Submission on the Revision of the Tobacco Taxation Directive 

Executive Summary

The revision of the T obacco T axation Directive (2011/64/EU) presents a decisive moment for the future of harm reduction in Europe.

While we support the Commission’s goal of reducing smoking rates and promoting public health, expanding the scope of this Directive to include smoke-free, tobacco-free products such as nicotine pouches would be a grave mistake.

Taxation should reflect risk, not nicotine content.

Nicotine pouches are non-combustible, tobacco-free, and carry 99.9% lower health risks than cigarettes. Penalizing these products with tobacco-style excise duties would:

● Make quitting more expensive, discouraging smokers from switching;

● Create economic incentives for illicit markets; and

● Undermine the EU’s own Beating Cancer Plan and harm reduction commitments.

The Swedish experience shows that rational taxation and availability of oral nicotine products lead to record-low smoking rates, 5.6%, the lowest in the EU and 44% fewer tobacco-related deaths than the European average.

Europe should follow that model, not tax it out of existence.