Tobacco Facts supports the proposals put forward in the memorandum on taxation of highly concentrated e-liquids. However, we would also like to state that the taxation is insufficient to protect both public health and children. We believe that the exemption of e-liquids and other nicotine-containing products that have been destroyed from taxation is more in line with the needs of the Swedish Tax Agency than the importer's responsibility and possible tax liability for these goods.
The memorandum proposes that the exemption from taxation for acutely toxic products be limited so that it does not include e-liquids with a concentration between 15 and 20 milligrams of nicotine per milliliter of liquid. Such liquids are now referred to as “highly concentrated e-liquids” and should be taxed at SEK 4,000 per liter of liquid. It is also proposed that e-liquids or other nicotine-containing products that have been destroyed under the supervision of the Swedish Tax Agency be exempted from tax liability for approved warehousekeepers.
Generally
Price increases on tobacco products and e-cigarettes, including liquids, are, according to available research, the single most effective measure to discourage tobacco and e-cigarette use. In particular, price is important in discouraging tobacco and e-cigarette use among children and young people, but price is also important for adult consumers who want to reduce their consumption or completely stop using it. Strong public health reasons therefore argue for regular and substantial increases in tobacco and e-cigarette taxes. Even though the proposed increase is twice as high as that for other e-liquids, i.e. 4,000 SEK per liter, the increase must still be considered very moderate and result in negligible effects on public health. The price for a daily smoker's consumption is estimated to increase to between 11 and 14 SEK per day. In comparison, the price increase for e-liquids with a nicotine concentration of between 15–17 mg/ml is about half that, i.e. 2,000 SEK per liter, equivalent to 5–7 SEK per day.
As mentioned, price increases give many consumers an impulse to reduce or stop using tobacco, e-cigarettes and other nicotine products for pleasure. However, since nicotine is highly addictive, such impulses often only have a short-term effect, and consumers become accustomed to the new price level. However, the possibility of successfully quitting tobacco and nicotine increases with each new attempt. Against this background, it is important not only that the price is increased, but also that the price increases occur repeatedly, at least every year. The pace of tax increases should be adjusted so that the price, as a minimum, keeps pace with inflation and the development of purchasing power. It is long-term real price increases that provide benefits for public health.
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Continued low prices for e-cigarettes, while Sweden has not so far banned fruit and candy flavors in e-cigarettes like many other countries, risks resulting in Sweden experiencing the same dramatic development in e-cigarette smoking as the USA, where 1 in 4 children now smoke e-cigarettes.
Tobacco Facts would once again like to regret that e-cigarettes did not continue to be completely banned after the Swedish Board of Administrative and Financial Supervision Authority's decision in 2016. Our view is based on the fact that e-cigarettes, like other nicotine products for pleasure, risk luring children and young people in particular into nicotine addiction, which in itself can pave the way for a later transition to traditional cigarettes.
From a public health perspective, the tax on e-cigarettes should also be as much as possible equal to that on other tobacco products. The harmful effects of smoking are more pronounced, but the Tobacco Control Convention is clear – the goal is to reduce all tobacco use and nicotine use for pleasure.
Finally:
Tobacco Facts assumes that the commercial interests surrounding the continued spread of the harmful and sometimes deadly e-cigarettes and other tobacco products will express completely different opinions than Tobacco Facts. This is especially true since we note that among the consultation bodies, in addition to the authorities, public health representatives only amount to two organizations: Tobacco Facts and NSG. The tobacco and nicotine industry's activities, including their allies, amount to at least 6 times more in number with the sole purpose of selling as many products harmful to health as possible. Price and tax increases threaten their activities and sales. In the continued processing of this matter, we therefore assume that these interests will have no influence whatsoever on the final design of the proposals, since their products would hardly have been allowed for sale if the products had been regulated like any other consumer product. Article 5.3 of the WHO FCTC, which Sweden ratified in 2005, also clearly states that such economic interests should be prevented from influencing public health policy as far as possible because they are completely incompatible with the interests of public health. It follows from this that we are seriously concerned that the Riksdag, government and authorities have hardly implemented the FCTC's recommendations to keep the tobacco and nicotine industry's influence on public health policy, including public consultation processes, at all.
