This is my reply to Heidi Alexander:
Dear Heidi Alexander,
Thank you for your reply the contents of which confirmed to me that you do not understand the TPD Article 20.
Article 20, is the section that applies solely to e-cigarettes, it does not affect the new TPD regulations for tobacco cigarettes or loose tobacco. So your comment that Lord Callanan's fatal motion would also remove these is incorrect.
The size of an eliquid container does not make the slightest difference to the quality of the e-liquid contained therein. I can see no reason for this ruling apart from bureaucratic harrassment. Why ban smaller packets of 10 cigarettes but, at the same time, ban larger bottles of eliquid. This is just contradiction in its worst form coming from incompetent regulators that do not know what they are doing!
The 20mg maximum nicotine limit is another example of poor regulation. Any smoker that has switched to vaping will tell you that heavy smokers need a higher 24mg and upwards nicotine content. If they cannot get satisfaction when switching to ecigarettes they are unlikely to persevere and will relapse to smoking. Low nicotine content and slow delivery is also the cause of the low success rate of NRT products. I know vapers will be able to get a prescription from their local GP for higher mg nicotine but who is going to be producing it? Bearing in mind the future regulatory costs for eliquid approval, producers will be unlikely to offer this type because it will not be cost effective. The EU appears indifferent to the costs and burdens that will break many of the e-liquid companies -- a great gift to the tobacco companies who do have vast sums to spend on such.
Excessive warnings on eliquid containers and packages is totally unnecessary when there is nothing like equivalent risk. A child-proof cap and "keep out of children's reach" is all that is necessary. Off-the-shelf medications do not contain large excessive warnings and many are within easy reach for children in supermarkets..
The so-called dangers and highly addictive designations attached to nicotine has now been scientifically disproved. It is no more addictive than caffeine. However, it is highly addictive when mixed with chemicals found in a tobacco cigarette. I have done my research and suggest that you do yours. The stigma attached to nicotine and tobacco should not be applied to vaping products.
To sum up, I think the TPD Article 20 is bad regulation. It breaches most principles of good policy-making. The secretive "behind closed doors" approach that the EU took ensured that we were uninformed and were unable to participate in the process.
Regards,