Scientific errors in the Tobacco Products Directive concerning e-cigarettes

A dialogue between scientists and the European Union

Few days ago, leading researchers on tobacco and e-cigarettes from all over the world gathered together and prepared a letter to Health Commissioner Borg and other relevant parties concerning e-cigarette regulation, emphasizing the mistakes made in the regulation. As you may have seen, our letter was backed by extensive scientific evidence supporting all our arguments. Our letter was featured in the journal “New Scientist”. The European Commission replied to us through Mr Seychell (the Deputy Director General for Consumers and Health).

His response can be found here (pdf file)

Instead of making any personal comments judging their response, I will let anyone decide by himself on the integrity and validity of the arguments from each side. Below is our reply to Mr Seychell, once again signed by the same distinguished scientists in the field of tobacco and e-cigarette research.


January 31, 2014

Dear Mr. Seychell

We do appreciate your response to our letter, and we thank you for your quick reply.

However, we do not think that our concerns were addressed. The legislation remains based on misunderstood or misinterpreted evidence and imposes restrictions which are not justifiable. A legislation that regulates e-cigarettes in a more restrictive way than tobacco cigarettes that are much more harmful by any standard of measurement will be damaging for public health.

We accept your clarification about the consistent dosing as concerning nicotine content in vapour rather than nicotine delivery to users as the wording implies. The wording could be made clearer.

Considering the rest of your response, this ignores our arguments that the statements concerning nicotine toxicity, nicotine threshold and use by non-smokers or adolescents, which form the basis of the proposed restrictions, are not substantiated by evidence and are therefore inappropriate.

You state that 'electronic cigarettes with such a nicotine threshold or below help the vast majority of smokers' and 'already today we see that their consumption is no longer limited to established smokers' but there is no evidence for these assertions that we are aware of.

As it stands, the proposed legislation is aiming to prevent negligible and mostly imaginary dangers while threatening to undermine much more likely and much more substantial benefits.

Yours sincerely,


As per your request, please find below the CoI of the signatories.

Professor Jean-François Etter, PhD
Institut de santé globale, Faculté de médecine, Université de Genève, Switzerland.
I was reimbursed by an e-cigarette manufacturer for travels to London and to China, but was not paid for these talks.

Dr. Konstantinos Farsalinos, MD
Researcher, Onassis Cardiac Surgery Center, Athens, Greece
Researcher, University Hospital Gathuisberg, Leuven, Belgium.
I have no financial interests in any e-cigarette company. Some of my studies were performed using funds provided to the institution by e-cigarette companies. My salary is paid by a scholarship grant from the Hellenic Society of Cardiology.

Professor Peter Hajek, PhD
Wolfson Institute of Preventive Medicine, Barts and The London School of Medicine and Dentistry Queen Mary University of London, London, UK.
I have no links with any e-cigarette companies.

Dr. Jacques Le Houezec, PhD
Consultant in Public Health, Tobacco dependence, Rennes, France
& Honorary Lecturer, UK Centre for Tobacco Control Studies, University of Nottingham, UK.
I have received no financial support from e-cigarette companies, nor received any other significant benefit (e.g. travel etc).

Dr. Hayden McRobbie, MB ChB PhD
Reader in Public Health Interventions, Wolfson Institute of Preventive Medicine, Queen Mary University of London, UK.
I have received no personal financial or non-financial support from any companies for research on e-cigarettes. PGM International provided products at no cost for the public-good funded ASCEND e-cigarette trial and I have undertaken research on Ruyan e-cigarettes, for which the University of Auckland was funded by Health New Zealand, independently of Ruyan.

Professor Chris Bullen, MBChB, PhD
Director, The National Institute for Health Innovation, The University of Auckland, Auckland, New Zealand.
I have received no personal financial or non-financial support from any companies for research on e-cigarettes. PGM International provided products at no cost for the public-good funded ASCEND e-cigarette trial and I have undertaken research on Ruyan e-cigarettes, for which the University of Auckland was funded by Health New Zealand, independently of Ruyan.

Professor Lynn T. Kozlowski, PhD
Dean, School of Public Health and Health Professions, Professor of Community Health and Health Behavior, University at Buffalo, State University of New York, USA.
I have not undertaken research, provided consulting or received funding/travel support from electronic cigarettes companies.

Dr. Mitchell Nides, PhD
President, Los Angeles Clinical Trials, Director, Picture Quitting, the Entertainment Industry's, Quit Smoking Program, Burbank, CA 91505, USA.
I have received research funding from NJOY Inc, Scottsdale, AZ.

