GINN Panel | InterTabac Dortmund 2026
Moderator: Joel Rubenstein, GINN
Panelists: Tomasz Płaska, Chemnovatic; Jack Li, HG Innovation; Shivam Bihani, Satyam’s Sun Products (MYNT)
The following transcript has been lightly edited for clarity and readability while preserving the substance and meaning of the speakers’ remarks.
Introductions
Joel Rubenstein:
Hello, everybody. We’re going to shift to a panel discussion this morning rather than a presentation. I’ll introduce myself, and then I’ll let the panelists introduce themselves.
My name is Joel Rubenstein. I’m part of the GINN organisation, and outside of GINN I’m a consultant working in the harm reduction arena. I’m an American based in southern Sweden.
Tomasz Płaska:
Hello, everybody. My name is Tomasz Płaska. I’m Head of Marketing at Chemnovatic. We manufacture nicotine raw materials, e-liquids and nicotine pouch mixes.
Jack Li:
Hi, everyone. This is Jack. I manage global government affairs, communications and stakeholder engagement.
Shivam Bihani:
Good morning, everyone. My name is Shivam Bihani. I’m from Satyam’s Sun Products. We manufacture MYNT nicotine pouches, and we are currently looking to expand further within the nicotine segment.
Where Is the Gap?
Joel Rubenstein:
As an introduction to the topic, everybody here certainly knows the concept of harm reduction. No one is going to make a legitimate argument that an oral, tobacco-free nicotine product is not less harmful than a combustible tobacco product.
The science is irrefutable. There are numerous case studies, small ones as well as country-wide examples. If you look at what’s happening in Sweden and Norway, smoking rates are plummeting, predominantly because smokers have other options. They may still want to engage with nicotine, but they don’t have to resort to cigarettes.
Yet despite this situation, governments are not overwhelmingly positive. There are many markets where they’re neutral, and some where they’re even negative towards some of these harm reduction products.
So there’s a gap somewhere. Something is going on where this isn’t simply common sense in the way it probably is to most of us in this room.
Tomasz, I’ll start with you. What’s missing? What is the fundamental gap between what we know, believe and think is obvious versus how governments are treating our portfolios?
Tomasz Płaska:
I believe there is a very high concentration on youth uptake. While that objective is certainly important in terms of health, it does not seem to be a comprehensive one.
If we think more broadly about health, we should consider the net population impact of regulations and whether those regulations are able to keep demand within the legal market.
We have seen that the illicit part of the market can be significant. If regulation does not keep that demand within the legal market, then it is failing in that respect.
So I would say there is too much concentration on youth uptake. It is very important, but it is not a comprehensive perspective on health.
Jack Li:
In my understanding, apart from what Tomasz has already mentioned about youth uptake, there is also the question of solid scientific evidence showing how alternative products can help smokers and former smokers transition away from smoking.
That needs to be considered alongside other topics, including youth protection and the wider impacts of products such as pouches and vaping products.
Shivam Bihani:
What I would add is that we believed the science would speak for itself, but evidently it doesn’t.
That is where we have missed something. As manufacturers, we have been more focused on marketing the product. What we haven’t done enough is generate credible data, get it to regulators, engage with regulators and provide that evidence before they develop regulations.
I think that is something we have missed and something we should address.
Risk, Taxation and Illicit Markets
Joel Rubenstein:
Do you think there are competing agendas? You mentioned misuse, adverse events, youth entering nicotine and taxation.
Cigarettes generate a tremendous amount of tax revenue. Are there competing agendas in some markets?
Shivam Bihani:
From the regulator or government point of view, taxation is obviously a concern. But at the same time, they also need to understand the different risk profiles of different categories of products.
Even if they want to tax these products, taxation should reflect the risk the products carry rather than simply treating everything in the same way because it falls within a tobacco or nicotine category.
Taxation itself is not necessarily the problem. It should, however, have a scientific and evidence-based foundation.
Tomasz Płaska:
If we talk about different risk profiles between nicotine products, then there should also be differences in taxation and, ultimately, in the prices consumers see.
If there is a significant price gap between illicit and legal products, that can create an incentive for illegal operators to enter the market.
