Lack of consumer perspective in new nicotine regulations
15th Dec 2022
Iceland recently adopted new legislation regarding nicotine products. This new law includes regulations on marketing, licensing, and product requirements. While these regulations are generally welcomed, some parts of the regulation lack a consumer perspective. The European Union should not do the same mistake when revising its Tobacco Products Directive.
Notification requirements introduced
Under the new legislation, only nicotine products that meet safety standards and product safety criteria in Iceland will be allowed to be sold on the market. Manufacturers and importers of nicotine products who wish to sell their products must notify the authorities six months before marketing and must include toxicological data on the ingredients of the product. Selling or importing a product without prior notification is prohibited.
One of the most significant aspects of the new legislation is the introduction of an explicit nicotine limit. Nicotine products containing more than 20 mg/g of nicotine will not be permitted to be sold. Pouch Patrol welcomes such regulations under the condition that maximum limits are not set to low, which is not the case in Iceland. However, the maximum limit should be set per pouch rather than per gram to better reflect real-life consumption patterns and make it easier for consumers to compare different products and understand their nicotine intake.
In September, the German Federal Institute for Risk Assessment estimated that the nicotine concentration in the blood following 20 minutes of use of a pouch with 16.6 mg of nicotine was equivalent to the level found after smoking a cigarette. This could be seen as a reasonable nicotine limit per pouch.
Lack of consumer perspective
Overall, it is important for new regulations to be designed with the consumer in mind rather than solely from a government perspective. Officials may be able to easily calculate the nicotine dose per pouch, but consumers do not have the same access to this information. It is crucial that the EU takes into account the importance of the consumer perspective when revising its own Tobacco Products Directive.