From there, Juul proceeded to describe how its device works and the potential health benefits it presents smokers who are looking for an alternative to combustible cigarettes. The company mentions how the FDA itself has acknowledged to some degree how ENDS are potentially less harmful than combusted cigarettes. It gets into how flavors have been shown to play a role in helping adult smokers switching to ENDS like Juul. The company references research that shows that adult smokers made the switch to e-cigarettes due to the variety of flavors available to them and how many opted for non-tobacco flavors to use with their ENDS. The variety of flavors prevented many smokers from going back to combustible cigarettes, the company says.
“Juul Labs is planning future research in this area, which will drill down on which user demographics favor certain flavors and provide a stronger understanding of whether any flavors might be particularly attractive to adult vs. non-adult users,” the company revealed in its submission.
Juul advises the FDA conduct more research on flavors before issuing a categorical restriction. It also warns that regulating or restricting flavors could have an negative consequence such as creating a gray market, as happened following Ontario’s menthol cigarette ban.
“If FDA chooses to restrict the use of menthol in combusted tobacco, in order to transition menthol smokers to potentially less harmful products, flavors should be continued to be allowed in alternative products as an “off-ramp,” as was seen after menthol cigarettes were banned in Ontario,” advised Juul in its submission.
Among Juul’s other suggestions were to use the premarket submissions and the ingredient listing process to evaluate flavors on a product-by-product basis, focus resources on youth access and youth-orientated marketing, and to consider science-based purity standards for ENDS flavor ingredients.
You can read Juul’s full submission to the FDA by clicking here. For all the latest news from Juul, visit juul.com.