Subject: Proposed amendments to the Tobacco Act - JDM/26-0826
From: "Ethra Ethra" <[email-masked]>
To: "Justiits- ja Digiministeerium" <[email-masked]>
Date: Mon, 27 Jul 2026 18:08:18 +0300

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear Liisa-Ly Pakosta, Minister of Justice and Digital Affairs,

ETHRA welcomes Estonia’s objective of preventing youth use of adult products 
and supports proportionate product safety rules and clear enforcement 
against supply to minors. However, several core provisions of the draft 
would also make low-risk alternatives to smoking less acceptable, less 
available or practically unusable for adults who smoke. That would undermine 
the draft’s public health purpose.

The central weakness is that the draft proposes regulation through 
prohibition rather than regulating products based on the risk they pose 
relative to combustible tobacco. Estonia still has a substantial population 
of adults who smoke: 13.2% of adults aged 16–64 smoked daily in 2024, and 
51.6% of daily smokers said they wanted to quit. A tobacco control law 
should protect young people while preserving realistic routes away from 
combustion.

Our response is on behalf of the European Tobacco Harm Reduction Advocates 
(ETHRA). ETHRA is the voice of 27 million EU consumers of safer nicotine 
products (SNPs). The safer nicotine products we use include vapes, nicotine 
pouches, snus, and heated tobacco products. ETHRA is a consortium of 24 
grassroots consumer associations in 17 European countries, supported by 
experts in tobacco control and nicotine research. We are a voluntary 
operation with no industry funding or conflicts of interest. Our 
transparency registration number is 354946837243-73.

In the attached pdf we outline our position and share relevant evidence that 
underpins our position.