Comment from USC Tobacco Center of Regulatory Science (TCORS)

Summary: The University of Southern California Tobacco Center of Regulatory Science (USC-TCORS) argues that the draft guidance is too narrow because it fails to account for the sensory attributes (like cooling and sweetness) of flavors such as menthol, mint, and coffee, which can increase appeal to youth and non-smokers. They propose that the FDA should require the industry to provide evidence on these sensory characteristics and use standardized assessment methods in PMTAs to better evaluate public health risks.