For Sake of Public Health, FDA Should Not Ban E-cigarette Flavors

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Food and Drug Administration (FDA) Commissioner Scott Gotlieb, a medical doctor and cancer survivor, has had a long-term interest in tackling tobacco-related diseases. But unfortunately he’s on a path that will, perversely, be a disaster for the very people he wants to help.

Specifically, he has his agency considering a proposal to ban all flavored tobacco, including flavors for less harmful e-cigarette devices (read CEI’s public comment on the issue here). While predictably sold as a means of protecting children from becoming attracted to these products, such a ban will do more harm than good for smoking cessation efforts.

Smoking is still one of the leading causes of preventable death around the world. In the U.S. alone, over 16 million Americans suffer from smoking-related diseases and half a million die each year as a result of health effects arising from their habit. But, instead of embracing all avenues that could reduce this health burden, many within the public health profession stubbornly cling to an “abstinence only” approach. 

At this point, no credible researcher can deny that e-cigarettes are significantly less harmful than smoking, simply because of the fact that, unlike traditional cigarettes, e-cigarettes have no combustion. Yet anti-vaping advocates continue to push government to regulate these two different products the same way. They justify this based on the unproven hypothetical that e-cigarettes, especially candy- and fruit-flavored varieties, attract adolescents who would otherwise have never smoked. Their anxiety about this so-called “gateway effect” has no basis in reality or research.

Based on the U.S. government’s own evidence, tobacco use among adolescents has declined faster since e-cigarettes came to the market. Furthermore, despite claims that youth vaping is an epidemic, the government’s own data shows that e-cigarette use among teens has been declining since 2015. In fact, among high schoolers e-cigarette use has dropped an impressive 30 percent, despite the proliferation of both e-cigarette devices and flavors since 2015.

Flavors don’t attract children: Despite claims that sweet and candy-like e-cigarette flavors attract non-smoking teenagers to initiate use of electronic cigarettes, the evidence indicates that e-cigarette flavors hold little appeal to nonsmoking adolescents. In small 2015 study researchers found that flavors had no significant appeal to teens. Though statistically insignificant, the study found that the flavors that teens expressed the greatest preference for were actually “classic tobacco” and “single malt scotch.” This might indicate that when adolescents are interested in flavors, it is not the stereotypical “kid-friendly” varieties, but rather the more seemingly-adult flavors that are most attractive.

More importantly, if vaping were really the “gateway” to nicotine addiction some advocates believe, we should expect to see smoking increase with the rise of e-cigarette popularity. However, the opposite has happened. Youth smoking has plummeted to the lowest levels ever recorded, falling by half between 2011 and 2016. Similarly, while the decline in adult smoking plateaued between 2006 and 2008, after 2009 adult smoking began declining again, reaching the lowest levels ever by 2015.

Not only did e-cigarettes not stop the decline in smoking, there is evidence that e-cigarettes may have contributed to greater reductions in smoking.

Flavors help adult smokers: While nonsmoking teens may not be interested in flavors, the 2015 flavor study did find that interest in flavors was higher among adult smokers and even more so among adult e-cigarette users. While these groups rated “classic tobacco” as the most appealing, it was closely followed by “menthol” and “vanilla bean.” Though considered appealing only to children, the adults also reported a significant interest in the fruit and candy options, like “butter crunch” and “cotton candy.”

Earlier survey data indicates that the variety of available e-cigarette flavors plays an important role for adults, not only in their wiliness to try e-cigarettes as a smoking-cessation tool, but in their ability to sustain their quit-attempt. A survey of e-cigarette users in 2014 found that only 22 percent used a single flavor and only 15 percent cited “tobacco” as their primary flavor choice. 

Another 2014 survey of more than 4,500 adults e-cigarette users found that tobacco seemed to be the preferred flavor for smokers who had recently switched to vaping, while longer-term ex-smokers preferred non-tobacco flavors. The majority of these vapers reported liking a variety of flavors (noting that using a single kind tended to “blunt” the flavor) and that flavor variety was crucial to their ability to stay smoke-free. Most importantly, the study found that the number of flavors regularly used by e-cigarette consumers was independently associated with complete smoking abstinence.

Just this month, a new study added to these results, finding that smokers are increasingly likely to switch to e-cigarettes with a non-tobacco flavor and those that started with tobacco flavor more likely to switch to non-tobacco flavors over time.

The FDA should reject a vape flavor ban. All the existing evidence indicates that limiting flavor variety in e-cigarettes will have no effect on nonsmokers—young or old. However, it would significant reduce e-cigarettes’ attractiveness to existing smokers who might consider such devices as a means of reducing or quitting smoking. Since there is no doubt, even among the most strident anti-vaping advocate, that e-cigarettes are less harmful than smoking (though perhaps not risk-free), the FDA should recognize that banning e-cigarette flavors could only have a net negative affect on public health and reject such proposals.