What's wrong with WHO? Ten fundamentals on tobacco and nicotine

The WHO uses World No Tobacco Day to attack far safer alternatives to smoking. It is an abusive disinformation operation that spreads doubt, protects the cigarette trade, and promotes organised crime.

On the tobacco and nicotine brief, the WHO has become an arrogant and abusive agency, doing more harm than good

World No Tobacco Day, 31 May each year, has become a dark day for truth and candour in public health. The volume of disinformation flowing from the World Health Organisation is becoming more blatant, and there is more of it.

To keep your sanity and to know where to push back, may I suggest ten fundamental propositions you should hold on to? Here’s the list below, then I’ll expand on each.

1. The vast burden of tobacco-related ill-health arises almost entirely from smoking, but vapes are part of the solution, not a terrifying new problem

2. People use nicotine for its psychoactive effects, and its use will persist indefinitely, whether we approve or not.

3. There are far safer consumer-acceptable ways to take nicotine than cigarettes, and the nicotine market is migrating towards these products.

4. The real public health challenge is not mainly about youth uptake, but about adults who already smoke

5. The WHO is using brazenly misleading statistics and warped interpretations about youth vaping

6. The public health impact of any policy on vapes, pouches, or heated tobacco mainly depends on whether it reduces smoking or causes an unintended rebound to smoking

7. The WHO presses for a policy agenda that drives the market for safer nicotine products illegal and underground

8. Illicit trade creates a raft of harms to society that must be weighed against the supposed value of the policy that caused it

9. Stop blaming the tobacco industry and evoking the spectre of Big Tobacco as if it were still 1975 to justify prohibitionist measures

10. The WHO needs to ask itself some hard questions, like “Are we the bad guys now?” The answer is “Yes, you are”.

Now, let’s go through each of these ten fundamentals and why they matter.

1. The vast burden of tobacco-related ill-health arises almost entirely from smoking, but vapes are part of the solution, not a terrifying new problem

The global burden of disease, disability and premature death from tobacco use is still very large [GBD Deaths in 2023: 5.81m from smoking, 1.66m from second-hand smoke, 251,000 from smokeless tobacco]. This is comparable to the excess mortality from COVID-19 in 2020 and 2021, though for smoking, it continues every year. The harm is caused almost entirely by prolonged inhalation of smoke created by the combustion of tobacco over several decades.

Stopping smoking by any method that works significantly reduces future risks for an individual, and stopping before 40 is likely to eliminate nearly all excess risk [Cho et al. 2025]. Smoking and the 1 billion people who smoke, with new additions every day, are the primary global public health challenge.

The WHO should direct its attention and resources to tackling smoking and reducing this giant burden of disease as its single-minded goal for tobacco policy. It has dropped this focus in favour of what it incorrectly perceives to be a new threat from vapes, pouches, and heated tobacco products. These are best understood as part of the solution to smoking, with some ancillary risks to be managed proportionately. They are not a terrifying new problem demanding a change of focus away from smoking.

2. People use nicotine for its psychoactive effects, and its use will persist indefinitely, whether we approve or not

Nicotine is a widely used legal recreational substance, and people use it for its psychoactive properties: pleasure, stimulation, mood modulation, and cognitive improvements. They will do that, whether WHO approves or not. In that respect, it is like caffeine, alcohol, and cannabis. However, as a substance in its own right, nicotine is relatively benign: with only minor health effects (it is not a cause of the main smoking-related diseases, though there are possible prenatal effects) and no serious impairments (loss of control, violence, hallucinations, oblivion, etc.) from the use of the drug itself. Its rewards make it dependence-forming, but dependence becomes much less problematic if it is consumed without smoke inhalation.

Yet WHO acts as if this relatively innocuous drug can just be eliminated by controlling the supply through regulation, taxes and prohibitions. But this does little to change demand, which is likely to persist indefinitely. It is hard to think of any illicit drug use that has died out without being replaced by a superior alternative (e.g., barbiturates and quaaludes were replaced by benzodiazepines, “benzos”).

If the WHO could find the humility and comprehension to accept that nicotine use is likely to persist indefinitely, then the public health problem becomes how to make nicotine available in acceptably safe and legal alternative forms to the dominant method of use today: tobacco smoking.

3. There are far safer consumer-acceptable ways to take nicotine than cigarettes, and the nicotine market is migrating towards these products

The relative safety of smoke-free nicotine products is not in serious doubt. There has been a determined and unethical merchant-of-doubt operation to cast doubt on safer alternatives to smoking. Activists and WHO officials have been playing up residual uncertainties and creating fear and doubt about the alternatives. However, we can be confident beyond a reasonable doubt that non-combustible nicotine products are far safer than cigarette smoking on account of the greatly reduced toxicity of the emissions, biomarkers of exposure and potential harm, and immediate health improvements arising from switching. It is hard to know by exactly how much, but we do not need to know the exact amount to be confident that people should switch from a product we know is deadly. The diagram below visualises the relative risk of a range of nicotine products; it was recently published in a 2026 paper by experts at the International Monetary Fund.

