The government is currently holding a consultation on "Tobacco and vapes: packaging, appearance and display" which closes at 11:59pm on 2nd October. It plans regulating safer nicotine like smoking, with restrictions on packaging, displays, advertising, flavours and more. The NNA has produced a website - which you can read here - to let our supporters know how to have your say about the new government proposals.
The consultation is very involved and features a large number of questions. So, we have produced a briefing, below, which may help those who wish to submit. We have given our views on the consultation questions which you may find helpful. You can also click here for the briefing as a PDF file.
Please do read the website and respond to the consultation. Consumers are the most affected in this process and should have the most important voice. If you do not have your say, other people will make decisions which could seriously affect you.
NNA Briefing on the government public consultation.
Here is a guide to the UK government’s ongoing consultation on “Tobacco and vapes: packaging, appearance and display.”
- Consultation closing date: 11.59pm on 2 October 2026
- The online submission form can be accessed here
- Your responses are vital, whether or not you are a nicotine consumer
- Make your case clearly and firmly but please remember to be polite and constructive
- You are not required to answer every question
- You do not have to complete the questionnaire in one go, you can get a link for your saved answers
- The consultation asks that you offer your suggestions on the aims of government proposals, how they would work in practice, and what issues they may cause
The NNA has assessed the consultation questions. If the government wants to see fewer smokers, it makes no sense to treat products which pose far lower health risks in the same way as cigarettes. In effect, this policy effectively protects cigarettes from competition.
We highlight below highly relevant questions on proposals which relate to reduced risk products (i.e pouches, vapes and HTPs) that consumers should definitely consider responding to. Please note that some of the points raised can apply to several questions.
Proposals for further plain packaging requirements
The Government has repeatedly and inappropriately equated heated tobacco products with combustible tobacco products. As a reduced risk nicotine product, it is wrong to treat heated tobacco the same as cigarettes. The important health distinction is between combustion and non-combustion, rather than between tobacco and non-tobacco products.
There is an abundance of research which finds that heated tobacco presents a far lower risk of disease than smoking.
The same is true for the next two questions on text health warnings and picture health warnings on the packaging of heated tobacco devices.
We question whether such health warnings could provide consumers with the most useful and actionable information: that the risks from HTPs are substantially lower than those from smoking, even if they are not zero. A warning that “this product causes lung cancer”, applied equally to heated tobacco products and cigarettes, would be highly misleading.
Likewise, the consultation information states that: “The images on the picture warning may need to be related to the harms caused by using each specific product.” No harms specific to heated tobacco have been evident so far. Any images would be misleading.
Proposals for pack inserts in packaging for all tobacco and heated tobacco products
The NNA has consistently advocated for the inclusion of pack inserts for smoking products to signpost people who smoke to reduced risk products. However, we believe that quitting messaging and related leaflets should focus primarily on combustible smoking products. Heated tobacco products should be treated as an option for smokers seeking to quit smoking.
Smokefree products such as vapes and nicotine pouches should not be overlooked as options in this process. The government could, for example, direct smokers to the highly successful Swap to Stop Campaign by way of these inserts.
Proposals for banning lights, branding, imagery, artwork and digital screens on heated tobacco devices
Restrictions on heated tobacco products the same as required for combustible cigarette packaging would mislead the public as to their relative risks. Heated tobacco products should appear more appealing than cigarettes to attract people away from smoking combustible tobacco.
Heated tobacco devices should not be styled in a way that could attract minors. They should never mimic toys, cartoons, sweets, or any other imagery that appeals to children.
Proposals for vaping and nicotine product packaging and shape
There is no credible evidence that setting strict limits or uniform standards on the size, shape, or colour of vaping devices discourages youth vaping. Considering that vaping is known to be the most effective and most popular means of adult smokers quitting smoking, all proposals should be evidence-based.
Proposals for restrictions on imagery, branding and text of vaping products
The effectiveness of reduced risk nicotine products in helping smokers quit depends on allowing people to find an experience that is more attractive to them than combustible tobacco. Preserving this diversity is crucial to supporting successful transitions away from smoking.
Proposals for packaging of all nicotine products to be child-resistant
Regulations should prioritise ensuring that refill bottles and tanks are fitted with child-resistant packaging. Overly complicated packaging, however, could make these products harder for adult smokers with dexterity issues to use.
The government should adopt the international ISO standard for “Child-resistant packaging — Requirements and testing procedures for reclosable packages”
Proposals to restrict flavour descriptors of all vaping products to a single lead flavour
For vape products, pouches and heated tobacco, flavours are vitally important. The proposals are to alter the 'flavour descriptors' (the names given to the flavours) rather than to ban the flavours themselves. This is relatively positive, as there is a wealth of evidence demonstrating that flavour bans are counterproductive to public health. However, the devil is in the detail, and we are concerned that these proposals on descriptors are ill thought out and could effectively remove thousands of flavours.
