Something is rotten in the (Tobacco Control) state of Sweden

Sweden is set to sabotage global efforts at Tobacco Harm Reduction by ELEVATING health warnings on snus, despite no evidence to support this. By senselessly following the EU TPD2 to the letter, even though there is no legal requirement to do so as snus has a derogation from the EU TPD2.

At the same time and in the same law:

Sweden is set to protect flavors and flavor information on snus to Swedish and Norwegian consumers, in violation of the EU TPD with reference to a derogation from legal requirement to follow EU TPD2 on snus.

Friday December 6th 2015 the government (The council of ministers make collective decisions by the way) published a proposal on legal implementation of the EU Tobacco Products Directive in to Swedish law before the dead-line on May 16th 2016.

In a Bizarre twist, tucked away in more mundane texts on smoking, is a quite real recommendation to RAISE the level of health warning on Swedish “snus” and this will imminently become law unless changed.

This is utterly bizarre and counterintuitive as “The Swedish Experience” with snus, so evidently and clearly shows “snus” to be part of the solution, not part of the problem.

Snus will, according to the new law, have it’s warning label ELEVATED from today’s warning. This will be enacted despite overwhelming evidence suggesting an even more moderated warning, a warning that actually promotes switching from cigarettes to snus, if quitting entirely seems too difficult (which seems to be the case for the majority of smokers).

The warning will be changed from “may cause harm” (which is an overstatement already) to “causes harm” (Which is a totally outrageous and erroneous overstatement and quite quite deadly). This will happen  without any further shred of remotely credible evidence having been presented, compared to the evidence already present when the EU ruled in 2001 that the current warning was quite sufficient.

Make no mistake about this: This new law on snus will have exactly ZERO effect here in Sweden where ZERO people die from using snus. It will however have devastating effects for the health of smokers and users of toxic smokeless formulations in THE 193 OTHER recognized countries in the world.

This will without any doubt seriously negatively affect some 1.3 BILLION tobacco using people who are not lucky enough to live in Sweden or Norway where snus is commonplace and the trivially low risk is a well known fact in the general population. 

Swedish Tobacco Control Science and Public Health bodies have had an extra full 14 years since 2001 to firmly establish harms from snus, had there been any.

In a report from 2014 by the NBHW (Swedish National Board of Health and Welfare) it is obvious that exactly ZERO such evidence has been found. Not in the 14 years and also not in the well studied entire century preceding 2001. In the entire period between 1901-2001 there is not one single clinical mention of serious adverse health from snus use whatsoever. None.

When the government in 2013 gave the order for this report to be prepared it was perfectly clear that both major tobacco products used in Sweden (cigarettes and snus with 49%/49% share of the total market) should be thoroughly reviewed and data presented. As there simply is no data do be found on serious harm from snus use, the NBHW simply changed the name of the report to imply that only smoking data was ever asked for.

The honest and scientifically correct reply from the NBHW would have been: With over 100 years of observation and a very thorough investigation in to the matter of snus, the actual serious harms found among the 1 million snus users in Sweden is so close to ZERO, that any residual harm cannot be meaningfully measured from a Public Health perspective.

 

There is also not one single mention of the word snus in Sweden’s most prominent medical journal between 1904-1995, but of course several hundred studies and articles on the devastating harms from smoking. In the very early 1900’s snus sales in Sweden was 7000 tons and again 7000 tons in the 2000’s. Serious harms from snus going unnoticed in a country like Sweden, for well over a century and with some +75  million user years, is simply not even a theoretical possibility.

The Rest of the Story:

The Government in Sweden instead intends to group practically harmless snus (totally banned in the rest of the EU) together with highly toxic Asian smokeless products like Khaini, Gutka, Pan-Masala, betel quid, areca nut and more (all allowed in the EU, in a further bizarre Brussels twist from a decade ago) and regulate them equally.

Peculiarly enough, and further adding to the bizarre and total lack of logical reasoning, flavor markings on snus and characterizing flavors in snus, will be allowed also in the future.

Specifically the EU TPD banning of flavor markings on tobacco products is with the intent of keeping all tobacco products as unattractive as possible to young people. In this respect however, Sweden instead chose to invoke the “unique status for self regulation” and derogation achieved in the EU accession that snus has, as legal grounds for keeping flavors and flavor markings.

I am baffled as to why Sweden did not chose the same legal route for the much more logical and Public Health safeguarding action, and keep the lower level warning? (or better: easing it in to a positive Tobacco Harm Reduction message, while warning young people, to avoid unintended uptake consequences)

It makes infinitely more sense for smokeless tobacco products like snus (that fill all the criteria in the Swedish Food Act), to keep the uniquely Swedish moderated warning labels. It would also make infinitely more sense to subject ONLY products NOT meeting these standards to the warning mandated in the EU Tobacco Products Directive. This would act to effectively help in directing tobacco users to the least harmful alternatives available, and informing on which is what.

