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ECCA Response to Cancer Research UK
Caerulea Offline

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ECCA Response to Cancer Research UK
This is a preliminary response from ECCA UK (the Electronic Cigarette Consumer Association UK) to the article from Cancer Research UK. A fuller response to the issues raised by the University of Stirling research paper may be released in due course.

In 1969, in the face of sustained anti-smoking pressure, an internal tobacco industry document proposed a way forward. It stated:

"…Doubt is our product since it is the best means of competing with the "body of fact” … It is also the means of establishing a controversy…”i

Fast forward forty four years and “doubt” is once again front and centre. This time, however, it is electronic cigarettes in the firing line and it is the Tobacco Control movement nurturing the doubt.

Phrases like “we don’t yet know enough”, “are they really safer?”, “not regulated” and “there are still unanswered questions” generate doubt. Couple them with emotive phrases about “protecting children”, “tobacco epidemic” and “gateway” products and you have a powerful mix that resonates with journalists, governments and the public, and provides an excuse for taking strong action against electronic cigarettes.

There is NO doubt that electronic cigarettes are safer than traditional cigarettes – The report itself states that

“…it is generally accepted that e-cigarettes are less hazardous
and toxic than traditional cigarettes…”

and that

“…the harm associated with cigarette smoking is almost entirely caused by the toxins and carcinogens found in tobacco smoke…”ii

There is NO doubt that electronic cigarettes are regulated – The full body of EU consumer and safety legislation applicable to electronic cigarettes has
been listed by the MEPs Christian Engström, Chris Davies, Christofer Fjellner and Rebecca Taylor in their proposed amendments to the Tobacco Products Directiveiii

There is NO doubt that electronic cigarettes are not medicine – reflected by decisions in four courts in the EU who have all ruled against decisions by national medicines agencies to attempt to reclassify them as such.

There is also NO doubt that, for millions of people across the world, electronic cigarettes provide an effective alternative to smoking traditional cigarettes.
Yes, there are still unanswered questions. Electronic cigarettes are, after all, still in their infancy. ECCA UK is under no illusion that the safety of these products needs to be ensured and that the quality of the liquid used within them needs to be safe and pure. However, we strongly dispute that
these outcomes can only be achieved via the route of pharmaceutical legislation.

The strategy documented in Beyond Smoking Kills, a report funded by Cancer Research UK and the British Heart Foundation, published by Action on Smoking and Health and endorsed by more than 100 organisations said that the aim of any regulation for products like electronic cigarettes must be to improve their “…acceptability, attractiveness and accessibility…”. iv

Appropriate regulation is unlikely to be achieved if it is left in the hands of the MHRA whose interests are closely tied to the pharmaceutical companies and whose funding is derived from fees for regulating products. This approach is no more acceptable than inviting the tobacco industry to regulate.

ECCA UK must reject any call for regulation that cannot emphatically and unequivocally demonstrate that it

“…improve[s] the acceptability, attractiveness and accessibility…”

of electronic cigarettes.

The Centre for Tobacco Control Research at The University of Stirling state that one of their aims is to:

“…Evaluate specific tobacco control policies and identify those that successfully change smoking behaviour…”v

ECCA UK suggest that it may have been of far more value had The University of Stirling been asked to evaluate the current “Do Nothing” control policy. There has been a successful change in the smoking behaviour of an estimated one million Britonsvi who have adopted electronic cigarettes in preference to tobacco with no input whatsoever from Tobacco Control. The cost to the nation for this was zero. It is a pity, particularly given the poor quality of some of the papers referenced in Stirling's report that little effort seems to have been made to establish the perspective of current users.

Such a research agenda may have provided an answer to the key question for Tobacco Control that sadly remains unanswered in the report:

“…How would NCPs be used if regulated, and how would this compare to use prior to regulation?...”

ECCA UK believe that, at core, CRUK share our aims of ensuring that the consumer is provided with a safe and effective product, together with unbiased information regarding relative risks, and we are happy to co-operate with any organisation with such aims.

However, we also believe that serious conflicts of interest would be created by leaving any regulation to the MHRA - an organisation closely involved with the pharmaceutical industry that is funded by the very regulation it promotes.


It was sent to CRUK when the report was first published (PA to Jean King) back on 3rd June. As noted above, the aim was to pop it onto our website and then release details but given the challenges we've had with it, that's not been possible.

We have since had a reply, that simply acknowledges receipt and says that they "look forward to receiving the fuller response to the issues raised in the paper" - that is in progress and aim to have it out the door by the end of the week.

19/06/13 10:11 AM
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