Open Letter to the EU Commission
13th Oct 2023
It is important that the EU-commission addresses all aspects of the nicotine harm-reducing alternatives in the upcoming legislative proposition on tobacco control. The European Commission’s Inter-Service Group (ISG) has been established, and a first draft of the upcoming tobacco control framework will soon be completed.
What is crucial is that this process is conducted with transparency and is evidence-based, considering the proposal’s implications across various sectors and supply chains. The e-commerce Haypp Group is concerned about that certain aspects of the process may be altered in the final report. What Haypp wishes the Commission to consider in the final report is nicotine pouches, as they have not received specific attention, particularly from an e-commerce perspective.
Haypp Group’s Head of external affairs, Markus Lindblad, writes in an open letter to EU Commissioner Didier Reynders that transparency and openness are essential for the new tobacco directive:
Subject: DG JUST’s involvement in the Evaluation of the legislative framework for tobacco control – Upcoming Inter-Service Consultation (ISC)
Dear Commissioner Didier Reynders,
My name is Markus Lindblad, and I am writing to you on behalf of Haypp Group.
The Haypp Group spearheads the global transformation from smoking to healthier product alternatives. With origins in Scandinavia, extensive experience from pioneering markets in smoke-free alternatives, and being a leader in the e-commerce sector, Haypp Group is taking the vision of inspiring healthier enjoyment for millions to a global scale. With ten e-commerce brands, the Haypp Group is present in seven countries, where we served more than 790,000 active consumers in 2022.
It is our understanding that the European Commission is currently evaluating the legislative framework for tobacco and related products. According to the DG SANTE Management Plan 2023, the Commission aimed to finalise its evaluation report in Q3-Q4 2023.
In line with the Commission’s internal decision-making rules, we understand that the interservice group (ISG) has been launched, and the draft evaluation report will then be subject to an interservice consultation (ISC).
We believe it is of utmost importance that this process is conducted transparent and evidence-based, considering the impacts across sectors and supply chains and including all relevant actors. To this end, we recently participated in an open public consultation. However, we remain concerned that certain aspects of this process may compromise the final reports’ impartiality. Reasons why we recently raised our concerns to the EU Ombudsman as some questions appeared particularly unbalanced and the form was not adapted to the wide range of products in the nicotine field.
In the context of this evaluation, we would especially like to highlight the importance of considering e-commerce aspects. An increased number of products are being sold online, and it is critical that these products are also safe for consumers and comply with applicable rules. These aspects should be considered, especially in relation to coherence with other legislation governing online sales. There is also the need to ensure the general coherence of the EU single market, especially in relation to the safety of consumer products, and these aspects should not be left out of the evaluation.
For the reasons stated above, we ask if the Directorate General JUST is actively taking part in the ongoing interservice group.
We would also like to encourage the Directorate General JUST to actively participate in the interservice consultation on the evaluation report. We sincerely believe that your expertise and insight on the aspects related to e-commerce and consumer safety would be critical to ensure a balanced report that entirely considers all perspectives to the file while also serving its purpose of adequately evaluating the impacts of the EU’s current legislative framework.
We remain at your disposal should you want to discuss this matter.
Head of Legal & External Affairs
Haypp Group AB (publ)