Comment from CDC Foundation
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Summary: The CDC Foundation submitted comments providing research data from their TEEN+ Study to support the FDA's draft guidance on flavored electronic nicotine delivery systems (ENDS). They argue that flavored e-cigarettes are highly appealing to youth and young adults, contribute to nicotine dependence, and that the FDA should consider these risks when reviewing marketing applications.
Attached please find the CDC Foundation's comments to the U.S. Food and Drug Administration (FDA) on FDA’s draft guidance, “Flavored Electronic Nicotine Delivery Systems (ENDS) Premarket Applications—Considerations Related to Youth Risk.” In this comment and appendix, we provide findings from the CDC Foundation’s Tobacco Epidemic Evaluation Network (TEEN+) Study of youth and young adults, our analyses of tobacco product retail sales data and our analyses of other related data.
As described in more detail in the attached comment and appendix, CDC Foundation analyses show:
1.A large proportion of youth and young adults currently use e-cigarettes in flavors other than tobacco (including mint, menthol, and other flavors). Considerable proportions of youth and young adults, regardless of their tobacco use, think they would like these e-cigarette flavors. Among youth and young adults who use e-cigarettes, substantial proportions show signs of nicotine dependence.
2.Youth and young adult brand preferences shift over time. Young people use a wide variety of brands, including brands without FDA marketing authorization.
3.E-cigarettes with technological features appeal to youth and young adults.