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Prime Minister’s Office, Head of Legal

Ministry of Foreign Affairs, Head of Legal

Ministry of Health and Social Affairs, Head of Legal

CC sent to Left Party, Greens, Social Democrats, Centre Party, Liberals, Moderates, Christian Democrats, Sweden Democrats

Open letter to Swedish Governmental offices and Agencies and political parties regarding “harm reduction” in relation to the proposed new Tobacco Law.

To whom it may concern,

We are representatives of a global network of scientists, professionals and 36 civil society advocacy organisations from 34 countries. We, together with numerous national governments, represent a globally increasing movement in recognition and acceptance that “harm reduction” is clearly mandated in the original FCTC (Framework Convention on Tobacco Control). Harm reduction also in tobacco is clearly a human right and that is enshrined in the rights to health and autonomy.

Enacting the proposed law may have the negative effect that 35 CSO-NGOs together with the global harm reduced nicotine user community will advise their members to disregard Sweden as a travel destination because of the increased anti harm reduction regulations and possible legal consequences. The proposed law in its current format is unnecessarily damaging to public health, individual health and to the goal of ending cigarette smoking and smoking related disease. The proposed law is a Human Rights to Health violation.

We are writing to your respective offices and to the media in some urgency as new circumstances have come to our attention. These are very positive circumstances and present a unique opportunity to instead implement prospective new knowledge that will not be available until 2020.

In our view these very recent circumstances clearly and urgently indicate that any legal decisions that affect snus and/or electronic nicotine delivery systems are wholly inappropriate to enact at the current time. We therefore respectfully ask that the proposed law be voted down, withdrawn or redrafted, as the scientific validity of harm reduction via snus and electronic nicotine delivery systems are not adequately reflected in the proposed law.

1.     We have received information that a project has been initiated within Swedish Agency SBU (Swedish Agency for Health Technology Assessment and Assessment of Social Services) to evaluate and assess snus (and e-cig) in relation to smoking and the results are expected no earlier than 2020. This project carries tremendous global value in that adequate and useful quantitative relative risk estimates between Swedish Snus and Smoking have so far to the best of our understanding never been produced or communicated, Nationally or Internationally. Snus is not harmless and should not be communicated as harmless. Nor should there be any misunderstandings regarding that nicotine use should best be avoided in entirety, but if not entirely then at least especially in and before pregnancy and preferably when there is cardiovascular disease present unless it is likely that the alternative is continued smoking. These facts are already known and almost universally agreed, therefore what remains to urgently quantify is the relative difference in risk between snus use and smoking to otherwise healthy and non-pregnant adults, and this announced project within SBU is therefore of immense global value.

2.     It has also come to our attention that a new tobacco law for Sweden was agreed by the Social Committee in Parliament on Thursday December 6th and published online on Friday December 7th.  These steps taken in preparation for a parliamentary debate on December 11th, with a planned Yay/Nay voting session on December 12th. In effect this means that the final version was made available to the public[1]on December 7th, and the voting session is less than three full weekdays from that day.

3.     We have received information that there is an initiative underway, with support from the Ministry of Foreign Affairs Treaty office, to correct an obvious mistranslation in Article 1(d) in the Swedish version of the FCTC (Framework Convention on Tobacco Control).

4.     The clearly mistranslated portion has changed the meaning of “harm reduction” as understood, expressed, and intended in 1(d) in the original as a requirement, to instead becoming a de facto ban of “harm reduction” in Sweden. The most obvious effects of this are found in science and policy regarding snus and the international (mis)information enabled by the error. A correction of the Swedish FCTC text, to accurately reflect the true meaning and intent of “harm reduction” as expressed in the treaty and preparatory materials would be a very welcome step forward and have tremendous potential value in the fight against tobacco related disease. We believe a correction would have a positive impact on willingness and ability to affordably achieve UN Agenda 2030 SDG goal 3 targets, also in Low and Middle Income Countries (LMIC) globally, where soon 75% of global smoking takes place.  


There is every likelihood that prospective and retrospective results from assessments by SBU in 2020, and a correction in the Swedish translation of the FCTC, can considerably improve and expand the available toolbox that the global health community and public health communities use in “Tobacco Control” work as per the requirements and intentions enshrined in the FCTC.

We therefore respectfully urge political representatives of the Kingdom of Sweden, and her governmental bodies and agencies – to postpone any proposed legislation that negatively affects the ability to exercise and utilize an appreciation of the relative risks of different products– at least until such a time as the two crucial issues in this letter have been thoroughly examined and resolved.

With our great respect for Sweden and her role in promoting health, equity and Human Rights.


Atakan Erik Befrits

NNA Sweden (New Nicotine Alliance Sweden)

INNCO (International Network of Nicotine Consumer Organisations)

This email address is being protected from spambots. You need JavaScript enabled to view it.

+46 764 156046


Nancy Sutthoff

Chairman AVCA, New Zealand

President of the Board INNCO


Kim Dabelstein Petersen

Chairman of the board DADAFO, Denmark



David T. Sweanor J.D.

Chair of the Advisory Board, Centre for Health Law, Policy & Ethics, University of Ottawa

Adjunct Professor, Faculty of Law, University of Ottawa

Legal Counsel, Non-Smokers’ Rights Association, 1983-2005

Recipient, Outstanding Individual Philanthropist Award, Ottawa, 2016


Professor Marewa Glover

Director, Centre of Research Excellence: Indigenous Sovereignty & Smoking

Scientific Advisor to INNCO