By Timothy S. Donahue

Top Takeaways:

• At GTNF 2025 in Brussels, Clive Bates argued for risk-proportionate regulation, faster lawful access to non-combustibles and clear adult-focused communication.
• He warned of five diversions from the mission, false claims of comparable risk, fixating on nicotine itself, youth-only framing, anti-industry litmus tests and prohibition.
• Success should be measured by adult switching, legal market share and smoking declines rather than seizure totals or rulemaking volume.

During the 2025 Global Tobacco and Nicotine Forum (GTNF) in Brussels, Clive Bates, Director of Counterfactual, delivered a keynote address focused on resetting global nicotine policy to align with science-based facts concerning non-combustible nicotine products and consumer realities. He opened with a dry comment about offering a frenetic and wild rant, then outlined a clear structure: the mission, the disruption, and five factors that hinder governments from implementing effective solutions.

The mission remains the same: lower smoking, disease, and death. Bates said that the world is not on track. Although smoking rates are dropping in many countries, the global population is still increasing, so the total number of smokers is going up. He pointed out that the trends in disease burden continue to climb.

In 2021, roughly six point three million deaths were linked to smoking, with an extra one point two million from secondhand smoke and the harms of chewing tobacco adding to the total. The good news is that quitting smoking works at any age, with the greatest benefits for those who stop before forty. Everything else in the talk was based on this simple goal: helping people to quit smoking.

Bates refers to the disruption as a category of non-combustible products that deliver nicotine without igniting tobacco, such as vaping, heated tobacco, oral nicotine, and other established smokeless options. He argued that there is beyond a reasonable doubt that these non-combustible alternatives are significantly less harmful than smoking, often by one or even two orders of magnitude.

Bates presented a European case study to practically illustrate his concept: Sweden has high total nicotine use with very low smoking rates, while Germany has lower overall nicotine consumption but much higher smoking rates. Lung cancer rates seem to follow this pattern, with about half the incidence in Sweden compared to Germany, and a similar trend is observed for oral cancer. The key policy lesson is to separate nicotine from smoke and regulate these safer alternatives to encourage adults to choose them.

From there, he identified five diversions that steer policy away from its core mission. The first diversion is the claim that new products pose risks similar to those of cigarettes. Bates criticized statements from authorities and recent national bans that rely on this idea, calling it a fundamental scientific mistake. The second diversion shifts the focus from disease to nicotine itself and makes addiction the main issue.

He explained that people use nicotine for understandable and often practical reasons—such as mood, focus, or symptom relief—and that policies should offer safer alternatives to meet that demand instead of pretending the demand will disappear. He urged companies to be more transparent on this issue, noting that in Sweden, many people begin with a safer product and never return to smoking.

The third distraction is an exclusive focus on youth initiation that overshadows both the adult market and the actual facts. Bates said that adult users of nicotine products significantly outnumber youth users in the United States. He asked the audience to consider two groups of young people: those who would have used nicotine regardless, and likely would have smoked in an earlier era, and those who would not have used nicotine at all.

The first group benefits when available products steer them away from smoking. Policy should protect youth without ignoring that reality or restricting adult access to legal options.

The fourth misdirection is viewing harm reduction simply as an industry marketing ploy. Bates said opponents try to link the industry’s history with the idea so that anything supported by a manufacturer appears illegitimate. He warned against strict interpretations of treaty guidance that cause unnecessary conflicts. Someone needs to develop safer products. When companies shift their portfolios toward non-combustibles, it can support public health goals if it truly reduces harm.

The fifth diversion is prohibition. When disputes over science and legitimacy fail, bans are proposed. Bates cited recent prohibitions across dozens of countries and noted that they are rarely evaluated for unintended consequences. The impacts fall into three categories: adverse behavior change, illicit trade, and workarounds, Bates explained. Modern logistics and e-commerce make bans unreliable, and without credible legal pathways to market, the segment shifts to unregulated product suppliers. Bates said this undermines public health policy and tax collection efforts while draining enforcement resources.

Bates also looked ahead to the upcoming World Health Organization’s Conference of the Parties (COP 11). He stated that much of the agenda does little to change outcomes, while one forward-looking paper suggests measures beyond the convention that resemble coercion. He urged delegates to evaluate ideas based on whether they support the convention’s goal of addressing severe health, social, and economic harms. If a measure cannot show that effect, it is simply a distraction.

The keynote concluded where it began: with practical steps. Publish clear, risk-based standards for non-combustibles and make reviews interactive and time-bound, so lawful products reach the market before illicit channels become dominant. Establish joint enforcement efforts targeting criminal networks rather than compliant retailers, using smarter data such as export-import mirror checks and tighter control of free trade zone relabeling. Launch adult-focused communication through clinicians and pharmacists that explains relative risk in plain language and offers step-by-step guidance on switching. Report results on a public dashboard, including smoking prevalence, adult switching into authorized products, youth trends by category, lawful market share, and decision timelines.

His closing line summed up the “big” idea: Make nicotine use safer and succeed through consent, not coercion. Adults tend to change when safer nicotine delivery options are visible, trusted, and affordable. Regulators succeed when they get good products to market faster than bad actors can push illegal contraband. If policy aligns with science and consumer needs, he said, the next GTNF will be discussing how smoking rates dropped again because adults chose better, easier options.