Consumers do not necessarily buy illegal products because they are illegal. They buy them because they perceive a value difference between an illegal product and a legal one.
Taxation is therefore important when we talk about different risk profiles.
There are also different objectives among stakeholders and different departments within the European Commission. Ultimately, however, regulators are responsible to a significant extent for the outcomes of regulation.
If a significant part of the market becomes illicit, then we need to consider whether differences in product risk have been properly reflected in regulation.
And this is not only about the Tobacco Products Directive. Local regulation and taxation also influence the final price of products.
Jack Li:
I think there is a mutual understanding that the industry supports regulation and enforcement, but regulation and enforcement need to be sensible and proportionate, taking account of the relative risks of different product categories.
Shivam Bihani:
I would add that higher taxation can contribute to illicit markets and products that may not meet appropriate standards entering the market.
That can damage the credibility of the wider industry, which is an important consideration.
Does Regulatory Uncertainty Hold Back Innovation?
Joel Rubenstein:
If you look at the evolution of harm reduction, there is a spectrum of products: combustible cigarettes, heated tobacco, vaping, oral products and others.
Do you think the lack of global consistency in approaches to harm reduction is damaging innovation? Is it creating risks that are too great for businesses to take on, with smokers ultimately affected?
Jack Li:
In many countries, there are smokers who believe cigarettes are less harmful than some next-generation products. That can itself create problems.
Joel Rubenstein:
Are companies holding back innovative ideas because they think the regulatory headwinds are too great?
Shivam Bihani:
I would say yes.
When there is uncertainty in the market because of regulation, companies may be less willing to invest heavily in research and development or innovation.
Manufacturers may spend considerable time, money and resources developing something, only for the regulatory environment to change. That is a concern for manufacturers.
Jack Li:
My answer would be yes and no.
On the one hand, many companies and manufacturers are trying their best to make products compliant with an ever-changing regulatory landscape.
On the other hand, companies can invest human resources, money and budgets into products without knowing whether they will see a return because of regulatory changes and different enforcement standards.
Tomasz Płaska:
In an unstable environment, it is difficult to invest and feel confident about investing money in innovation.
What Can the Industry Do Itself?
Joel Rubenstein:
We’ve talked about the variability and constant changes in the regulatory environment.
Even within Europe, approaches to nicotine pouches differ considerably between countries.
Given that environment, how does the industry help itself? Looking internally, what can everyone in this sector do to reduce the likelihood of governments developing increasingly divergent rules? How does the industry regulate itself?
Shivam Bihani:
This is something very important that needs to be done.
As manufacturers, we need collectively to create credible evidence and present it to regulators. We need to engage with regulators, and this is something I think GINN is doing that is very important.
We need to provide evidence, toxicological reports, human behaviour research and other relevant data before regulations are introduced.
The objective should be to help governments develop more evidence-based policy.
Jack Li:
Compliance should be at the centre of everything a company does.
Under that umbrella are issues such as flavour descriptors, packaging and colours, where products should be sold and what kinds of marketing approaches should be used.
I would call this self-regulation rather than self-policing.
Self-regulation alone will not solve every problem, particularly when there are operators willing to work outside the legal framework.
The next step is to find allies who share responsible approaches and work with other stakeholders, including associations and the retail industry, to amplify those approaches.
Tomasz Płaska:
First, I think our sector—and by that I mean the wider nicotine sector—is not starting from a particularly strong position in terms of credibility with regulators because of the history of the tobacco industry.
We have to accept that and move forward.
We need to work on building credibility. There are two aspects to this.
One is coordinated work within the sector, which can be undertaken through organisations such as GINN. Within that work, we should provide data and evidence-based regulatory proposals that contribute to the public interest and future regulation.
The second issue concerns irresponsible players and products. Responsible companies are close to the market, often closer than regulators, so there may be opportunities to identify irresponsible behaviour, notify regulators and propose rules that respond appropriately.
Responsibility Across the Supply Chain
Joel Rubenstein:
Which part of the consumer chain is responsible for this type of self-regulation?
