, an EU-wide prohibition of flavours in e-cigarettes and nicotine pouches, and the extension of traceability requirements beyond tobacco products.
The revision of the TPD and TAD represents an important opportunity to ensure that EU tobacco control legislation is equipped to respond to today’s market and societal needs, while remaining adaptable to future products and marketing practices.
Stronger action on tobacco and nicotine products is an essential part of Europe’s cancer prevention agenda, helping reduce avoidable cancer cases and protect younger generations from the harmful effects of tobacco and nicotine products. ECO therefore calls for the revision to place public health and the protection of younger generations at its centre.
Learn more about the ECO’s position on tobacco legislation here.