Additional Comments submitted to FDA re Draft Concept Paper: illicit Trade in Tobacco Products After Implementation of a Good and Drug Administration Product Standard

Given the many legal and practical hurdles, it is unlikely that any sustainable, large-scale illicit market in non-complying cigarettes could emerge in response to an FDA rule to minimize nicotine levels in cigarettes and other smoked tobacco products (or in response to any other FDA tobacco product standard), Nevertheless, to maximize the public health benefits from any such rule, and provide a direct counter to likely industry scare tactics about illicit trade, FDA should take reasonable steps to make the emergence of any illicit market in non-FDA-complying cigarettes even more difficult and unlikely. Some possibilities follow:

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