Public Policy Resources

The undersigned organizations submit these comments in the above-designated docket concerning FDA’s draft guidance titled “Enforcement Policy for Certain Marketed Tobacco Products” (the “Draft Guidance”). The proposed policy would protect the financial interests of everyone in the supply chain at the expense of the health of the consumer. 

The undersigned public health organizations submit these comments on the above-listed tobacco product modified risk applications submitted for the IQOS heated tobacco product system. The subject applications should be denied for the reasons detailed in these comments.

ACS CAN appreciates the opportunity to provide comments to the U.S. Food and Drug Administration’s (FDA) on our shared priority of reducing death and disease caused by tobacco use.

The organizations signed below want to express as clearly as possible our views about what will be necessary to address e-cigarettes. We believe that FDA’s actions must address three core principles and that to be effective FDA needs to take action in four specific areas.

We write to bring to your attention numerous apparent violations of the Family Smoking Prevention and Tobacco Control Act (Tobacco Control Act) and the FDA’s deeming rule prohibiting the marketing, without a marketing order from FDA, of electronic cigarette products that were not commercially marketed as of August 8, 2016.

In its final Deeming Rule, the Food and Drug Administration (FDA) made the appropriate determination that there is no public health justification for exempting so-called “premium cigars” from the Rule. No data or other information has emerged since the final Rule was issued in May, 2016 that should cause FDA to reconsider that conclusion.

In order to protect kids from these products, FDA should publish a proposed, and then final, rule prohibiting characterizing flavors in all combusted and smokeless tobacco products as soon as possible.

On behalf of the American Cancer Society (ACS) and the American Cancer Society Cancer Action Network (ACS CAN), we appreciate the opportunity to provide comments on the Food and Drug Administration’s (FDA) draft concept paper on ‘Illicit Trade in Tobacco Products After Implementation of a Food and Drug Administration Product Standard.’

The Food and Drug Administration (“FDA”) has published and sought comments on a draft paper entitled Illicit Trade in Tobacco Products after Implementation of an FDA Product Standard. The document addresses the potential for development of an illicit market as a result of a number of different potential product standards, including but not limited to, those that would (1) impose a maximum level of nicotine in cigarettes and other combusted tobacco products at levels that would be insufficient to sustain nicotine addiction; and (2) prohibit the use of menthol in cigarettes and prohibit the use of characterizing flavors in other tobacco products.