Using a substance in a medicine does not, by itself, settle whether every consumer product containing it must be prohibited. Authorities should explain the relevant product rules, actual presentation and exposure. Consumers’ beliefs about an ingredient are not a substitute for a product-specific legal and scientific assessment.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

Oral CBD studies cannot simply be converted into a vaping verdict. Authorities should identify the inhalation and heated-emissions evidence supporting the proposed restriction, and explain how dose, formulation and exposure affect the conclusion. Where evidence is incomplete, a focused research and testing programme should be compared with a categorical ban.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

Precaution should be applied consistently. The circulated draft sets maximum concentrations for several other vape ingredients while proposing a cannabinoid prohibition. Authorities should explain why a substantiated limit, composition controls or other differentiated safeguards cannot address the identified cannabinoid risks. Different treatment needs a reasoned scientific justification.

Source: www.tabakfreiergenuss.org/wp-content/uploads/2026/10/Anlage-1-Entwurf-Reinform.pdf

Germany’s own law requires justification. Section 13(2) of the Tobacco Products Act permits ingredient restrictions insofar as necessary to protect health. Authorities should explain how the proposed blanket prohibition meets that requirement, alongside the heated and unheated ingredient-safety rule in section 13(1), rather than merely asserting that no alternatives exist.

Source: www.gesetze-im-internet.de/tabakerzg/__13.html

The real impact deserves a completed assessment. A finished-product ban can also reduce demand for ingredients, filling services, hardware and packaging. The circulated draft leaves business and administrative cost estimates unfinished. Authorities should assess supply-chain effects, consumer consequences and feasible alternatives before taking a decision with lasting effects.

Source: www.tabakfreiergenuss.org/wp-content/uploads/2026/10/Anlage-1-Entwurf-Reinform.pdf

Transparent procedure strengthens public trust. The authoritative draft, notification record, supporting risk evidence and responses to objections should be accessible. EU technical-regulation notification is not, by itself, proof that a restriction complies with every applicable EU rule. Parliament should obtain a reasoned examination, not rely on assumptions about procedural approval.

Source: eur-lex.europa.eu/eli/dir/2015/1535/oj/eng

A focused pause is a responsible request. Existing binding safety rules should remain in force while the disputed additional prohibition is reviewed. A sell-through period may ease the immediate disruption, but does not answer whether the ban itself is necessary. Reviewing the evidence and alternatives before implementation can prevent avoidable harm to consumers and accountable businesses.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

Adults deserve informed choice. Clear risk information, age restrictions and enforceable quality standards allow adults to make responsible decisions. Before removing that choice through a blanket CBD vape ban, authorities should explain why these safeguards cannot adequately address the identified risks.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

Consumer protection should target the actual risks. Independent ingredient and emissions testing, contamination limits, traceability and action against misleading claims should be compared with a blanket ban. Authorities should publish their evidence and explain why differentiated safeguards would be insufficient.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

A ban can remove accountable suppliers without removing demand. Consumers who continue seeking these products may turn to less transparent sellers, with greater risks of mislabelling, contamination or untested substitutes. The assessment must consider what people will actually consume after a ban, rather than judging its benefits only on paper.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

Germany must respect the same EU principles as France. In Kanavape (C-663/18), the Court required a sufficiently established health risk and a proportionate justification for restricting cross-border CBD trade. Germany’s proposed prohibition should be scrutinised against those principles, including whether less restrictive safeguards can protect consumers.

Source: eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62018CJ0663

CBD should be assessed on its own evidence. A broad cannabinoid category does not establish that every included substance has the same properties or risks. A defensible decision must explain the evidence for each affected substance and exposure, rather than treating a shared label as sufficient justification for a blanket ban.

Source: www.openpetition.eu/pdf/blog/pause-germanys-proposed-cbd-vape-ban-and-review-the-evidence_complete-scientific-and-legal-background-english_1791652852.pdf

The CBD evidence is more differentiated than a blanket ban suggests. A 2023 meta-analysis identified high doses and concomitant antiepileptic medicines as liver-risk factors; no liver-injury cases were reported in adults receiving under 300 mg/day in the included evidence. This does not prove vaping safety, but supports examining dose and context rather than assuming identical risk at every exposure.

Source: pubmed.ncbi.nlm.nih.gov/36912195/

Misleading health claims should be challenged directly. Authorities should explain why removing unlawful claims, correcting packaging and enforcing presentation rules would be insufficient before prohibiting all affected products, including those making no such claims. The assessment must distinguish an ingredient’s presence from the way a particular product is marketed.

Source: eur-lex.europa.eu/eli/dir/2014/40/2023-10-23/eng