Submission to the consultation on nontobacco nicotine products for “oral use”, particularly pouches (portions, pouches, nic-pouches, non-tobacco snus, all white snus, etc.)

Stockholm, January 16th, 2023

Submission to the consultation for a further amendment to the Tobacco and Related Products Order
prohibiting all non tobacco nicotine products for “oral use”, particularly pouches (portions, pouches,
nic-pouches, non-tobacco snus, all white snus etc.)

INNCO is a global community of ex-smokers helping smokers quit and defending the rights of 115 million
adult People Who Use Safer Nicotine (PWUSN) to avoid toxic forms of tobacco. In our view, current
global efforts to prevent or discourage the 1.3 billion people who use toxic forms of tobacco from
seeking safer alternatives is a form of mass murder. Safer nicotine alternatives include TPD products
such as nicotine patches, nicotine gum, nicotine lozenges, prescription nicotine inhalers, nicotine vapes,
snus (inexplicably banned in the EU), nicotine pouches and HTPs. Because every smoker is different,
prohibiting any of these smoking cessation options is profoundly harmful to public health.
We note that the US Food and Drug Administration (FDA) has now authorized 8 snus, 2 HTP and 23
nicotine vape products as “appropriate for the protection of public health.” It now allows the maker of
those snus products to tell customers the truth: switching completely from smoking to this product will
lower your risk of cancer, heart and lung disease. By doing this, also the FDA has recognized and
legitimized tobacco harm reduction.

We understand that the Government of The Netherlands is now considering a proposal to prohibit one
of these safer nicotine alternatives: nicotine pouches. These are snus-like smokeless oral nicotine
products. Unlike snus, they do not contain tobacco. Only harmless cellulose, nicotine, and the
harm-free flavourings that are used in chewing gum. There is no biologically plausible reason to believe
that nicotine pouches are any more harmful than nicotine gum, which has been available in every
pharmacy in the Netherlands for decades now.

The stated reasons for this proposed prohibition include the remote possibility that some teens may use
them and/or subsequently turn to smoking combustible cigarettes at some time in the future. INNCO
believes strongly that teens should not use nicotine. But we note (a) there is no evidence snus is a
gateway to smoking, and (b) teen use of nicotine gum – which is, literally, a candy – is non-existent. Other
reasons for the proposed prohibition include false claims concerning nicotine, so let us clear those up

Nicotine patches and gum have been used by millions of smokers for more than three decades now.
Post-marketing surveillance in the US, UK and EU shows that these products do not cause cancer, heart
or lung disease (even in ex-smokers who continue to chew nicotine gum for decades). According to the
FDA, nicotine patches and gum are “not dependence-forming or subject to abuse.”
According to the WHO’s International Agency for Research on Cancer (IARC), and the US Centers for
Disease Control and Prevention (CDC) nicotine does not cause cancer. The CDC says “using a nicotine
medicine [e.g., nicotine patch or gum] is much less likely to cause heart disease than continued
smoking.” Finally, it should be obvious that products you don’t inhale will not cause emphysema or
chronic obstructive pulmonary disease.

Combustible tobacco cigarettes shorten the lives of 50% of lifelong smokers by 10 years. Of these
premature deaths, 36% are due to cancer (29% lung cancer); 36% due to cardiovascular disease including
stroke; and 21% due to lung disease, primarily Chronic Obstructive Pulmonary Disease.

We are aware that certain people and organizations are now making demonstrably false claims that
nicotine causes cancer, heart and lung disease. We urge the Government of The Netherlands to question
these wildly false claims and the motivations (and funding) of anyone who is making these claims.
The death toll from toxic forms of tobacco is horrendous. To reduce this death toll, people who use toxic
products must be encouraged to quit or switch to safer alternatives. To boost switch rates, these
alternatives must be appealing to smokers. And smokers need to be accurately informed of the relative
risks. Finally, the safer alternatives must be available. Prohibition obviously prevents that.
To save lives, safer nicotine alternatives must be Acceptable, Affordable and Available to people who use
toxic forms of tobacco. These “three ‘A’s” guide all efforts to ensure access to life-saving drugs and
vaccines in low-income countries. They should also guide all regulatory efforts to reduce the horrendous
toll of death and disease from smoking.

Finally, no policy decision affecting smokers or People Who Use Safer Nicotine (PWUSN) should be made
without first consulting with the people who will be affected by that policy. We are those people.
Smokers’ access to harm reduction alternatives is a human right, a social justice imperative and a
life-or-death policy issue.

INNCO wishes to thank the Government of The Netherlands for the opportunity to express our views on
this important public health policy proposal. We believe that prohibiting products that could save the
lives of tens of thousands of your citizens would be seen, by future health historians, as mass murder..