3. The regulations require pre-approval or substantial equivalence determinations of almost all existing electronic cigarette products.

While the deeming regulations pretend to acknowledge that there is "a continuum of nicotine-delivering products" in terms of their health risks, the truth is that the agency fails to acknowledge that the most hazardous product along that continuum - cigarettes - are any more hazardous than the least dangerous product (non-tobacco electronic cigarettes).

Who should fund it?

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