This letter was sent to two Members of the European Parliament who asked the EU Commission how it planned to handle consumer mobilisation campaigns on harm reduction. The question cited out “Fix the Flaws” campaign directly.
Hello,
It’s been brought to my attention that you’ve sent a Parliamentary question about our campaign to “fix the flaws” that seem destined to be included in the revision of the Tobacco Products Directive. So I thought I’d write to you directly.
We included an AI submission tool on that campaign site so people could design a response for the call to evidence. Sadly, this wasn’t a great success. As we show on the front page of the site, only 48 users copied a submission from our tool (we’ve no idea how many of them went on to submit it). We probably won’t bother again should the opportunity arise.
But other similar campaigns – some AI based, others not – helped to drive over 80.000 responses to the call, of which 94.5% opposed the proposal according, to the data the Dutch vapers association ACVODA put together.
(They’ve actually done a pretty thorough breakdown of all the campaign data which might be of interest. It’s here. I’ve copied Hans Molenaar, who has spent ages on it in case you have specific questions)
I suspect, however, that your main objective in drafting this question might be to suggest that anyone who thinks that that nicotine harm reduction is a worthy cause should not be listened to because we’re all tied up with the tobacco industry. (I’ve been very open about our funding, it’s from the Consumer Choice Center and paid adverts).
I’m not going to run through the various arguments in favour of harm reduction when it comes to nicotine. There are academics from around the world who are far better placed to talk about it than I am.
But I would like to gently suggest that if you infer that the views of citizens you happen to disagree with are to be discarded, then you shouldn’t be shocked when they turn away from the kind of politics you strive for.
A cautionary tale, if I may.
In its report on the public consultation on animal welfare (attached, see page 2) – run by the same Commissioner in charge of the TPD consultation – the Commission calls many of the 190,000+ responses “mobilised by politically motivated NGOs”; and reduced 46,461 campaign responses to a single contribution in its analysis.
“Politically motivated NGOs” is not neutral language. It casts suspicion on organised participation. It’s the same language Viktor Orban uses to trash civil society in Hungary. Commissioner Varheyli, whose department is responsible for both consultations, is (as you know) from the same political party as Orban. It is deeply sinister.
And I fear that by linking a certain view on harm reduction with tobacco industry interference, you are doing exactly the same thing. Harm reduction as a public health strategy has its roots in the fight against the AIDS epidemic. It has saved hundreds of thousands, if not millions, of lives.
But the question is straightforward: if mobilisation makes citizens’ views less legitimate, does that apply universally? Do you support the Commission’s characterisation of animal welfare activists here? Would you accept tens of thousands of animal welfare activists being analytically downgraded as “politically motivated”?
I wouldn’t. Even if I disagreed with them.
Environmental NGOs mobilise. Animal welfare NGOs mobilise. Public health groups mobilise. Consumers mobilise. That is how pluralism works. If mobilisation invalidates a voice, then almost every organised civic effort becomes questionable.
Once institutions normalise filtering participation based on perceived motivation, that logic will not remain confined to one policy area. Either organised citizens count, or they don’t.
I’ve posted this letter to my website, clearingtheair.eu, which covers nicotine policy from a pro harm reduction standpoint. If you’d like to comment, shoot me an email back and I’ll make sure your view is included.
We’d also love to do a recorded interview with you should you like. We’ll publish the whole thing. Let me know.
Kind regards,
Peter Beckett
