Consultation response on Tobacco products and tobacco advertising – revision of EU rules

Executive summary

Considerate Pouchers welcomes the opportunity to contribute the consumer perspective to the revision of the Tobacco Products Directive. Adult access to nicotine pouches should be protected through proportionate, product-specific EU regulation, especially as divergent national rules have already created serious problems. France’s 2025 ban shows how adults who switched away from cigarettes can lose legal access while cigarettes remain widely available.

Nicotine pouches should not be treated like cigarettes. They contain no tobacco leaf, involve no combustion, and offer adult smokers a smoke-free alternative. Sweden’s daily smoking rate of 3.7 percent shows how legal access to lower-risk nicotine products can support major reductions in smoking.

EU rules should focus on strict youth protection, including a harmonised 18+ age limit, while avoiding measures that amount to prohibition. Blanket flavour bans and nicotine caps below 20 mg per pouch would make switching less attractive, risk relapse to smoking, and push consumers toward unregulated online and cross-border markets.