With tobacco harm reduction debates intensifying, COP11 exposes shifting EU positions and conflicting global strategies shaped a contentious conversation about safer nicotine alternatives.

The ongoing Eleventh Conference of the Parties (COP11) to the WHO Framework Convention on Tobacco Control (FCTC), currently being held in Geneva from 17–22 November 2025, marks the 20-year anniversary of the treaty’s implementation. Bringing together more than 1,400 delegates from over 130 Parties, the meeting aims to evaluate progress on global smoking reduction and establish future regulatory directions. Yet behind the formal agenda, COP11 has become increasingly defined by controversy—most notably concerns over its closed nature and deep divisions over how to address modern nicotine use, especially the rapid rise of non-combustible alternatives such as vapes, pouches, and heated tobacco products.

While many public health officials continue to push for strict controls across all nicotine categories, tobacco harm reduction (THR) advocates—including consumer groups, independent researchers, and behavioural scientists—highlight that real-world evidence warn against this. Countries that support reduced-risk products are achieving smoke-free goals far more quickly than those relying on prohibitionist or highly restrictive policies. This tension has made the parallel “Good COP” counter-conference particularly influential, framing COP11 as a pivotal test of whether the FCTC will evolve to match current scientific and technological realities.

Delegates have spent significant time reflecting on two decades of tobacco control progress under the FCTC. There is broad consensus that the treaty has accelerated global improvements such as advertising restrictions, smoke-free protections, and taxation strategies for tobacco. Yet many observers note that the structure of the FCTC was built for a world dominated by cigarettes—long before the emergence of modern vaping technology, nicotine pouches, or heated tobacco.

Good COP analyses emphasise that because these newer products did not exist when the treaty was drafted, the FCTC still treats tobacco control as if only combustible cigarettes matter. Some Parties believe the treaty must now be updated to reflect today’s diverse nicotine landscape. Others insist that all nicotine products—regardless of relative risk—should be subject to cigarette-level controls. This philosophical divide is one of the defining tensions of COP11.

Youth protection and adult harm reduction: not mutually exclusive
Youth nicotine use remains a core concern at COP11. Many delegations are calling for tighter restrictions on flavours, packaging, and marketing, arguing that experimentation among adolescents requires strong preventive measures. Harm reduction organisations agree that youth protection is essential but warn that treating all nicotine products the same obscures critical differences in risk.

Millions of adults rely on non-combustible products to quit smoking; banning or heavily restricting these tools could undermine public health progress. They also point to emerging research suggesting that many young people who might otherwise smoke are instead using reduced-harm alternatives. While not a desirable outcome in itself, they argue, it nevertheless represents a far lower health burden than youth uptake of combustible cigarettes.


Meanwhile, Good COP reports repeatedly reference countries such as Sweden, Norway, New Zealand, and Japan, where smoking rates have collapsed as safer alternatives gained traction. THR advocates hope COP11 will recognise that youth protection and adult harm reduction can, and must, coexist.

A shifty EU
Prior to COP11, a leaked early draft of the EU’s negotiating position alarmed harm reduction groups by appearing to support broad prohibitions on alternative nicotine products. Following widespread criticism from consumer organisations, independent researchers, and several EU policymakers, the final version softened considerably. The revised document prioritised proportionate regulation, national flexibility, and evidence-based decision-making rather than sweeping bans. For THR advocates, this shift demonstrated that scientific debate and public engagement could still influence policymaking even within the typically closed FCTC environment.

However, optimism faded quickly once COP11 began. Reports from Geneva indicate that Denmark, backed by the European Commission, is now pushing for EU-wide bans on vaping products and nicotine pouches, directly contradicting the EU’s agreed stance. Adding to the controversy is the fact that Denmark’s own recently released UngMap 2025 study shows youth smoking plummeting precisely because young people are shifting to non-combustible products.

UngMap 2025 surveyed more than 2,100 Danes aged 15 to 25 and found daily smoking had dropped to just 2.7 percent, down from 15.4 percent in 2014. The decline is occurring alongside increased use of alternatives like snus, vapes, and nicotine pouches, a trend mirrored globally. Despite this, Denmark now advocates for prohibitions that appear inconsistent with its own data.

Inside COP11’s biggest debates
The FCTC Secretariat continues to emphasise the need to prevent tobacco industry interference. Most Parties agree that cigarette manufacturers should have no role in shaping treaty decisions. Yet harm reduction organisations argue that the policy is being applied so broadly that it also excludes independent manufacturers, consumer advocates, and unaffiliated researchers. They contend that these exclusions reduce transparency and limit access to critical real-world data, including information on illicit markets, adult switching patterns, and product safety. This issue remains one of the most contentious structural flaws of the COP process.

Illicit markets have also featured heavily in COP11 discussions. Several Parties report significant growth in illegal tobacco and unregulated nicotine sales following harsh bans or very high taxes. Critics warn that aggressive restrictions often drive consumers (especially youth) toward unsafe, unregulated products while removing quality controls and undermining age-verification systems.

Enforcement challenges around disposable vapes are particularly acute. Harm reduction advocates argue that legal, well-regulated markets with clear age restrictions protect public health far more effectively than attempts to suppress demand through prohibition. Good COP commentary highlights this as an example of ideological rigidity overriding evidence: while some delegations push for tougher crackdowns, others stress that reducing harm through safer alternatives is more practical and effective.

Environmental concerns, including waste from cigarette filters and product packaging, are also being debated. Many Parties support measures such as filter phase-outs and extended producer responsibility. THR groups emphasise that environmental regulations should reflect the distinct waste profiles of different nicotine products, warning against applying cigarette-specific measures indiscriminately to devices such as pouches or refillable vapes.

The tug of war between harm reduction and prohibition
At its core, COP11 highlights a fundamental question: should global policy aim to restrict all nicotine use equally, or should it prioritise reducing harm by differentiating between combustible and non-combustible products? WHO and several Parties advocate precaution, citing long-term uncertainties around newer products. Harm reduction groups counter that extensive toxicological research, international case studies, and real-world population data already demonstrate dramatic reductions in smoking when safer alternatives are accessible.

Good COP reports warn that ignoring this evidence risks restricting adult access to products that could save millions of lives. The decisions made at COP11 will influence global approaches to nicotine for the next two decades.

For now, the conference stands at a crossroads—between traditional abstinence-driven doctrine and evidence-based harm reduction. As discussions continue, the fundamental tension remains unresolved, and sadly, the balance still leans toward precaution rather than pragmatism. Yet the rapid decline in smoking worldwide, combined with the rise of safer alternatives, makes one thing clear: the global nicotine landscape has changed. Whether the FCTC adapts to that reality may determine the future of public health.