Tobacco Harm Reduction: A Need for Balance
Introduction
The concept of Tobacco Harm Reduction (THR) aims to mitigate the adverse health effects associated with continued smoking by encouraging adult smokers, who would otherwise continue to smoke, to switch completely to reduced-risk*† alternatives[8]. We continue to demonstrate our commitment to THR through the development, scientific assessment and commercialisation of a multi-category portfolio of Smokeless Products. We recognise, however, that important stakeholders, for example The Royal College of Physicians[8], are critical of the genuineness of our THR efforts.
Stakeholder Perceptions
Our critics suggest that we manipulate the concept of THR by portraying our Smokeless Products as safer than smoking without sufficient long-term evidence. Critics also argue that our portfolio transformation is driven purely by profit motives and is aimed at misleading adult consumers about the risks associated with our Smokeless Products. Our critics have also raised concerns that our strategies target the underaged and adult never smokers, potentially creating new generations of nicotine consumers[8].
Commitment to Innovation and Tobacco Harm Reduction
We maintain that our THR efforts are genuine. As an initial point, we are very clear that Smokeless Products are not risk-free. Moreover, we are also clear that our Smokeless Products are intended for adult smokers and existing nicotine consumers only.
Through development of our portfolio of Smokeless Products, we have invested significant resources into THR. This investment has resulted in Smokeless Products being more acceptable to adult consumers and commercially sustainable. Our engagement with regulators and policy makers on THR is underpinned by our open and transparent regulatory positions. In the UK, we have advocated for more extensive regulation of e-cigarettes and other Smokeless Products[9]. We seek to engage with public health authorities and regulators, to help develop policies that balance THR objectives with concerns about underage access, environmental impacts and consumer safety. These partnerships can lead to more effective and comprehensive THR strategies.
Supporting Scientific Research
Our research into Smokeless Products and THR strategies is fundamental for complying with global regulations and has contributed valuable data to the scientific community. Mindful of concerns about bias, our studies follow standardised regulatory endorsed methodologies where those exist, comply with requisite quality standards and practices (e.g. Good Laboratory Practice and Good Clinical Practice), and where possible are conducted in third party Contract Research Organisations. We seek transparency and scientific integrity of our findings and as such we publish our science, which undergoes rigorous peer review, and participate at global scientific conferences.
Absolute Risk vs Relative Risk
We are clear that many of our Smokeless Products have not been on the market long enough to fully assess the long-term impacts of their use. Some stakeholders maintain that this absence of long-term data means that Smokeless Products have no role to play in THR. For example, the EU’s Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) issued an opinion in April 2021 focusing on the potential absolute risk of e-cigarettes[10]. While the SCHEER report reviewed the evidence for an association between a number of risks and e-cigarettes use, classifying the evidence base for each risk as “strong”, “moderate”, or “weak”, it did not compare the level of these risks to the well documented risks associated with combustible cigarettes. We believe that this relative perspective is crucial for THR, as the primary goal is to reduce tobacco-related morbidity and mortality for those who would otherwise continue smoking.
Numerous other public health authorities similarly focus on the absolute risks of Smokeless Products compared to cigarettes. These authorities argue that because Smokeless Products are not risk-free, they should not be promoted as part of THR strategies. Such arguments overlook the significant reduction in risk when comparing these alternatives to traditional smoking. For example, studies highlighting the potential carcinogenic or cardiovascular risks of Smokeless Products tend to ignore the actual and substantial risks posed by combustible tobacco products. We believe that this narrow focus on absolute risk fails to acknowledge the public health benefits of switching to Smokeless Products for adult smokers, who would otherwise continue to smoke.
Relative Risk at the Core of THR
The essence of THR lies in the relative risks between cigarettes and Smokeless Products. Our Smokeless Products are not risk-free, but the key is that, based on the weight of evidence, they are less risky*† than combustible cigarettes. This reduction in relative risks underscores the potential of Smokeless Products as effective tools in THR. Indeed, in numerous markets that have embraced THR, the introduction of Smokeless Products has been associated with further declines in smoking prevalence. This highlights that when properly regulated, Smokeless Products can support rather than undermine public health efforts.
Conclusion
We accept that our role in the THR discussion is complex. What is clear, however, is that we have the resources and capabilities to significantly contribute to THR efforts. By investing in new products, supporting regulatory frameworks, and funding research, we can play a positive role in reducing tobacco-related harm. A balanced approach that provides all stakeholders (including BAT) with a seat at the table and which includes strong regulation, transparency, and accountability is essential to ensure that THR regulation genuinely benefits public health.
Footnotes
* Based on the weight of evidence and assuming a complete switch from cigarette smoking. These products are not risk free and are addictive.
† Products sold in the U.S., including Vuse, Velo, Grizzly, Kodiak, and Camel Snus, are subject to FDA regulation and no reduced risk claims will be made as to these products without agency clearance.
References
A full list of references for this page can be found in the section 11. References.
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