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In other words, the anti-smoking movement is violating the first principle of public health practice by doing public health harm.

I cannot think of a regulatory provision that would be more favorable to combustible cigarettes than to ban any potential competitor products that are not made from tobacco and do not involve combustion from informing consumers that these products are safer alternatives to smoking. This is literally a huge gift to the combustible cigarette market and therefore, it is devastating to the public's health. It is going to increase disease and death. This is absolutely the opposite of what the FDA should be doing in these regulations.

All in all, the deeming regulations are a disaster. However, they are not as much of a disaster as they could have been. The positive side is that internet sales, marketing to adult consumers, and flavors are still allowed and that no products will immediately be taken off the market. The negative side is that new products will require pre-approval, virtually every product on the market will require a substantial equivalence determination (if not a new product approval), and that manufacturers will be forced to implicitly lie about the intended purpose and relative safety of the product by not being allowed to correctly point out that these products are much safer than tobacco cigarettes.

Second, the advocates want the same type of marketing and other restrictions that apply to cigarettes to apply equally to e-cigarettes. They are afraid that defining electronic cigarettes honestly might put a damper in those plans.


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