2. Those products are not electronic (fake) cigarettes.

My point is that this appears to be a deliberate attempt to mislead the public. It is not consistent with just being a mistake, an issue of a differing interpretation of study results, or a lack of awareness of the study limitations.

The Tobacco Control Legal Consortium (TCLC) is urging the public to write to the FDA and encourage the agency to strengthen the proposed deeming regulations on electronic cigarettes. In a set of provided by the TCLC, the Consortium attacks the 24-month grace period for the submission of substantial equivalence or new product applications by electronic cigarette products, calling for the removal of this grace period:

All three of these entities have offered common sense advice with which I wholeheartedly agree. In fact, this advice may be the single most important change that I recommend in the proposed deeming regulations.

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