Thus, it appears that cigarette filters did produce a small but measurable decline in cancer risks associated with smoking, while further design changes that lowered tar levels did not. In other words, there is evidence that filtered cigarettes produce lower cancer risks than non-filtered cigarettes. However, within the filtered cigarette category, there is no evidence that low-tar cigarettes confer any reduced cancer risk.

"It is not known how much nicotine or other potentially harmful chemicals are inhaled by users, nor is it known whether e-cigarette use may lead to use of other tobacco products. Neither are the benefits of using e-cigarettes over traditional products known."

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."

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