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Experts’ Critique of The EU Scientific Committee Preliminary Opinion on E-Cigarettes

In preparation for the 2021 revision of the European Union Tobacco Products Directive (TPD), the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) has posted its “Preliminary opinion on e-cigarettes.” A paper published on Harm Reduction Journal presented a critique of this opinion.

Diane Caruana

March 22, 2021

“The Opinion omitted reporting on the individual and population health benefits of the substitution of ENDS for cigarette smoking. Alternative hypotheses to the gateway theory were not evaluated.”

The SCHEER’s “Preliminary Opinion on Electronic Cigarettes” concluded that e-cigarettes only achieve a sub-optimal level of protection of human health. A paper by renowned tobacco harm reduction expert Dr. Riccardo Polosa and his team at the Center of Excellence for the Acceleration of Harm Reduction (CoEHAR), analysed and critiqued the SCHEER’s arguments.

They presented evidence that the Commitee’s “conclusions are not adequately backed up by scientific evidence and did not discuss the potential health benefits of using alternative combustion-free nicotine-containing products as substitute for tobacco cigarettes.”

Polosa and his team looked for articles in PubMed and Google Scholar, and articles were also retrieved with a review of references in major publications. Moreover, primary data from World Health Organization (WHO) surveys, conclusions from reviews, and peer-reviewed independent studies, were cited to address the errors and omissions identified in the Opinion.

The health benefits of using e-cigarettes were ignored

The research team found that the SCHEER failed to consider studies indicating the individual and population health benefits of using e-cigarettes (ENDS) as safer alternatives and also ignored alternative hypotheses to the gateway theory. “The Opinion omitted reporting on the individual and population health benefits of the substitution of ENDS for cigarette smoking. Alternative hypotheses to the gateway theory were not evaluated.”

The CoEHAR team sadly identified other patterns of inaccurate reporting. “Its assessment of cardiovascular risk is contradicted by numerous reviews. It cites ever-use data that do not represent current patterns of use. It did not report non-nicotine use. It presented erroneous statements on trends in ENDS prevalence. It over-emphasized the role of flavours in youth ENDS initiation. It did not discuss cessation in sufficient length.”

Factors the SCHEER needs to consider

To this effect, concluded Polosa and his team, there are a number of factors that the SCHEER need to consider in order to deliver an accurate report. “For the delivery of a robust and comprehensive final report, the members of the Working Group of the Scientific Committee on Health, Environmental and Emerging Risks will need to consider (1) the potential health benefits of ENDS substitution for cigarette smoking, (2) alternative hypotheses and contradictory studies on the gateway effect, (3) its assessment of cardiovascular risk, (4) the measurements of frequency of use, (5) non-nicotine use, (6) the role of flavours, and (7) a fulsome discussion of cessation.”