Tobacco Europe and its members constructively participated in the Open Public Consultation (OPC) on the revision of the TPD and TAD Directives that concluded on August 14.
As the 12-week window to submit responses has come to an end, Tobacco Europe expresses its concerns regarding the upcoming legislative proposal. Firstly, the way the OPC was designed limits its capacity to generate clear, neutral, balanced, and decision-relevant evidence, as well as to enable meaningful stakeholder participation. The survey suffered from various methodological issues, including leading questions and framing that limited our ability to provide precise responses. The European Commission’s platform itself also experienced technical glitches, with questions appearing and disappearing, stakeholders not receiving confirmation emails, and other related issues.
Importantly, given the tight timeframe in which the file is progressing, with a draft expected by the end of the year, we are concerned that our responses may not be adequately taken into consideration by the European Commission. In our view, it will be materially impossible for the relevant DGs to fully assess all the evidence submitted by the numerous stakeholders who responded to the consultation in such short period.
Considering these shortcomings, we therefore call on the European Commission to invite us to a targeted stakeholder consultation, allowing us to present more comprehensive data and substantive evidence on tobacco, nicotine, and non-nicotine products.