15% of adult vapers say that restrictions on flavours “will cause an increase in their smoking” according to the latest survey by Action on Smoking and Health (ASH).
Some of the government’s proposals would require the vendor to misdescribe them. For example, with regard to sensory flavours, there is a difference between “Blueberry” and “Blueberry Ice”. Using “ice” in the descriptor conveys information to the user that the flavour contains menthol or mint. According to ASH, “43% of [adult] vapers sometimes or always use ‘ice’ flavours”.
Epidemiological research has repeatedly found limiting flavours is shown to lead to an increase in smoking, especially amongst youth. By limiting flavours to a single word descriptor, the regulation would effectively ban thousands of flavours which are used by adults.
Proposals for information on and inside vaping and nicotine products packaging
This is common sense information. The NNA has particularly argued that the display of nicotine pouch strength should be standardised so that it is clearly visible to the consumer what they are buying.
Proposals to limit the colour of vaping devices, and restrict branding, imagery, and artwork
Adults who have switched from cigarettes to products which the Office for Health Improvement and Disparities (OHID) concludes present “a fraction of the harms of smoking” should not be restricted in the same way as if they were using harmful combustible products. Plain packaging, as is being proposed, and restrictions of brands treats far safer products the same as cigarettes.
The Royal College of Physicians has stated that any approach which “makes e-cigarettes less easily accessible, less palatable or acceptable, … less consumer friendly … causes harm by perpetuating smoking."
Proposals for restricting the digital screens on vapes
There is no credible evidence that screens encourage youth vaping. Vaping is the most effective and most popular means of adult smokers quitting smoking, all proposals should be evidence-based.
The sum of these measures will further reinforce misinformation in the minds of the public. Already, surveys have found that a majority of the public wrongly believe that vaping is as harmful or more harmful than smoking. Evidence-free measures such as this will have no public health benefit but will undoubtedly convince many more people that vapes are as harmful as cigarettes.
Digital screens on vaping devices should be allowed when they serve practical functions such as showing battery life or device settings.
Proposals to stop vapes imitating other products
Vaping products should avoid designs that mimic toys, cartoon imagery, sweets, or any other shapes and objects likely to attract children. Their appearance should reflect that they are intended for adults.
Proposals to restrict the display of heated tobacco devices and prices
Heated tobacco is a reduced risk nicotine product which should not be treated in the same way as cigarettes. Many smokers have found heated tobacco to be a way out of using combustible tobacco and a product which can improve their health. There is an abundance of research which finds that heated tobacco presents a far lower risk of disease than smoking.
Proposals to restrict the display of nicotine products
Vaping and nicotine pouch use is not smoking. Safer nicotine products are not cigarettes. There is a huge difference between the products. This is key to their success in transitioning smokers to taking their nicotine in a far safer form. Restricting their display the same as combustible tobacco will send entirely the wrong message to the public. Misconceptions around the relative risks compared to smoking will be reinforced which can only have harmful consequences for public health.
Proposals to restrict the display of prices for nicotine products
This information is vital to consumers when they purchase the products.
Banning the displays of these items along with their prices treats far safer products exactly the same as cigarettes. There should be some recognition that low risk nicotine products are vastly safer than cigarettes and they should not be treated in the same way.
Proposals to allow for the display of vaping products in relevant trade premises BUT NOT to vape shops, since they are not clinical settings.
Specialist vape retailers employ staff who can demonstrate products, help with appropriate product selection and offer advice which could help an adult quit smoking. They often work hand in hand with smoking cessation services. Many supply items for the government’s Swap to Stop campaign which has helped hundreds of thousands of smokers quit smoking.
Hiding products from adult smokers actively seeking alternatives to smoking serves no public health purpose. In fact, it will only serve to confirm, in the minds of the public, that safer nicotine products are as harmful, or more harmful, than smoking.
Observations on the consultation stage impact assessments
The government’s Impact Assessment states that “display restrictions could discourage some adult smokers from switching to less harmful alternatives such as vapes.” All the measures directed at safer nicotine products will, without doubt, reinforce negative misinformation in the minds of the public and hinder people switching.
Public understanding of the relative risks of vaping compared with smoking is already significantly flawed, especially among smokers who do not use vapes. Introducing measures that treat vaping in the same way as combustible tobacco, risks reinforcing the mistaken belief that the two carry similar levels of harm.
Protecting children is an entirely legitimate objective. Responsible manufacturers, retailers, and consumer groups all support robust age restrictions and sensible enforcement against youth access, but policies designed to protect young people should not come at the expense of millions of adults who smoke or have quit smoking by using safer products.