Vapor Technology Assoc. Issues 74 page Response to FDA on value of flavors
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The Vapor Technology Association (VTA) did not hold back in its recent comments to the U.S. Food and Drug Administration’s rulemaking proposals to regulate e-flavors. Distributed electronically July 19, VTA released a 74-page report emphasizing the potential benefits of the industry.

Beginning on page 51, VTA responds to 25 of the most-asked questions surrounding the act of vaping.

Here are condensed versions of the top questions and answers:

Q: What is the role of flavors (other than tobacco) in tobacco products?

A: The role of non-tobacco flavors in electronic nicotine delivery systems (ENDS) products cannot be viewed through

the same policy prism as characterizing flavors in other tobacco products, including cigarettes. Unlike any combustible tobacco product, the naturally occurring flavor of e-liquids prior to the introduction of flavorings is not tobacco because ENDS e-liquids do not contain tobacco.

Q: How do flavors act as a “gateway” to forming a nicotine habit?

A: The theory of a supposed “gateway” effect is entirely unsubstantiated and provides no basis to limit access to non-tobacco flavored ENDS products.

 Q: Do flavors help adult cigarette smokers cut back or quit?

A: Non-tobacco flavored ENDS play a critical role in smoking cessation and harm reduction efforts and restricting access to them would leave millions of current and future adult smokers without a proven tool for moving down the continuum of risk to less harmful products. The existing reliable scientific literature trends strongly in support of the conclusion that the availability of a wide range of flavors—and particularly non-tobacco flavors—plays a critical role in encouraging switching and cessation among existing smokers and preventing relapse to combustible cigarettes.

Q: From the point of views from the three main groups of potential vapers, youth, young adults and adults, what is the perceptions of developing a flavor addiction?

A: There is no scientific basis to enact any product standard that would treat tobacco flavored ENDS any differently than non-tobacco-flavored ENDS, including on the faulty premise that non-tobacco-flavored ENDS are more attractive to youth and young adults.

The complete release can be seen here.

Enjoy the read – and the knowledge.