IEVA would like to express its concerns regarding the Dutch ministerial decree Amending the Tobacco and Smoking Products Order, presented by the Ministry of Public Health, Welfare and Sports.
According to the statement of grounds submitted by the Ministry, the decree intends to “extend existing tobacco product rules to heated tobacco products” in accordance with the Delegated Directive (EU) 2022/2100 amending the Tobacco Product Directive (TPD) of 2014.
The statement also states that the Ministry takes the opportunity to “clarify the implementation of Article 7 (6) of the Tobacco Products Directive”, by applying Article 7 (6) to electronic vapour liquids (e-liquids). The Ministry publishes a list of additives including substances that they claim facilitate the uptake of nicotine, such as TRPM8 receptor agonists.
IEVA is concerned by this ministerial decree, which effectively bans e-liquids by forbidding the use of essential and indispensable substances for their production.
IEVA believes that the extension of the additive list, originally targeting heated tobacco products (HTP), to e-liquids, runs several risks:
- The effective ban of e-liquids in the Dutch market will lead to a boom in black market activities with dangerous, non–compliant products
- It will lead to a rise in smoking rates
- It will put at risk tens of thousands of jobs and would lead to a reduction in government revenues by reducing tax collection
Overall, IEVA respectfully calls on the Ministry of Public Health, Welfare and Sports to refrain from extending the prohibited additive list to e-liquids as it is and to re-examine it in the light of the information we provide in this contribution.
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