Can heat-non-burn tobacco be "non-burn" and "smokeless"?

Abstract

Introduction: The EU Tobacco Products Directive (TPD, 2014/40/EU) clearly states that, in the case of novel products, its application depends on whether those products fall under the definition of a smokeless tobacco product or of a product for smoking

Heat-non-burn tobacco is a new product. Manufacturers of these products claim that, as no combustion process takes place, their products are smokeless and thus, the TPD is not applied to them

Methodology: Combustion principles are applied here to show that heat-non-burn products are not smokeless

Results: The transfer of energy to all organic compounds results in heating. After an energy threshold, which can be reached even at quite low temperatures, this organic compound is dissociated and the first radicals are formed. This initiation step occurs in either presence or absence of air. During the propagation step, which comes next, the radicals undergo decomposition and oxidation in the presence of air, while they are combined together to form heavier products leading to particulate matter, which is smoke, in the case of general or local oxygen lack. At the end, the radicals are combined together to form the final products (termination step). This mechanism is followed by all organic compounds under heating

The detection of carbonyls, which are intermediate products during the combustion of all organic compounds, and particulate matter in the products of heat-non-burn tobacco implies that combustion (burn) does occur in this product. Combustion leads inevitably to smoke and thus this product is not smokeless

Conclusions: The term heat-non-burn tobacco is not scientifically correct and is used ubusively. Heat-non-burn tobacco products are ‘burn” and not “non-burn” and cannot be “smokeless”