IMF, Van Oordt & Rosenberg, Taxing harmful habits, 2026. Graphic derived from Murkett et al. 2022

This IMF presentation of risk is far more pragmatic and usable than anything the WHO has ever produced. We should ask why this organisation is unable or unwilling to be candid about risks. We can make an assessment based on what we do know and come up with something informative like this. The alternative is to hide behind doubt and rely on what can only be confirmed over multiple decades, if ever. You would only do that if you wished to inspire confusion and fear.

4. The real public health challenge is not mainly about youth uptake, but about adults who already smoke.

WHO and prohibition campaigners have enlisted adolescents’ health and well-being as their key rhetorical weapon. Yet this is an emotive misdirection designed to reframe the challenge as one of securing prohibition policies to protect youth.

Look at two aspects of the risks:

1. Consider the risks to youth. It is helpful to imagine two types of young people who take up vaping or pouch use: those who would otherwise have smoked in the absence of vaping or pouches and those who would never have used nicotine in any form. For the first of these, the uptake of vapes or pouches is a diversion from smoking and hence highly beneficial. For those who would never have used nicotine, there is a detriment, but it is small and likely to be transient. It is likely that the benefits to youth of vaping and pouch use compared to the counterfactual greatly exceed the detriments, given the respective risks of smoking and vaping or pouch use.

2. Consider the risks to adults. Adults who have been smoking for two decades or more are the population at the greatest and most immediate risk of serious disease (cardiovascular, cancer, pulmonary). They are also the population that could benefit most from switching to a safer product as soon as possible. They could subsequently choose to stop using the safer product if they wish. The first stage of this transition (from smoking to a safer nicotine product) brings nearly all of the health benefits. It is likely easier to do than quitting completely because it involves giving up less and does not require nicotine cessation. Some activists see that as a failure, but it is a huge win, especially as it can reach people who would not otherwise quit.

WHO and the tobacco control activists need to accept that youth uptake of vaping is largely beneficial and part of the societal migration of nicotine use from high-risk to low-risk formats. They need to get behind a real push to encourage adults at high risk of serious smoking-related disease to switch if they can’t quit or don’t wish to.

5. The WHO is using brazenly misleading statistics and warped interpretations about youth vaping

The WHO World No Tobacco Day package includes the following:

In countries with available data, adolescents are on average nine times more likely to vape than adults. [web page]

No source for this number was readily accessible, and no definition of the numbers used was provided - e.g., was it “ever-use” (i.e. experimentation as little as once). It must relate to prevalence (not the number of people) and includes large countries like India and China, where vaping is banned or heavily restricted. In the United States, 5.9% of middle and high school students (1.63 million people) reported current e-cigarette use (NYTS), and the adult e-cigarette prevalence is 7.0% (18.8 million people) (CDC NHIS). The prevalence is roughly the same, but the number of adults is more than 11 times as large.

If we consult WHO’s own publication, WHO Global Report on Trends in Prevalence of Tobacco Use 2000–2024, it reports adult e-cigarette use at 1.9% or 86.1 million people (Table 15) and youth e-cigarette use at 7.2% or 14.7 million people (Table 16). So the ratio of prevalence is 3.8 to one, and the ratio of numbers is one to 5.9 (youth to adult).

But all of that misses the point. WHO’s statistic is not just false; its interpretation is deeply misleading. The higher prevalence among youth reflects a success story. This age group has been far faster at migrating away from smoking and diverting to safer products at the point of uptake. WHO isn’t telling you what those 14.7 million teenage vapers would be doing if they weren’t vaping. The good news is that these young people will never be harmed to the extent of the pain and suffering their parents’ and grandparents’ generations faced. We do have a real and serious problem; it is the slower migration of older adult nicotine use to safer products. As always, WHO is ignoring the real challenge and making a distracting argument about youth to promote a prohibition agenda - they have their priorities exactly the wrong way around. Why might older adults be moving more slowly? Maybe because of the misinformation and the doubt created by major agencies that people ought to be able to trust.

6. The public health impact of any policy on vapes, pouches, or heated tobacco mainly depends on whether it reduces smoking or causes an unintended rebound to smoking

Even if a policymaker is only making policy on vapes, pouches, smokeless or heated tobacco, the public health effect of that policy will likely be dominated by whatever effect that policy has on smoking. This is because the risks of vaping are a small fraction of the risks of smoking. Even a small rebound effect to smoking is likely to overwhelm any hoped-for benefits from reducing vapes or pouch uptake: the unintended consequences are the main consequences. Some examples:

• High credibility quasi-experimental economic studies have shown that anti-vaping measures such as vape taxes and flavour bans will increase smoking. This link between smoking and vaping arises because vapes and cigarettes behave as economic substitutes. See, for example, Friedman et al, 2026. E-Cigarette Flavor Restrictions’ Effects on Tobacco Product Sales.

