IPCPR Submits Comment in Response to FDA Draft Guidance

Earlier this week, IPCPR submitted a comment to the Food and Drug Administration (FDA) Draft Guidance: “Modifications to Compliance Policy for Certain Deemed Tobacco Products”, which proposes to modify the current compliance policy in several significant respects for certain electronic nicotine delivery systems (ENDS) and flavored cigar products.

The IPCPR position states that:

  • The current FDA approach to flavored tobacco products will not achieve the desired outcome of keeping tobacco and nicotine products out of the hands of teenagers;
  • The definition of “flavors” is entirely too vague and is therefore impossible to understand or comply with;
  • The change of product sell through time (for those products that do not meet the standards) is much too short at 30 days, as premium products average over 100 days to sell.