UEMO Proposal for a position Revision of the Tobacco Directive

05/07/2013 Policy2 2175 Views

UEMO – the European Union of General Practitioners / Family Physicians – is the organisation of European medical associations representing general practitioners and family physicians. UEMO gathers today twenty six member countries represented by their respective national medical association and/or by their most representative association of General Practitioners.

The promotion of the best standards in public health, able to meet the needs and expectations of European citizens, stands out as the main mission for each and every European general practitioner and family physician.

Promoting tobacco consumption prevention and improving citizens’ information on its dangers is to this extent a crucial issue for the UEMO.

Manufacture, presentation and sale of tobacco products are currently regulated by Directive 2001/37/EC from June 2001. Due to scientific, market and health developments in more than 10 years, the Commission has issued a proposal to revise this directive on December 2012. The Council reached a compromise on 21 June 2013, while the ENVI Committee of the European Parliament will vote on its report and the related amendments on 10 July 2013, for a plenary scheduled on 8 October 2013.

The UEMO regrets the considerable downgrading of primary ambitions for this Directive, a move based on economic concerns that would lead to damages on European citizens’ health and long-term health systems’ financial resources.

The UEMO wishes therefore to express its position for an ambitious revision of the current Tobacco Products Directive (TPD).

1.     Reducing tobacco’s attractiveness to young people

  • Toward “plain packaging” for all tobacco products

While the Commission envisaged last year to propose the introduction of “plain packaging”, as in Australia, today’s Council position is that packet should only be warning covered on 65{cabf78295431282ca1bec49ffbe2c87b89a1285ae102b2d0687184fc21af24ba} of their surface – from 75{cabf78295431282ca1bec49ffbe2c87b89a1285ae102b2d0687184fc21af24ba} in the Commission’s proposal.

As stated in the WHO’s Framework Convention on Tobacco Control (FCTC) guidelines, plain packaging should be adopted[1]. As shown in the TPD Revision Impact Assessment, a large majority of European citizens support the introduction of large health warnings and pictures[2].

Moreover, to avoid misunderstanding and belief that some other tobacco products are less dangerous, all tobacco products should be labelled in a similar and homogenous way as far as health warnings are concerned. This means eliminating all exemptions, applying for instance to smokeless tobacco products, pipe, cigars, etc.


Therefore, the UEMO supports the introduction of plain packaging for all tobacco products with the highest possible coverage.

  • Banning flavourings and special ingredients on all tobacco products

Recent developments in institutional talks tend to diminish Commission’s first proposal by authorizing “slim” cigarettes, insisting on the need to allow “product differentiation”, reducing restrictions on flavouring.

Such position is not compatible with the Directive’s ambitions to reduce the attractiveness of tobacco for vulnerable publics, including young people. Tobacco products of any category should not include any elements that are misleading consumers as to their lethal nature.

The UEMO strongly opposes any differentiation between different tobacco products for the banning of flavouring which should be equally imposed on all products.


2.     Banning distance sales

To ensure market is not fragmented and directive provisions cannot be passed by, distance sales of tobacco products should be banned, as stated in the WHO’s Framework Convention on Tobacco Control. Nine Member States have already enforced such a ban. Compliance to legal requirements, such as age requirement, advertising, as well as a facilitated access to tobacco may undermine tobacco control policy.

The UEMO supports the banning on distances sales.


3.     Vigilance over nicotine-containing products, including E-cigarettes

E-cigarettes are a new product, subject to very different regulations in Member States. Consensus is general on the need for better regulation, for such a recent product with largely unknown effects on health. However, debate is on whether they are a useful replacement product for existing smokers, simply a gateway for new smokers, or a way for smokers to getting nicotine in smoke-free areas.

The precautionary principle should apply when scientific evidence and experience are not sufficient to ensure a product is not harmful. On the other hand, electronic cigarettes have the potential to be used as an effective way as a medicinal tool for quitting tobacco. For doing so, it has to respect some principles which include composition (nicotine and flavours) and marketing (instructions for use should be provided, an age limit and restrictions on promotion set)..

The Commission’s proposal is therefore not satisfactory in differentiating between nicotine-containing products on the basis of nicotine level. Less nicotine would simply change the way of using e-cigarettes for smokers dependent to the substance, for instance through “compulsive smoking”.

The UEMO recommends a high vigilance over nicotine containing products including E-cigarettes for which a reduction of the nicotine threshold is necessary to guarantee that these products are correctly authorised on the market and monitored. A common protective approach at EU level would be a preferable solution than allowing different threshold at national level.




[1] “Parties should consider adopting plain packaging requirements to eliminate the effects of advertising and promotion on packaging”. (GL Article 13)

[2] According to a Eurobarometer of 2012, 76{cabf78295431282ca1bec49ffbe2c87b89a1285ae102b2d0687184fc21af24ba} of the EU population supports large pictorial warnings; and 57{cabf78295431282ca1bec49ffbe2c87b89a1285ae102b2d0687184fc21af24ba} support a ban on logos, colours and promotional elements on packs: http://to.ly/lRps

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