Dear Sir or Madam,
My name is Edward Longe, and I am a Policy Manager at the American Consumer Institute. The American Consumer Institute is a 501(c)(3) non-partisan, educational, and public policy research organization with the mission to identify, analyze, and project the interests of consumers in selected legislative and rulemaking proceedings.
We share the FDA’s view that disincentivizing the use of harmful combustible products is in the interest of public health, but are deeply concerned that the prohibition of flavored menthol products is not adequately paired with measures to help smokers transition to less harmful alternatives and ultimately help them cease smoking. By failing to provide consumers with an alternative path, we believe the Food and Drug Administration is not empowering smokers with the tools necessary to stop the harm caused by tobacco use. We are also concerned that a prohibition on flavored menthol cigarettes will force consumers to purchase unsafe and unregulated products on the black market. This will not only lead to poorer public health outcomes but could see further criminalization among African-Americans who use menthol cigarettes at higher rates than other demographic groups.
As the Food and Drug Administration moves forward with the rulemaking, we urge the agency to consider measures, including allowing greater access to electronic cigarettes and non-combustible tobacco products, that have been scientifically shown to help smokers quit and remain abstinent. In approaching public health questions in a way that follows the science as opposed to ineffective prohibitions, we believe the Food and Drug Administration would be better placed to meet its mission of protecting public health.
We look forward to working with you in crafting a regulatory environment that incentives Americans to ultimately quit and remain smoke-free.
Edward J. Longe