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In relation to the recent announcement from Commissioner Gottlieb, we share the FDA’s concerns around youth access to vapour products and we welcome the priority that he has given to this matter. However, in relation to his proposals on menthol cigarettes, the science today does not support treating them differently from other cigarettes.

Regarding youth access to vapour products:

• ��We have robust measures in place that demonstrate our commitment to marketing which does not target youth and have also communicated to the FDA that we will be applying additional measures.
• ��We fully support third party age verification of e-commerce and we already have this in place.
• ��We are also instituting an enhanced programme with all of our contracted retailers to drive compliance with underage sales laws.
• ��We would welcome similar measures being adopted industry-wide.

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We also share the FDA’s concern regarding balancing the importance of encouraging adult smokers to consider potentially reduced-risk alternatives to cigarettes – like vapour products – whilst ensuring that youth do not use them.

Whilst research shows that flavours play an important role in an adult smoker’s transition out of smoking, we understand the FDA’s concern that some flavours can play a role in increasing youth appeal. That is why we are happy to work with our nearly 200,000 contracted retail stores to address youth access to vapour products.

In relation to these vapour proposals we encourage the FDA to introduce enforceable regulations as soon as possible. Further, we encourage the FDA to bring forward the PMTA deadline earlier than 2022.

In relation to menthol cigarettes, while we will continue to engage with the FDA on its proposed plans, it is important to note that:

• ��When the FDA first examined menthol in 2013, the published science did not support regulating menthol and non-menthol cigarettes differently and the published science since then has not changed this situation.
• ��While some consumers may prefer menthol cigarettes, the science has not demonstrated that menthol leads to higher levels of initiation, greater dependence, reduced ability to quit or increased health risk.
• ��Any regulation of menthol in cigarettes must be done through the established comprehensive rule-making process and must be based on a thorough review of the science while considering the unintended consequences of any rule. Failing to do so would mean any such action would not withstand judicial review.
• ��Regulating menthol cigarettes (which comprise around a third of the market) differently to non-menthol cigarettes will increase the illegal market, fueling more criminal activity, adding further challenges to criminal and social justice issues. Further, as an illegal market in menthol cigarettes will increase, youth smoking access will increase.

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We will continue to work closely with the FDA on these important issues, including participating in a thorough science-based review to address the use of menthol in cigarettes. At the same time, we will continue to deploy our best efforts to curb youth access to vaping and tobacco products.