3. Those products are real tobacco cigarettes.

The FDA is undermining decades of public health efforts to underscore the ubiquitous danger of cigarette smoking and the lack of value of even major design changes, such as filters and lower yields. By doing so, the agency is negating any positive effects of its own anti-smoking media campaign.

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.

What the FDA is stating is that it does not believe that it would be any worse for individual X to resume cigarette smoking than for her to remain an ex-smoker by continuing to vape. The FDA is stating that it is aware of no evidence to suggest that returning to cigarette smoking would be an unwise decision for this individual.

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