Comment from Coalition of Manufacturers of Smoking Alternatives (CMSA)

Summary: The Coalition of Manufacturers of Smoking Alternatives (CMSA), a trade group representing tobacco manufacturers, supports the issuance of the draft guidance but urges the FDA to revise it to better balance the potential benefits of flavored ENDS for adult smokers against the declining risks to youth. They argue that the current draft overestimates youth risk and fails to account for the illicit market, requesting more clarity on evidentiary expectations and the inclusion of post-market surveillance.