There are manufacturers, retailers, distributors, raw-material suppliers and brand owners. Where does responsibility sit?
Tomasz Płaska:
I would look at it from two perspectives: supply and demand.
There are many measures regulators take on the supply side, and enforcement is important.
But there is also the demand side. As I mentioned earlier, consumers do not buy illegal products simply because they are illegal. They may do so because they perceive a value gap between illegal and legal products.
Perhaps, as a sector, we can contribute to regulation by making proposals that minimise that gap.
That is an area where the sector can contribute to the regulatory process.
Shivam Bihani:
For me, it starts with everybody involved regulating themselves.
That means raw-material suppliers, brand owners, marketing agencies, distributors, wholesalers, retailers and manufacturers. Everybody involved in the value chain needs to take responsibility for compliance.
We need good-quality raw materials, appropriate certification and high manufacturing standards. Facilities and processes should continue to improve as better standards become available.
Everybody needs to be educated and everybody needs to do their part.
For me, this is about differentiating between responsible and irresponsible parts of the market. The behaviour of a small number of irresponsible operators can affect the entire industry.
Jack Li:
I agree with Shivam.
Every step of the value chain should act responsibly. But there are also stakeholders outside that value chain, including associations and enforcement bodies.
The industry can regulate itself, but it also needs feedback from wider society and cooperation with other stakeholders.
As I said earlier, we welcome regulation as long as it is sensible and proportionate.
Can Smaller Companies Work Together?
Joel Rubenstein:
Are there mechanisms for smaller regional or domestic companies to collaborate and raise the category as a whole? Or is every company effectively operating on its own and hoping everyone else does the right thing?
Jack Li:
From what I see, companies are largely operating on their own at the moment, while the industry’s voice often relies heavily on larger companies.
That is an obstacle we need to overcome.
Larger businesses should be willing to work with different players across the industry to make the voice of the sector more unified and more clearly heard.
Shivam Bihani:
Companies may be isolated, and that is where associations such as GINN and ABN become important.
They provide a platform where small, medium and larger manufacturers can come together, provide the data they have, and allow organisations to help bring that information together and present it to regulators and relevant authorities.
Right now, we are very focused on marketing products. But if we are looking at long-term development rather than short-term market share, we also need to engage much more with the science.
We should not assume that science will speak for itself. We need to support the science as actively as we support product and brand development.
Tomasz Płaska:
Companies should be compliant. That is non-negotiable.
We should also have trustworthy standards, and perhaps there is an opportunity to develop shared standards around production that could improve how the sector is perceived.
However, I don’t think responsible companies can simply talk illegal operators out of doing illegal business.
The greater opportunity may be to improve cooperation with regulators—to notify them quickly, become a useful partner and respond to irresponsible products appearing on the market.
I believe cooperation with national regulators may be particularly important.
Collaboration on Science
Joel Rubenstein:
Large companies have people whose job is specifically to identify opportunities for cooperation. Smaller companies often don’t have those resources.
How can smaller players find the areas where cooperation creates something greater than what each company could achieve individually?
Jack Li:
One starting point is breaking down the wall of distrust between different parts of the industry.
That can take time.
Many smaller players are focused on short-term commercial returns. But for responsible companies and manufacturers, a purely short-term approach is unlikely to work in an ever-changing regulatory environment.
Shivam Bihani:
Smaller manufacturers do not have the same leverage or resources as the biggest companies.
They can compete when it comes to brands and commercial activity. But when it comes to science, there is a strong argument for coming together and sharing appropriate data.
Perhaps an organisation or association can provide a structure where companies contribute information that can then be compiled to help understand wider trends—for example, nicotine use, product characteristics or how adult consumers move between cigarettes and other nicotine products.
Data on consumer behaviour and other areas can help create evidence and credibility for smaller players.
An organisation that allows companies to collaborate on science could help everyone learn and, in the long term, support the development of better products.
Tomasz Płaska:
The bigger the company and the greater the scale, the easier it may be to find efficiencies through cooperation.
There is space for smaller companies to cooperate as well, but those opportunities can be harder to identify.
That may be another area that organisations such as GINN can help facilitate.