This route of regulation is even more baffling due to this gloriously simple fact: The products in question will/would never be legally sold in the EU anyway. They are specifically and discriminatorily BANNED, period!

For a better and more comprehensive legal explanation to the discriminatory and product specific targeting of snus by the EU, please follow this link to open source book excerpt with an excellent analysis: Legal discussion

On a final note. What then, might the lead author of the world’s most comprehensive study on Smokeless Tobacco globally have to say on the matter of snus? Link to very comprehensive and globally recognized study:Global burden of disease due to smokeless tobacco consumption in adults: analysis of data from 113 countries By Dr Kamran Siddiqi, University of York et. al.

Please find quote from an email to me dated August 28th 2015, published with author Dr Kamran Siddiqi’s kind permission:

“I am also a supporter of harm reduction strategies in tobacco control. The challenge with smokeless tobacco is the spectrum. At one end (Swedish snus) is more or less harmless and can be used as harm reduction substitute while on the other hand the products used in Asia and Africa have very high TSNA and are extremely harmful.”

Dr Kamran Siddiqi

If the above is true (it is), then why would anyone who cares about health want consumers to believe that Food Grade Smokeless Tobacco (suns) is no better than cancer causing Asian and African products, and little better than continued smoking?

Tobacco Control Sweden, you know this, and yet you applaud this proposed new law for elevated warnings on snus, why?

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9 thoughts on “Something is rotten in the (Tobacco Control) state of Sweden

  1. gitchorama

    Thank you, Atakan, for this review. This certainly does sound troubling.

    You mention that this will go in to effect “imminently”–does this mean that there is no path to provide comments, seek to get it modified/changed, no appeal? Please forgive my ignorance of how this happens in Sweden.

    What can those of us outside of Sweden do?

    Thank you again for bringing this to the attention of people who care about tobacco and nicotine issues.

    Joe

    Reply
    1. befrits Post author

      Dear Mr Gitchell, Council on Legslation will check it for legality, and to some extent proof it for obvious fubars. Unless we can persuade the Council that the justification for elevating the warning is as scientifically sound and correct as banning morphine in the ER as a means to combat illegal heroin, I argue that it is a done deal. No politician remotely interested in getting re-elected will argue with otherwise sensible regulation on smoking, even with a trojan horse built in. I may be wrong. I hope I am wrong.

      Reply
      1. gitchorama

        Atakan – first of all, let me say that I suspect that gov’ts of all size should have a DPOF (Department for the Prevention of Obvious FUBARS)–I love it and Joseph Heller would be proud.

        Is the challenge that the Council can’t modify this proposal, it can only accept or reject it in its entirety? So your “poison pill/Trojan Horse” analogy is exactly right? Again, please forgive my ignorance (which, for the avoidance of doubt, is NOT limited to how the Government of Sweden works!).

        But here’s a crazy notion (as this sure seems like an unfortunate step on so many levels–science informing good public health policy at the top of the list): is there any reason not to ask for an audience at the Swedish Embassy (“House of Sweden” – http://www.houseofsweden.com/ – so darn cool and I’ll take just about any excuse to go and visit) to express dismay? To that point, can you send a link to the proposed regulation directly so I can properly refer to it?

        Thank you.

        Joe

  2. befrits Post author

    Joe – Excellent idea! The Legislative Council can definitely recommend the Government to change or remove certain parts of proposed legislation before sending it to Parliament. This would be the optimal route, getting them to criticize this part of the bill strongly with reference to insufficient evidence and possible resulting in unecessary harm to health with almost zero benefit. Also it would be interesting to see if there is any reaction to the simple fact that the proposed elevated warning will have almost ZERO effect in Sweden but in all likelihood have a great potential effect on the FDA for example (along with another 193 countries, most of which cannot afford to go without dirt-cheap and practically harmless food grade snus). With regards to this, please note that the experts involved in the preparation of the bill come from 2 Public Health Agencies who both wrote separately to the FDA and asked them to NOT accept the Swedish Match MRTPA. One of those letters is not on the docket because it was sent to the TPSAC, I have a copy of it though :), the other letter is on the docket. Please find enclosed link to the proposal sent from Government to the Legislative Council: http://www.regeringen.se/contentassets/5e5bfa005e774ecfb6d4f504def0bd4a/lagradsremiss-genomforandet-av-eus-tobaksdirektiv_webb.pdf

    Reply
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