The Foundation for a Smoke-Free World (the Foundation) shares the concerns of the US Food & Drug Administration (FDA) about the rising rates of vaping among American youth. We are encouraged by the proposed actions of the FDA in their recent statement to prevent use of harmful tobacco and nicotine products by youth, while allowing adult smokers to use reduced harm products as smoking cessation tools. However, we believe that the policy recommendations announced by the FDA today may also inadvertently restrict access to valuable new technologies that offer important harm reduction options to millions of adult smokers who have tried to quit smoking but failed to do so.

The FDA’s planned actions are aligned with the Foundation’s mission to end smoking in this generation through the elimination of cigarettes and other combustible tobacco products worldwide. The FDA acknowledges that flavored electronic nicotine delivery systems (ENDS) (menthol- and mint flavored) are important tools for adult smokers as they transition away from cigarettes. The Foundation supports the FDA-proposed ban on these flavors in cigarettes and cigars, as the latter are gaining popularity among youth, while retaining these flavors in ENDS. We also see the wisdom of the FDA’s intention to “monitor the rates and use patterns among youth and adults for these products.” Smoking-cessation initiatives must be evidence-based and need to rely on continually updated data.

However, a campaign against other flavors in vaping products and heated tobacco products could limit effective use of these new technologies as smoking cessation tools for current adult smokers. The body of research showing the benefits of harm reduction from vaping devices compared to traditional cigarettes continues to grow, and we now see that flavors in addition to menthol and mint play an important role for adult smokers in their struggle to quit smoking (please see Working Paper 23865 from the National Bureau of Economic Research). Limiting access to flavors other than tobacco, mint, and menthol could impede the willingness of adult smokers to seek them as harm reduction options relative to combustible tobacco products.

We also believe that more stringent age verification measures must be implemented to prevent access to youth while allowing adult smokers to access flavored products and new nicotine technologies as effective harm reduction and smoking cessation tools.

The Foundation is encouraged by the FDA’s intentions to support adult smokers as they seek options to help them quit smoking while keeping combustible tobacco products and other nicotine products out of the hands of children. We encourage the FDA to seek actions that are not detrimental to the millions of adult smokers who wish to quit. The Foundation welcomes a discussion with the FDA to outline practical and effective solutions to achieve these objectives.