Editor’s Note: The comments of NACS The Association for Convenience and Fuel Retailing in response to the FDA’s Advance Notice of Proposed Rulemaking (ANPRM) on menthol in cigarettes are attached here. The Conclusion of NACS comments to FDA are reprinted below.
NACS encourages the FDA to undertake a thorough analysis of the potential for an illicit market, its potential size and the degree to which it would impact public health and jobs. We hope that the FDA will not be satisfied with simply receiving responses as part of the ANPRM process. Instead, we urge the FDA to assemble the responses of NACS and others to develop a robust research agenda into the existence today of illicit markets, the impact on youth smoking, the ingredients in counterfeit cigarettes and other issues.
There is a very real fear that banning menthol in cigarettes will worsen today’s unregulated and unhealthy illicit market. Thank you for your time.