At the beginning of April, the European Commission published its evaluation of the Tobacco Products Directive (TPD). Its core message is straightforward. The European framework has helped restrict advertising, raised awareness of health risks, and contributed to a reduction in smoking prevalence. At the same time, the decline across Europe remains rather gradual, and the Union is still far from the ambitious goal of reducing the share of smokers to five percent by 2040. Moreover, the market has changed fundamentally over the past fifteen years. Alongside conventional cigarettes, we now see products such as e-cigarettes, heated tobacco products, and nicotine pouches. The Commission is undoubtedly right about this. The rules from 2014 no longer adequately reflect today’s reality.
All the more surprising, then, that even after more than ten years, the evaluation itself fails to answer the key question: What actually worked and contributed to the reduction in smoking prevalence, and why?
The Commission itself acknowledges that it is unable to quantitatively isolate the impact of European legislation from other factors, such as tax policy, national regulation, smoking bans in various settings, or changes in consumer behaviour. In other words, we know the situation has changed, but our understanding of why remains limited. And that is a problem, not merely a methodological footnote. In practice, it means that European regulation may be shaped without a clear picture of which instruments actually work and which do not.
It is therefore important to examine more closely the differences among individual member states. Those differences are significant. Yet they remain largely on the margins of the evaluation.
The Czech experience is instructive in this regard, as it offers a sober, non-ideological perspective. According to the National Survey on Tobacco and Alcohol Use in the Czech Republic 2024, the share of traditional tobacco product smokers declined from 31.3% in 2012 to 22.4% in 2024. That is a more pronounced decline than the European average. It does not automatically mean that any single instrument or policy is responsible. It does mean, however, that the Czech case warrants deeper analysis, particularly given that domestic addiction strategies have long operated with the concept of harm reduction and the assumption that both regulation and taxation levels should correspond to the degree of harm posed by individual products.
Equally instructive are the experiences from Sweden. Sweden has long been among the countries with the lowest smoking rates in the European Union, along with significantly lower mortality rates from oncological and cardiovascular diseases. In Sweden, these changes resulted from a shift in consumer preferences towards smokeless tobacco, specifically snus. Yes, tobacco policy differs between member states. And precisely these differences would merit a deeper and more systematic analysis than the current evaluation provides.
As noted above, instruments other than product regulation also play a significant role, as the data themselves demonstrate. Tax policy, for instance, has long been regarded as one of the most effective factors influencing tobacco consumption. European legislation is therefore only one part of a broader picture, not the sole explanation.
This is an elementary principle of modern public health policy. Between a cigarette and a nicotine pouch, between combustible tobacco and a smokeless product, between a long-term smoker and a young adult, there are differences that regulation should be able to distinguish. Indeed, there is consensus in the expert community that the use of alternative products is associated with lower health risks compared to conventional smoking. Acceptance of scientific evidence should be reflected in policy decision-making. That is what a rigorous, evidence-based approach should look like. It is a pity that in this respect, the report is more than reticent.
The European evaluation report is strong, as it highlights real problems, marketing, fragmentation of national rules, and regulatory gaps concerning new products. It is weaker where it moves too quickly from these findings to an implicit assumption that more restriction automatically yields better outcomes. We know that in public health, it does not work that simply.
This is evidenced, moreover, by the ongoing expert debate. Respected figures from both the international and Czech scientific communities have, in recent months, openly drawn attention to the limitations of current risk communication at the European level. In an open letter addressed to European Commission President Ursula von der Leyen, experts call for regulation to more consistently distinguish between individual types of nicotine products and to be grounded in the scientific assessment of their risks. Even if this does not represent the unanimous view of the expert community, it certainly reflects an effort to advance a relevant, substantively grounded debate that it would be prudent not to overlook in the preparation of new legislation.
The TPD revision will therefore serve as a test of whether the European Union is capable of making evidence-based policy rather than assumption-based policy. The objective should be less smoking, fewer diseases, and fewer deaths, not more prohibitions on paper. If the new European regulation is to hold up, it must above all be analytically and empirically rigorous. It is also necessary to acknowledge uncertainties, account for differences in risk levels, and learn more from the real-world experiences of member states. The Czech debate in the field of addiction demonstrates that such an approach is possible. It would be a shame if Europe failed to draw inspiration from it.
Author: Dr Ladislav Csémy, President, Institute for the Mental Health and Addiction Studies, and psychologist working in the addiction research programme at the National Institute of Mental Health