Sky Views: Vaping further proof that the US and Europe are worlds apart
Friday 15 November 2019 06:39, UK
"Americans are from Mars, Europeans from Venus."
So said Robert Kagan, a former foreign policy official in the Reagan administration, in his book Of Paradise And Power, America And Europe In The New World Order.
Published in early 2003, on the eve of the second Gulf War, Mr Kagan explored why, in the fields of foreign policy and defence, Americans and Europeans so frequently disagree.
The business world has long known of this divide. The corporate annals are full of examples of American companies failing to crack Europe, such as Wal-Mart in Germany, and of European businesses failing to crack the US, such as Tesco, Saab and Carrefour.
Such divisions are clearly being seen in areas of the so-called 'new economy', for example, in the way European governments have sought to rein in the power of Silicon Valley's tech giants more aggressively than Washington.
And one of the most fascinating divides is now emerging in the field of e-cigarettes.
In the US, the Trump administration has declared war on vaping. In September, it announced a nationwide ban on flavoured vaping products, although it has since said it would not be extending that ban - as previously announced - to include menthol-flavoured e-cigarettes. Only tobacco-flavoured vaping products will otherwise be permitted.
The decision has already had big repercussions for business. The proposed merger between Altria and its sister company Philip Morris International, which would have created a $200bn giant, has gone up in smoke.
Then, on Tuesday this week, Juul Laboratories, which dominates the US vaping market, announced it was laying off 650 workers - around one in six of its employees.
Mr Trump has also proposed raising the age at which Americans may buy e-cigarettes from 18 to 21 - despite the fact that this would create a situation in which Americans could buy traditional cigarettes at 18 but would have to wait until hitting 21 before being able to buy vaping products.
Public opinion in the US is also hardening after the Centre for Disease Control and Prevention, the government's health protection agency, published figures suggesting there have been 39 deaths and some 2,051 cases of "lung injury" among people who have vaped.
It also revealed that, in some 29 samples taken from vapers, an oil called Vitamin E acetate - which contains THC, the psychoactive ingredient in cannabis - had been found.
In Europe, the situation is entirely different, with governments in general adopting a 'wait and see' approach.
The European Commission has said that it will review existing regulation governing e-cigarettes by May 2021 but is showing no signs of rushing towards a Trump-style clampdown. Across Europe, in general, public health bodies have tended to view vaping as a safer alternative to smoking tobacco.
Public Health England argues that using e-cigarettes is at least 95% safer than smoking traditional tobacco products. It is reckoned that some 70,000 Britons have been able to give up smoking each year thanks to switching to vaping.
Healthcare professionals in this country also dispute the claim, frequently heard by their opposite numbers in the US, that e-cigarettes are a 'gateway' to smoking tobacco.
Of the 3.6 million British adults who have used vaping products during the last decade or so, only 6% are reckoned to have not already been smokers in the traditional sense.
So why the difference? There are a couple of possibilities. One is that e-cigarettes are more tightly regulated in Europe than in the US. Advertising e-cigarettes is banned in Europe even though in some countries, notably Germany, traditional tobacco products can still be advertised on billboards and in cinemas. This may explain why Germany has seen less uptake of vaping than other European countries such as the UK and France.
Furthermore, there are also tight rules governing the manufacture of vaping products thanks to the European Commission's 2014 Tobacco Products Directive, which restricted the size of e-cigarette refill tanks and which prohibited the use of ingredients such as taurine (the compound found in many energy drinks) and caffeine.
Crucially, unlike the US, the directive also barred the use of THC and Vitamin E acetate oil in e-cigarettes and also placed a limit on the nicotine content of e-cigarettes. It also specifically set out to ensure that it wished to create "an environment that protects children from starting to use these products".
All this means that e-cigarettes in Europe are probably safer than their American counterparts.
Boiled down, the big difference between European and American attitudes to e-cigarettes is that, in Europe, e-cigarettes are viewed as a way of helping wean smokers off tobacco while, in the US, the focus is on preventing young people from taking up vaping in the first place for fear of them then graduating to smoking.
The US Food & Drink Administration, the main US healthcare regulator, has argued that there is an "epidemic" of teenage use of e-cigarettes. The danger is that, by belatedly forcing through tougher regulation on e-cigarettes, the Trump administration may actually do more harm than good.
Clive Bates, former director of the leading anti-tobacco campaign group Action on Smoking and Health (ASH), told The Sunday Times recently: "After 10 years of vaping in the US this sudden spate of deaths has been laid at the door of regular nicotine vaping by unscrupulous operators in the federal government, and it's completely irresponsible.
"It has nothing to do with regulated vaping. These deaths are caused by cannabis-based products, made in backstreet factories, but they're being used to intensify an already existing moral panic.
"President Trump's ban on vaping flavours will simply mean that fewer people switch from tobacco. Around 80% of vapes are flavoured, it's very popular, and if you make the product less appealing, it will be used by fewer people. It protects tobacco from an effective competitor, which will lead to more smoking and many thousands more deaths. I cannot think of a more unscientific and unethical course of action."
In Europe, e-cigarettes are viewed as a way of helping wean smokers off tobacco while, in the US, the focus is on preventing young people from taking up vaping in the first place for fear of them then graduating to smoking.
His argument is borne out by experience. The ban on cigarette advertising and the forced introduction of plain packaging for cigarettes entrenched the market share of established players.
For example, Imperial Brands (maker of Lambert & Butler, Regal and Superkings) and Japan Tobacco International (maker of Sterling and Mayfair) have together accounted for 80% of the UK tobacco market for decades.
Neither had faced any meaningful competition until the arrival of e-cigarettes, both of which have now embraced with vaping products of their own.
It would be ironic indeed if Mr Trump's proposed measures further entrenched the power of Big Tobacco in the US.
Sky Views is a series of comment pieces by Sky News editors and correspondents, published every morning.
Previously on Sky Views: Rowland Manthorpe - Sovereignty? If it's not technological, it won't count