Comment from The Coalition for Safer Alternatives

Summary: The Coalition for Safer Alternatives, a public health advocacy organization, opposes the Draft Guidance because it creates a flavor-tiered evidentiary burden without statutory authority and sets practically unachievable study requirements. They argue that the guidance relies on outdated youth use data, ignores the benefits of flavored ENDS for adult smokers, and risks expanding the illicit market by making the legal pathway for flavored products functionally unattainable.