Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504 #16

Submission Number:
16
Commenter:
Lori Rotolo
Organization:
TFAC- Tobacco Free Action Communities
State:
New York
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504
As a local public health educator I feel it is necessary for the FTC to begin collecting information from e-cigarette marketers about their sales and marketing activities. The information gathered will useful to our organization, TFAC (Tobacco Free Action Communities) in order to assess the impact of and strategies around ENDS marketing, which then will inform evidence-based policies to address issues of concern. We use information and data collected by the FTC to inform and educate the public as well as policy makers, to counter the tobacco industry activities and improve public health. My work centers around the effect of point of sale marketing on tobacco use and the industry's continued efforts to recruit youth as their new "replacement" smokers. Retail tobacco marketing increases the likelihood that adolescents will initiate tobacco use, as well as thwarts cessation attempts by current users, by using promotional sales, price discounting, multi-pack discounts, give-aways and coupon marketing strategies. Studies have shown that cigarette consumption decreases as prices increase; and lower prices attract new users. There is a growing and disturbing trend of ENDS promotion and marketing to youth, particularly at the point of sale. While ENDS are fairly new to the market, they are a toxic, addictive product, and another form of tobacco. It is vital for residents, public health professionals and policymakers to know how marketing and sales affect the community, especially as it pertains to youth use of ENDS. Armed with the FTC report and data on ENDS marketing, I will be able to educate our community leaders about the significance of product price and the industry's marketing expenditures and it's ultimate affect on our community and population health risks and outcomes. It would be helpful for the FTC to differentiate by tobacco/ENDS manufacturer, product type (disposable vs. refillable), flavored vs. unflavored products, nicotine concentration levels, etc. in order to understand the industry strategy and the resulting marketplace. ENDS marketing mimics traditional cigarette marketing of the past and may have similar effects on the initiative of ENDS use by youth. The industry is likely to continue using the same marketing strategies for ENDS that were successful increasing cigarette sales and other tobacco products. ENDS promotion has increased dramatically in recent years and this advertising is effectively reaching youth and young adults, resulting in a rising popularity of ENDS among young people. It will be useful for the FTC to collect information on ENDS manufacturer expenditures on advertising to deter youth from purchasing or using ENDS products..