Comment from Hillfield Company on behalf of Geek Miracle Limited

Summary: Geek Miracle (HK) Limited opposes the Draft Guidance because it introduces a higher evidentiary burden for specific flavor categories rather than maintaining a uniform "appropriate-for-the-protection-of-public-health" (APPH) standard. The company argues that the current regulatory framework is already effective at reducing youth vaping and that flavor-specific requirements will reduce legal supply, discourage compliant submissions, and expand the illicit market.