Marlow hits on all points and in a way that chastises the FDA on almost every point. Well worth the time to read.
Some that got my attention:
"The proposed rule pushes e-cigarette manufacturers
to focus efforts toward developing new flavors, packaging, and other attributes unrelated to improved
public health. The proposed rule might also promote combustible
tobacco use because manufacturers
will be unable to market e-cigarettes as safer alternatives or even state that they don’t contain tobacco. It
is likely that fewer smokers will quit or reduce cigarette consumption.
Public health will worsen to the
extent that e-cigarettes are a safer alternative to tobacco cigarettes."
And a good take on the consequences if the proposed deeming becomes the final rule:
• Suppressing the e-cigarette market can be devastating to product innovation. Manufacturers
will be unable to market their products as safer alternatives to cigarettes to smokers who are seeking
harm reduction. The proposed rule pushes manufacturers to enlist other marketing angles,
such as flavors, price, convenience, and appealing packaging. Public health worsens to the extent
that manufacturers steer away from developing new products aimed at helping smokers reduce or
quit smoking. In effect, the proposed rule removes much of the profit out of developing safer and
more effective harm-reduction products and redirects resources toward other attributes unrelated
to improved public health.
• Suppressing the e-cigarette market is likely to promote FDA-approved NRT. This effect might
improve public health if NRT is more effective than e-cigarettes in promoting lower consumption
and quitting by smokers. However, as discussed above, the efficacy of NRT is debatable. Moreover,
the literature suggests that smokers find e-cigarettes helpful. The FDA needs to explain why
favoring the NRT industry promotes public health in light of this evidence.
• The e-cigarette industry is likely to become less competitive as costs of bringing products
to market and other costs rise. Limiting competition allows e-cigarette manufacturers to gain
market power, thus raising prices, curbing consumption and limiting consumer choices. Larger
firms carry an unfair advantage due to greater financial and legal resources, thus again limiting
competition at the expense of consumers. Raising prices of e-cigarettes for smokers who might be
interested in quitting is unlikely to promote public health when e-cigarettes are effective harm reduction
tools.
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There's much more, and again, worth taking the time to read it. Thanks Bill - might not have run into this elsewhere.