China arrives at COP11 of the WHO Framework Convention on Tobacco Control (FCTC) with figures that embarrass any health authority, with more than 300 million smokers and around one million annual deaths attributable to tobacco, while its state industry maintains a structural influence on domestic regulation. At the same time, Europe (and Spain in particular) report an increase in seizures of illegal electronic cigarettes, with the majority originating in Chinese supply chains. The summit (November 17-22 in Geneva) measures not only the ambition of the treaty, but also its ability to manage conflicts of interest of a key actor.
The Chinese State occupies “both sides of the table”, as it is part of the FCTC and, at the same time, owner of the largest conglomerate in the sector, the China National Tobacco Corporation (CNTC), under the umbrella of the State Tobacco Monopoly Administration (STMA). Academic literature documents that the STMA controls “all aspects” of the market, a design hardly compatible with Article 5.3 of the FCTC, which requires protecting public policies from industry interference.
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The industrial epicenter of vaping
Reference organizations describe in China a picture of inconspicuous health warnings, low taxation and irregular compliance with smoke-free environments, factors that slow down the reduction in consumption. The human toll continues to be enormous in a country that concentrates almost a third of the planet’s smokers.
China is the global factory in the sector: different sources place its production share of vaping hardware at around 90%, with its epicenter in Shenzhen. This manufacturing muscle feeds, in addition to the legal market, illicit circuits that evade health and fiscal controls in third countries.
Europe tightens rules… and the black market emerges
The EU and the European Anti-Fraud Office (OLAF) have added the illegal trade in e-cigarettes to their priority radar. The European agency points to seizures and the appearance of unauthorized production units in several member states, and promises more customs cooperation.
In parallel, Spain registers frequent operations, since in Seville, the Civil Guard intervened 171,407 devices in 2024; This year, points of sale with more than 55,000 expired or unlabeled units have been dismantled.
The United Kingdom has banned single-use vapes since June 1, 2025, with a sanctioning rollout that seeks to contain sales to minors and electronic waste, although doubts persist about their effectiveness without customs enforcement.
France also approved the ban on disposables at the beginning of the year. These movements, celebrated by the anti-smoking movement, coexist with warnings about the risk of diverting demand to illegal channels if they are not accompanied by border controls and online surveillance.
Customs and the FDA have carried out the largest operations against unauthorized e-cigarettes in 2024-2025, with millions of units seized and valuations exceeding $80 million; most shipments left from China. The cases illustrate the logistical scale of the phenomenon and its ability to reorient routes towards European markets when the siege in the United States tightens.
What is at stake at COP11
The Geneva meeting will not only address minimum taxation, illicit trade and covert advertising; also the fit of new nicotine products. The WHO maintains a stance of maximum caution on vaping, while influential reports in the United Kingdom (Public Health England and the Royal College of Physicians) position e-cigarettes as substantially less harmful than combustible tobacco, with potential for cessation, always with strict regulation and kept away from minors. The decoupling between regulatory approaches makes consensus difficult and leaves room for reluctant actors (China among them) to slow down progress.
The regulatory reinforcement prepared by the Government and the regional sanctioning push need to be accompanied by three fronts: customs intelligence on parcels and ports, inspections in distribution chains and real traceability of the product. The seizure figures and the focus of OLAF anticipate that, without this triangle, the void will be occupied by cheap and non-compliant remittances.