The American Dental Association (ADA) submits the enclosed comments concerning the Comprehensive Smokeless Tobacco Education Act of 1986, 16 CFR Part 307. The ADA supports strong warning labels as one means of discouraging use of smokeless tobacco by children and adolescents, which is very important as each year more than 800,000 young people in the United States experiment with spit (smokeless) tobacco. The warning labels should occupy at least 25 percent of the front of the package and be printed in black and white, which would be similar to actions already taken in Canada and Australia.