Executive Summary
Considerate Pouchers welcomes the opportunity to comment on Israel’s proposed excise duty on nicotine pouches but urges the government to reconsider the planned rate of NIS 349.18/kg (approximately €100/kg). While supporting the objectives of protecting public health and ensuring sustainable revenues, the organisation argues that the proposed tax is disproportionate and was introduced without the kind of dedicated market review conducted for electronic cigarettes. It warns that setting such a high rate without assessing consumer behaviour, market size, and risks of illicit trade could undermine both fiscal and public health goals.
The response also argues that Israel’s proposal is significantly higher than international benchmarks. Many European countries apply lower, differentiated tax rates to smoke-free nicotine products, recognising their lower risk profile compared to cigarettes. The EU is reportedly moving toward a minimum rate closer to €30/kg, while countries such as Sweden have demonstrated that proportionate regulation of smoke-free alternatives can contribute to major reductions in smoking prevalence.
Finally, Considerate Pouchers cautions that excessive taxation risks repeating Israel’s experience with electronic cigarettes, where high excise rates contributed to the growth of illicit markets and weak tax collection. A similarly restrictive approach to nicotine pouches could drive consumers toward unregulated products and discourage smokers from switching away from combustible cigarettes. The organisation therefore recommends a dedicated market review, alignment with emerging EU benchmarks, differentiated taxation for smoke-free products, and enforcement measures that support a regulated legal market.
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