• The 1992 EU snus ban denied Europeans a product with minimal risk that had been extremely successful in reducing smoking and disease in Sweden. Since 1992, twenty million European Union citizens have died from smoking-related diseases and 94 million still smoke. If only a small share of this total had been prevented from being diverted to snus, the snus ban would have caused thousands of net deaths.

• The EVALI scandal, in which the CDC falsely claimed that nicotine e-cigarettes were responsible for a spate of nasty lung conditions involving about 2,800 hospitalisations and 68 deaths, may have killed far more by deterring a small fraction of America’s 30 million smokers from switching. Only a 0.1% shift to smoking would mean 30,000 additional smokers, and likely many more deaths than EVALI itself.

7. The WHO presses for a policy agenda that drives the market for safer nicotine products, illegal and underground.

The WHO routinely presses for and rewards complete bans on safer alternatives to smoking - for example, it awarded India’s Health Minister a special medal:

…for spearheading the Government of India’s legislation to ban e-cigarettes and heated tobacco products [WHO press release].

However, where bans are not politically feasible, it has a range of favoured measures that function as semi-prohibitions and argues that all nicotine products should be treated the same way (though it never tries to have cigarettes banned).

WHO website for World No Tobacco Day 2026

Most of the WHO’s prohibitionist policy proposals lead straight to illicit trade and nurture exploitative organised criminal networks. If people cannot get what they want because the products are prohibited, because what they like about the products is banned or restricted, or because they have been made way too expensive or inaccessible, then people can tap into the illicit market. We have already seen the fruits of these policies: According to Euromonitor, Over 75% of global e-vapour volume is driven by the illicit market, October 2025.

Source: Euromonitor 2025

What an amazing achievement! 75% of the world market is now unregulated, with minimal controls on commercial practices, while nourishing the informal or criminal economy.

Has WHO learned anything at all from this debacle? Absolutely not. Its latest thinking is that the same policy package should be applied to nicotine pouches, which are even safer than vapes, see WHO warns that nicotine pouch brands targeting youth as sales surge, May 2026. The playbook and policy prescriptions are the same. Perhaps that’s what they want - the whole market to go illegal?

8. Illicit trade creates a raft of harms to society that must be weighed against the supposed value of the policy that caused it

We are in an absurd situation in many countries where, for people to access safer nicotine products that can save their own lives, on their own initiative, and at their own expense, they find the government trying to obstruct them. So, they can either comply and die or go to the illicit market.

But illicit trade is awful. Here are a few things it does:

• When something is banned, it does not disappear; if people want it and there is no comparable alternative, it is just supplied illegally. So if the aim was to ban a product to protect youth, then it will fail because the product is available illegally and usually easily. The Food and Drug Administration recently consulted on its extremely restrictive regulatory treatment of flavoured vapes. But as part of its case for a restrictive approach, it pointed out that most young people were already using flavoured vapes:

  87.6% of youth who currently used ENDS in 2024 reported using flavored products, among which fruit (62.8%) and candy, desserts, or other sweets (33.3%) flavors were the most common.

  But here is the twist… The FDA has never authorised these fruit, candy, desserts or sweet flavoured vapes, so the youth use highlighted here was already illicit, because of the FDA’s restrictive position. Illicit markets defeat the policy intent that creates them.

• Some of the products supplied illegally may be lawful and regulated in other jurisdictions. But some may not be. Illicit products are unregulated, may be of poor quality, perhaps dangerous (you don’t know), deceitfully described, possibly out of date, and offered with no consumer redress.

• Criminal supply is ultimately controlled by violence, which involves extortion, bribery and the corruption of officials and enforcement bodies. Law enforcement can see opportunities to collect bribes or favour chosen suppliers.

• The same networks that provide illicit nicotine products often have other lines of business and will supply a range of illicit products or services to anyone with money, exposing consumers, especially younger consumers, to risks they would not ordinarily encounter.

• Young people are drawn into criminal supply networks as both bottom-tier suppliers and consumers. They provide low-cost distribution and are likely to face lower penalties if caught and charged.

• Law-abiding firms cannot function normally or at all in the face of competition from illicit supply and are undercut by competitors that bear no compliance costs and face no barriers to innovation.

When will WHO and the other prohibitionist activists take some responsibility for this? Remember, 75% of the global vape trade is now illicit, and that has happened because governments followed the advice of WHO, the FCTC Secretariat, and hundreds of unaccountable foundation-funded activists.

