Comment from Campaign for Tobacco-Free Kids on behalf of 73 public health, medical, civil rights and community organizations

Summary: A coalition of 73 public health, medical, civil rights, and community organizations opposes the Draft Guidance, arguing that it creates a pathway for authorizing flavored ENDS products that pose substantial risks to youth. They specifically argue that the FDA's categorization of certain flavors like menthol and mint as "lower risk" is flawed because it fails to account for shifting youth preferences, the toxicity of flavors, and the history of menthol's appeal to young people.