Key Points
- The EU Cardiovascular Health Plan consultation closed on September 17, 2025, receiving 677 submissions across the EU. A 2Firsts analysis found 161 explicitly mentioning tobacco or nicotine — making tobacco-related issues a key focus of public feedback.
- Feedback reveals a clear policy divide: public health organizations such as the WHO Regional Office for Europe and the World Heart Federation advocate strict control and uniform regulation for all nicotine products, while harm reduction advocates — including Konstantinos Farsalinos, Haypp Group, and VdeH — call for risk-based, evidence-driven regulation recognizing lower-risk alternatives.
- The final plan, expected to be adopted by the Directorate-General for Health and Food Safety (DG SANTE) in Q4 2025, may serve as a barometer for future EU regulatory debates, including the forthcoming Tobacco Products Directive III (TPD III).
2Firsts, October 7, 2025--Following its earlier special report “EU Cardiovascular Health Plan Consultation Sparks Debate on Regulation of Novel Tobacco Products”, 2Firsts has reviewed the complete feedback dataset published by the European Commission for the EU Cardiovascular Health Plan consultation, which closed on September 17, 2025.
According to the European Commission’s “Have Your Say” platform, the initiative received 677 public submissions.
Through a keyword-based review using “tobacco,” 2Firsts identified 161 entries directly referring to tobacco, nicotine, or harm reduction — representing approximately 23.8% of all feedback.
The analysis shows that tobacco-related topics became one of the most discussed aspects of the consultation, revealing a clear divide between advocates of complete nicotine cessation (abstinence) and those supporting a risk-proportionate harm reduction approach.
Broad Participation Across 27 Member States
Of the 677 submissions, NGOs accounted for 29.7%, followed by EU citizens (27.4%) and academic or research institutions (14.5%). Companies and business associations represented 6.7% and 5.5% respectively.
By geography, Belgium, Germany, Italy, Spain, and France ranked among the top five contributors, indicating broad engagement from Western Europe.
The plan, prepared by the Directorate-General for Health and Food Safety (DG SANTE), is expected to be adopted in the fourth quarter of 2025.
As a non-legislative Communication, the plan aims to strengthen cardiovascular health through prevention, early detection, and treatment — while fostering medical innovation and the competitiveness of Europe’s health sector.
Harm Reduction Advocates Call for Evidence-Based, Risk-Proportionate Regulation
Among the 161 tobacco-related submissions, several came from academics, industry associations, and physicians who urged the EU to recognize the harm-reduction potential of non-combustible products and regulate them according to their relative risk.
Greek cardiologist Konstantinos Farsalinos stated in his submission:
“Tobacco Harm Reduction (THR) offers a pragmatic, evidence-based pathway.”
Swedish company Haypp Group wrote in its feedback:
“Nicotine itself does not cause cardiovascular disease… The main risks come from toxic chemicals in tobacco smoke.”
Germany’s electronic cigarette association Verband des eZigarettenhandels (VdeH) emphasized in its submission:
“Harm reduction should be established as an equally important pillar alongside prevention and cessation.”
Argentine think tank We Are Innovation suggested:
“Tax products by CVD risk (cigarettes highest, oral tobacco-free lowest), following Sweden’s successful model.”
Public Health Organizations Urge Stricter and Unified Regulation
In contrast, public health and international organizations generally called for consistent regulation across all nicotine products, treating them within the same control framework as tobacco.
The World Heart Federation (Switzerland) stated in its submission:
“EU policies on electronic nicotine delivery systems should mirror tobacco regulation, including taxation.”
The WHO Regional Office for Europe (WHO/Europe) wrote:
“Tobacco causes 152,000 CVD deaths annually… Brief interventions are an effective tool for reducing tobacco and alcohol use.”
The Swedish Cancer Society (Cancerfonden) asserted:
“Use of all tobacco and nicotine products is linked to increased risk of ill-health.”
The Health Funds for a Smokefree Netherlands advocated:
“An EU-wide ban on e-cigarette flavours would make it far more difficult for young people to come into contact with these products.”
Policy Dynamics: A Barometer Ahead of TPD III
Although the EU Cardiovascular Health Plan is a non-legislative initiative, many observers believe that its “prevention” section — if it references nicotine or harm reduction — could influence the forthcoming revision of the Tobacco Products Directive III (TPD III).
The European Commission is expected to release the final text by the end of 2025.
Based on publicly available feedback, participants are divided over the future direction of public-health policy: some support complete nicotine cessation (abstinence), while others favor risk-based harm reduction.
TPD III has not yet been formally proposed and is unlikely to enter the legislative process before 2026.
If nicotine-related language is strengthened in the final Cardiovascular Health Plan, it could later be referenced by member states in national or EU-level regulatory debates.
Conclusion
The consultation results highlight that nicotine and harm reduction have become central to Europe’s public-health conversation.
While public-health groups emphasize strict control and uniform regulation, scientific and industry contributors advocate evidence-based harm-reduction strategies.
This divergence is likely to shape discussions around the forthcoming TPD III and related EU policy frameworks.
2Firsts will continue to monitor the release of the final plan and its potential implications for both policymakers and the nicotine industry.
Data Note
This report is based on publicly available data from the European Commission’s EU Cardiovascular Health Plan consultation.
2Firsts identified a subset of 161 submissions containing the keyword “tobacco” to analyze discussions relating to nicotine, smoking, and harm reduction.
Minor limitations may arise due to translation inconsistencies or incomplete metadata.
This article summarizes public feedback for informational purposes and does not represent the views of the European Commission or any contributors.
Readers are encouraged to verify details directly via the official EU “Have Your Say” website.
The cover image was generated by ChatGPT.
