Some points you may want to consider for your comments:

• Lower-power vapor products require higher concentrations of nicotine in order to appeal to people who smoke and inspire them to switch completely away from combustion.
• Mandating lower nicotine levels in smoke-free alternatives actually protects the appeal of the most harmful products that rely on combustion. A similar sales ban on cigarettes that actually deliver more nicotine is not being proposed.
• The so-called “youth vaping epidemic” misrepresents prevalence of use among young people by focusing on the most eye-popping statistics and preys on the public’s misunderstanding of substance use.
• A low-nicotine mandate may pressure people to travel outside of the state to purchase regular strength closed-system products (i) not supporting local businesses, and (ii) imposing a hidden tax resulting from extra travel expenses. This rule may also inspire people to purchase and consume more e-liquid which is a similar hidden tax as it forces people to spend more money.
• People will compensate for low-nicotine delivery by consuming more material, exposing themselves to more risk (although still not even close to what they are exposed to by smoking). While some people choose to vape larger volumes of e-liquid, in this case, the UDOH will be making that choice for them.