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CASAA Submits Comment to FDA Regarding Nicotine Limits

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The U.S. Food and Drug Administration (FDA) has issued Tobacco Product Standard for Nicotine Level of Combusted Cigarettes, an advance notice of proposed rulemaking (ANPRM) seeking public comment for consideration in developing a potential nicotine product standard for combustible tobacco products. The FDA claims that “lowering nicotine to a minimally or non-addictive level could potentially save millions of lives, both in the near and long-terms.”

Because CASAA is a tobacco harm reduction organization, we generally do not take a position on regulation of combustible products. However, since CASAA also represents people who currently smoke who may in the future choose to use Tobacco Harm Reduction (THR) products, we submitted a comment on this ANPRM because we are concerned about the unintended consequences of dramatically reducing nicotine levels in combustible cigarettes and how that may actually harm smokers instead of reducing their risks.

CASAA’s concerns regarding lowering nicotine levels include:

  • An increase in compensatory smoking
  • Perpetuation of the myth that nicotine is what causes smoking-related diseases
  • Increase in black market sales
  • Lack of a clear regulatory path forward for low-risk products so that smokers have acceptable alternatives
  • FDA hinting of the possibility of even greater prohibition on other low-risk tobacco products by, for example, eliminating the sale of higher nicotine content liquid for e-cigarettes to prevent potential use in low-nicotine combustible cigarettes

CASAA’s full comment can be viewed here.