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?