Shivam Bihani:
If you look at the biggest organisations, they have in-house scientific teams and R&D departments, and they publish data.
But much of the available industry-generated evidence comes from only a small number of large players.
Smaller manufacturers may either lack the resources or may not yet be sufficiently focused on generating their own data.
Over the long term, that can create a credibility problem because they do not have evidence to support their products.
Rather than every small company trying to replicate the infrastructure of a multinational business, associations could potentially help bring together appropriate evidence and knowledge.
How Can Smaller Businesses Engage?
Joel Rubenstein:
High-quality studies can be expensive, particularly when dealing with nicotine.
How can companies without multinational-level budgets engage externally and help move the regulatory process forward if they cannot afford to fund major studies themselves?
Jack Li:
My direct suggestion to smaller companies would be: speak out.
When major regulatory frameworks are being discussed, there can be a lack of participation from smaller industry players.
If companies do not have the resources to conduct major research, they can still participate in public consultations and provide feedback to legislators.
Everyone in the industry matters, and the sector should not miss those voices.
Tomasz Płaska:
Looking at the European process, there are different stages at which companies can engage.
National representatives and regulators will be involved as policy develops. Companies operating in different countries can identify the relevant regulators and government representatives and begin speaking with them.
They can provide data, explain their perspective and offer evidence-based regulatory proposals.
National regulators are closer to their local markets and circumstances and may be well placed to understand the potential effects of future regulations.
If we want to meet again next year and discuss why we’re winning rather than why we’re losing, this is an opportunity to contribute constructively to future regulation.
Shivam Bihani:
Apart from funding studies through organisations, manufacturers also need to invest in their own scientific foundations.
That includes stability studies, toxicological assessments and understanding how products behave.
Perhaps some resources currently devoted to excessive branding and promotion could instead support these areas.
If we are thinking about the long-term evolution of the category rather than only short-term market share, these investments matter.
Responsibility also extends beyond manufacturers to raw-material suppliers, distributors, logistics providers and others who can contribute useful information and data.
We need collectively to create the evidence and make sure the science is there.
What Matters Most?
Joel Rubenstein:
We’ve covered several areas: responsible behaviour, the need for more science—both breadth and depth—and the importance of greater engagement.
If you had to choose one lever that matters most for the long-term future of harm reduction, what would it be?
Jack Li:
I think it’s mindset.
People working in this industry need genuinely to believe in what they are doing and in the potential of alternative products and harm reduction.
The evidence may take time to develop, but companies need a long-term mindset.
Shivam Bihani:
For me, it would be education.
Many people do not understand the differences between smoking and non-combustible nicotine products or what tobacco harm reduction means.
We need to educate people, but that education also needs to be backed by credible science.
That should be an important goal for the sector.
Tomasz Płaska:
I would shift the current narrative away from simply asking whether harm reduction is good or bad and towards discussing the net population impact of regulation.
We should assess regulations according to their actual health outcomes.
A ban itself is not necessarily a measure of success. The relevant question is whether regulation improves population-level health outcomes.
I believe shifting the discussion in that direction would be important both for the sector and for the public interest.
Closing Remarks
Joel Rubenstein:
We’ve covered a lot, and I think the issue is multifaceted.
For many companies here, especially smaller ones, there is a need to challenge perspective. I completely understand that businesses need to survive the next business cycle, and I don’t want to belittle that challenge.
But companies also need to look long term.
Changes to branding, formulation, investment in clinical research or consumer engagement may seem like small steps in the short term, but collectively they contribute to long-term viability.
I’ll answer the question I asked the panelists myself.
If I had a brand in one of these non-combustible categories, one of my greatest concerns would be a serious adverse event or an example of irresponsible youth-oriented behaviour becoming highly publicised and triggering a wider regulatory reaction.
One incident could have consequences extending beyond the individual company involved.
For that reason, I believe marketing, flavour profiles, brand names, targeting and communications need to be approached responsibly.
I’m not simply talking about what is legal or illegal. I’m talking about what is the right thing to do for the long-term future of the category.
If that isn’t controlled, I don’t think anything else matters.
Thank you all for attending.