Professor Dimitris Kouretas, MD
Professor and Deputy Rector University of Thessaly, Greece.
The University of Thessaly signed a research proposal between University and The Greek Chamber of e-cigarettes importers to test the toxicity of the liquids that are sold in the Greek market. I have not received money from any e-cigarette company.

Professor Riccardo Polosa, MD, PhD
Director of the Institute for Internal Medicine and Clinical Immunology, University of Catania, Italy.
I have been serving as a consultant for Arbi Group Srl (Milano, Italy), the Italian distributor for 'Categoria' e-Cigarettes.

Dr. Karl Fagerström, PhD
President, Fagerström Consulting AB, Vaxholm, Sweden.
I have no links with any e-cigarette companies.

Professor Martin Jarvis, Dsc
Emeritus Professsor of Health Psychology, Department of Epidemiology & Public Health, University College London, UK.
I have no financial links with any electronic cigarette company, and have not consulted for or received travel support or research resources from any such company.

Dr. Lynne E. Dawkins, PhD
Senior Lecturer in Psychology, School of Psychology, University of East London, Stratford, London, UK.
I have no personal financial or non-financial interests in the e-cigarette industry. My university (University of East London, UEL) has received funding from Skycig Ltd for a research project that I co-ordinated as well as travel funds and hospitality from Totally Wicked and E-Lites.

Dr. Pasquale Caponnetto, Assistant Professor, Researcher
Centro per la Prevenzione e Cura del Tabagismo, Azienda Ospedaliero-Universitaria “Policlinico-V. Emanuele”, Università di Catania, Catania, Italy.
I declare no conflict of interest.

Professor Jonathan Foulds PhD
Professor of Public Health Sciences & Psychiatry, Penn State University, College of Medicine, Cancer Institute, Cancer Control Program, Hershey, PA 17033-0850, USA.
I have not received any financial compensation of any kind from an electronic cigarette company, nor received any other significant benefit (e.g. travel etc).





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0 #8 Pasquale 2014-06-05 04:58
I will discuss the steps to remove the smoking mechanism in future articles.
In the United States alone there are about 46 million today and
there are many more people who have quit
smoking in the United States. If you start at zero, you cannot jump to one hundred per cent.
0 #7 Dr Farsalinos 2014-03-14 19:39
Due to spam messages, the comments will be reviewed by the webmaster before being published.
Therefore, there may be some delay between making the post and becoming visible.
Sorry for this.
0 #6 Adam Hill 2014-03-14 19:21
I think the rappators need to declare their conflict too especually where Big P is involved
and who is this Guy is he a scientist who has done research like the scientists who signed this letter and have the experience to talk truthfully
+2 #5 Irish Lass 2014-02-10 01:25
It is a declared tactic of the anti-smoking fanatic brigade, whose declared intention is to rid the world of all smoking in any public place by whatever means, to challenge every study that gives results that are even marginally favourable to smoking by attacking the authors for having received funding from the tobacco industry. See

Now the same fanatics are using the same tactics against e-cigs. For shame! I find it hard to believe anything the "public health" brigade tell us any more and as for politicians? lazy? misguided? or just corrupt? I don't know. But they are NOT doing their jobs properly. They are supposed to be acting for the benefit of their people. Not creating harmful legislation behind closed doors.
+1 #4 Irish Lass 2014-02-10 01:16
The authors of anti-smoking studies, e.g. the recently published study into the alleged dangers of Third Hand Smoking (!!), have frequently failed to disclose conflicts of interest that are MUCH more serious than these . See

Yet, somehow, no-one ever challenges these authors. Hmmm. Wonder why!
+3 #3 Bill 2014-02-03 09:27
The EU Health Commission does not care about facts. Other than the crusaders, all they care about is protecting the profits of the cigarette and drug industries.

It has NOTHING to do with public health - about which they care little.
+4 #2 Paul Fowkes 2014-02-01 13:52
Good work.
I hope we are going to see similar statements of interests too from Mr Seychell and other EU parties involved...
+5 #1 R.C. 2014-02-01 09:28
Right answer!!!-thank you for that!
They have some nerve!!!
What do they think? Just saying something is enough to shut us all up, including the scientists? Where are the proofs what they are saying?...they are not obliged to deliver them?
How long can they ignore the truth? It gets already exhausting to talk to the mountains! Where/who is an authority who can force them to admit it, or deliver the proofs for their saying at last?
What/who are they...the All Mighty?

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