Public-health regulation frequently begins by identifying hazards. That is necessary, but identifying that a substance or product has the capacity to cause harm is not the same as establishing the level of risk associated with a particular pattern of use. This distinction matters increasingly in nicotine policy. Nicotine is addictive and is not risk-free, yet the health risks associated with nicotine use vary considerably according to how nicotine is delivered and what other substances users are exposed to in the process. Treating the presence of nicotine itself as sufficient to place all products in the same regulatory category can therefore obscure meaningful differences between cigarettes and non-combustible alternatives.
Hazard and Risk Are Different Questions
A hazard describes something with the potential to cause harm, while risk considers the likelihood and severity of that harm under particular conditions of exposure. This distinction is familiar across public health, occupational safety and environmental regulation, where factors such as dose, frequency, duration and route of exposure all influence actual risk.
Nicotine regulation requires the same approach. The presence of nicotine raises legitimate concerns, particularly around addiction and use among young people, pregnant women and people who do not currently use nicotine. However, it does not follow that every nicotine-containing product produces the same health consequences. How nicotine reaches the user, and what substances accompany it, are important parts of assessing risk.
Combustion Changes the Risk Equation
The distinction becomes particularly important when comparing cigarettes with non-combustible nicotine products. Cigarettes deliver nicotine by burning tobacco and exposing the user to the resulting smoke. The U.S. Food and Drug Administration identifies combusted tobacco products such as cigarettes as the most harmful tobacco products and recognises that tobacco products exist along a continuum of risk.
Non-combustible products avoid tobacco combustion, although this does not make them harmless. Their risks depend on their composition, method of nicotine delivery, patterns of use and other product characteristics. Nevertheless, removing combustion can substantially change the toxicant exposure associated with nicotine consumption. This is one reason why the presence of nicotine alone is an inadequate basis for assuming that different products carry equivalent risks.
Nicotine Should Not Become a Proxy for Smoking
One of the challenges in modern nicotine policy is the tendency for nicotine itself to become shorthand for the harms historically associated with cigarette smoking. The two should not be conflated. Nicotine plays an important role in dependence, but cigarette smoke exposes users to a much wider mixture of harmful chemicals produced through combustion.
Nicotine replacement therapies provide a familiar example of why this distinction matters. They deliver nicotine without reproducing the exposure profile associated with cigarette smoking. This does not automatically establish the safety of every newer nicotine product, but it demonstrates why delivery method and exposure need to be considered alongside the presence of nicotine.
Research on tobacco-free nicotine pouches provides another example. Chemical analyses have reported substantially lower levels of measured harmful and potentially harmful constituents compared with combustible cigarettes. However, long-term epidemiological evidence for nicotine pouches remains limited, and lower toxicant exposure should not automatically be interpreted as proof of a particular reduction in long-term disease risk.
Risk Exists on a Continuum
Recognising a continuum of risk does not require describing any nicotine product as safe. Combustible cigarettes sit at the highest-risk end because decades of evidence have established their substantial contribution to cancer, cardiovascular disease, respiratory disease and premature mortality. Medicinal nicotine products have a substantially different risk profile, while newer non-combustible consumer products occupy different positions depending on their characteristics and the available evidence.
The precise position of individual products should remain open to revision as scientific evidence develops. That is exactly why regulation should be evidence-led. Where evidence demonstrates meaningful differences in toxicant exposure and product characteristics, regulatory frameworks should be capable of recognising those differences rather than assuming equivalence simply because products contain nicotine.
Why Risk Communication Matters
The distinction between hazard and risk is also important for consumer understanding. Adults who smoke need accurate information about the differences between continuing to smoke, stopping tobacco and nicotine use entirely, or switching completely to a non-combustible alternative.
Communication that focuses only on the presence of nicotine can leave consumers without sufficient context to understand those choices. At the same time, communicating relative risk should not become product promotion. Lower risk does not mean no risk, and public-health messaging should remain clear that young people and people who do not currently use nicotine should not initiate use.
The FDA reflects this balance by stating that quitting all tobacco products provides the greatest health benefit while also recognising that adults who smoke may reduce exposure to many harmful chemicals by switching completely from cigarettes to certain non-combustible products.
What This Means for Regulation
For GINN, distinguishing hazard from risk provides an important foundation for proportionate nicotine regulation. Regulators should assess products according to scientifically relevant characteristics, including toxicology, ingredients, contaminants, nicotine delivery, emissions where applicable, patterns of use and emerging evidence about population-level effects. Youth uptake, dependence and unintended initiation should remain important considerations.
These protections can coexist with recognition of relative risk. Appropriate product standards can address unsafe ingredients and product characteristics. Age restrictions and effective enforcement can reduce youth access. Marketing rules can prevent misleading health or cessation claims, while post-market surveillance can identify emerging patterns of initiation, dual use and switching.
None of these measures requires regulators to treat nicotine pouches, e-cigarettes, medicinal nicotine products and combustible cigarettes as though they present identical risks. A proportionate framework should instead reflect meaningful differences between products where those differences are supported by evidence.
Regulation Should Follow the Evidence
The objective of public-health regulation should ultimately be to reduce harm. For nicotine, that requires distinguishing the addictive properties and potential hazards of nicotine from the broader harms created by different delivery systems, particularly tobacco combustion. It also requires acknowledging uncertainty where long-term evidence for newer products remains incomplete.
Nicotine products should be regulated responsibly, young people and non-users should be protected from initiation, manufacturers should meet appropriate product and marketing standards, and consumers should receive accurate information. But regulatory decisions should also reflect what the evidence shows about differences in product characteristics, exposure and risk.
Recognising that something presents a hazard is therefore only the beginning of the assessment. For nicotine regulation to remain scientifically credible and proportionate, policymakers must also ask how much risk a product presents, to whom, under what conditions, and compared with what alternative.
