Docket ID: FDA-2014-N-0189; RIN: 0910-AG38
Electronic cigarettes are not tobacco products and should not be treated as such. Deeming them as tobacco is a grave error with deadly consequences for more than 40 million American smokers who will be denied access to an alternative that is more than 1,000 times safer than combustible tobacco.
The proposed deeming regulations would remove more than 99% of electronic cigarette (ecig) products from the market and deliver the entire ecig business into the hands of Big Tobacco, and sending the rest into extralegal markets. In the wake of historic declines in cigarette sales [1][2], Big Tobacco is not worried. They have already announced and celebrated the FDA-facilitated takeover of the entire ecig market [3][4][5]. In their Investor Day webcasts [4] Philip Morris effectively called FDA their “second pillar supporting our [...] business model.” Is this the image FDA and CTP want to project to the American public? A pillar of the Big Tobacco business model?
The financial pressures to stop or reverse the expansion of the ecig market and preserve the status quo of the tobacco trade are not solely coming from Big Tobacco. Big Pharma has publicly exposed their financial interests in an anti-vaping ad campaign [6]. State governments are also publically facing the reality that ecigs have a very solid chance of causing them to default on $96 billion worth of tobacco bonds [7], by spelling the end of TMSA payments. The thought of losing tobacco tax revenue does not sit well with any branch of government. In this game of political and commercial interests, I and 40+ million American smokers have become the pawns; our health and lives not even an afterthought, while Big Tobacco, Big Pharma, Big Government, and so-called “public health” groups pursue the billions flowing from our pockets into theirs thru the tobacco gravy train. FDA has an opportunity to fulfill its mandate and moral obligation and stand by the true stakeholders in the tobacco debate – the 40+ million American smokers whose health is at stake; and the millions of consumers of ecig products who have accomplished the most significant step towards avoiding tobacco-related illness by quitting smoking and switching to vaping.
Snubbing ecigs by deeming them as tobacco products would solidify FDA’s position as a pillar of the Big Tobacco business model at the expense of my health, public health, and the lives of all 40+ million American smokers.
[1] http://files.shareholder.com/downlo.../2014-17_RAI_increases_2Q14_profitability.pdf
[2] Reynolds American Inc.
[3] PMI.com Press Release
[4] Philip Morris Agenda
[5] https://www.media-server.com/m/instances/8hjnb6wm/items/29n825fv/assets/75ngrwuk/0/file.pdf
[6] http://www.amazon.co.uk/b?node=4933990031
[7] Decline In Smoking & Tobacco Bonds | Spinfuel eMagazine
Electronic cigarettes are not tobacco products and should not be treated as such. Deeming them as tobacco is a grave error with deadly consequences for more than 40 million American smokers who will be denied access to an alternative that is more than 1,000 times safer than combustible tobacco.
The proposed deeming regulations would remove more than 99% of electronic cigarette (ecig) products from the market and deliver the entire ecig business into the hands of Big Tobacco, and sending the rest into extralegal markets. In the wake of historic declines in cigarette sales [1][2], Big Tobacco is not worried. They have already announced and celebrated the FDA-facilitated takeover of the entire ecig market [3][4][5]. In their Investor Day webcasts [4] Philip Morris effectively called FDA their “second pillar supporting our [...] business model.” Is this the image FDA and CTP want to project to the American public? A pillar of the Big Tobacco business model?
The financial pressures to stop or reverse the expansion of the ecig market and preserve the status quo of the tobacco trade are not solely coming from Big Tobacco. Big Pharma has publicly exposed their financial interests in an anti-vaping ad campaign [6]. State governments are also publically facing the reality that ecigs have a very solid chance of causing them to default on $96 billion worth of tobacco bonds [7], by spelling the end of TMSA payments. The thought of losing tobacco tax revenue does not sit well with any branch of government. In this game of political and commercial interests, I and 40+ million American smokers have become the pawns; our health and lives not even an afterthought, while Big Tobacco, Big Pharma, Big Government, and so-called “public health” groups pursue the billions flowing from our pockets into theirs thru the tobacco gravy train. FDA has an opportunity to fulfill its mandate and moral obligation and stand by the true stakeholders in the tobacco debate – the 40+ million American smokers whose health is at stake; and the millions of consumers of ecig products who have accomplished the most significant step towards avoiding tobacco-related illness by quitting smoking and switching to vaping.
Snubbing ecigs by deeming them as tobacco products would solidify FDA’s position as a pillar of the Big Tobacco business model at the expense of my health, public health, and the lives of all 40+ million American smokers.
[1] http://files.shareholder.com/downlo.../2014-17_RAI_increases_2Q14_profitability.pdf
[2] Reynolds American Inc.
[3] PMI.com Press Release
[4] Philip Morris Agenda
[5] https://www.media-server.com/m/instances/8hjnb6wm/items/29n825fv/assets/75ngrwuk/0/file.pdf
[6] http://www.amazon.co.uk/b?node=4933990031
[7] Decline In Smoking & Tobacco Bonds | Spinfuel eMagazine