9. Stop blaming the tobacco industry and evoking the spectre of Big Tobacco as if it were still 1975 to justify prohibitionist measures

Yes, I do understand just how bad the tobacco industry has been in its history, and I have done my bit to hold them to account. But it is pitiful to watch WHO and others rely so heavily and lazily on evoking industry misconduct and interference to justify their policy agenda. They deflect scrutiny by claiming any argument they find inconvenient to be an “industry talking point” as if that should end the discussion. In the media, it usually does.

Yet, the situation has changed dramatically in the 21st Century compared to the darkest days of industry malfeasance. They are no angels, of course, but consider the following:

• They stared into the abyss of super-litigation and personal prosecutions in the late 1990s and were clobbered by product liability litigation, the Master Settlement Agreement, and racketeering charges. They have since become governed by lawyers and infused with caution (almost to the point of self-destruction).

• They now have products that can displace cigarettes and are, to varying degrees, pursuing market share in reduced-risk nicotine products as a core business strategy. The migration of the nicotine market to low-risk products is a good transition for consumers and beneficial for public health. The interests of the industry and public health are, at least in part, aligned.

• You may be surprised, but they are often correct and knowledgeable about topics that seem to mystify WHO officials and tobacco control activists, such as the economics of taxation, product stewardship, or toxicological risk assessment. They generally produce high-quality science and make careful and guarded statements about risks and benefits.

10. The WHO needs to ask itself some hard questions, like “Are we the bad guys now?” The answer is “Yes, you are”

I believe there is an appalling symmetry between the tobacco industry’s mendacity of the past and the conduct of the WHO and many agencies, academics and activists today - sustained by uncritical media coverage and superficial politics.

There is a good case that tobacco control has become the problem (see: Is tobacco control the new Big Tobacco?). Here are some reasons to think so:

• If you deny people who smoke access to safer alternatives to cigarettes, how is that different from encouraging them to smoke?

• If you mislead people by exaggerating the risks of safer alternatives, how is that different from misleading people by downplaying the risks of smoking?

• If you put in place prohibitions or regulatory barriers to safer alternatives, how is that different to protecting the cigarette business from anti-smoking laws and hostile regulation?

• If you insist on addressing smoking with policies that don’t work that well, how is that different from tobacco companies that used to do the same?

At the moment, I see a tectonic shift happening in consumer behaviour driven by the personal interests and preferences of nicotine users, combined with private sector innovation. We are witnessing a steady migration of the nicotine markets to much safer products with two main mechanisms: (1) smokers switching to safer products; (2) younger people never smoking in the first place and initiating with safer products, then ageing into the population. To resist the second of these mechanisms - a futile and counterproductive enterprise as discussed above - the tobacco control establishment is obstructing the first. In doing so, it is protecting the cigarette trade, killing smokers, abusing young people, and promoting criminality.

I’ll go one step further: it is worse than Big Tobacco ever was. The lies, the money, the influencing operations, the disdain for debate, and the contempt for the public are all disturbing. But what is so much worse is the abuse of trust. The capture of trusted public institutions by weird fanatics and opinionated billionaires. Since the 1960s, most people have been sceptical about the tobacco industry, but they have expected to trust bodies like the WHO. They are being sorely let down.

At least the tobacco companies were ultimately held to account in the courts. The WHO will ultimately be held to account in the court of public opinion and face the punishment of a political backlash. I predict it won’t be pretty.

The WHO should get back to these fundamentals. Where could it find inspiration? It needs to look no further than the Framework Convention on Tobacco Control (FCTC), the global tobacco treaty ratified by 183 nations. This is a harm reduction to promote harm reduction.

Article 3, the Objective of the FCTC states:

3. The objective of this Convention and its protocols is to protect present and future generations from the devastating health, social, environmental and economic consequences of tobacco consumption and exposure to tobacco smoke by providing a framework for tobacco control measures […]

This objective is all about reducing harm. That translates in practice to finding a way to cut smoking as deeply and rapidly as possible. If there are trade-offs or unintended consequences to consider, the guiding lodestar is the choice that minimises these harmful consequences to the greatest extent. That will almost always lead to doing whatever it takes to cut smoking, not obstructing popular methods to cut smoking or creating giant illicit markets.

What are tobacco control measures? Article 1d of the FCTC provides a definition:

1 (d) “tobacco control” means a range of supply, demand and harm reduction strategies that aim to improve the health of a population by eliminating or reducing their consumption of tobacco products and exposure to tobacco smoke (emphasis added)

If the WHO and the FCTC Secretariat took their role seriously, they would be audited and assessed on how they spend their resources: financial, human, and political capital on reducing harm.