To be sure, the FDA should prohibit the marketing of electronic cigarettes to youth. But a total ban on electronic cigarette advertising would be throwing away the baby with the bath water.

3. American E-Liquid Manufacturing Standards Association: "FDA should use the effective date of the final rule for the Deeming Regulations as the new "Grandfather Date" for e-cigarettes and e-liquid products and model the substantial equivalence requirements for these products based on the Section 510(k) pathway for medical devices."

The major purpose of regulating advertising in the first place is to prohibit companies from deceiving consumers. But by precluding companies from telling consumers the truth, the CAP's regulations actually ensure that consumers are deceived. There is no legal nor public health justification for this campaign of deception. It protects cigarette profits at the expense of the lives and health of UK citizens.

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