Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504 #21

Submission Number:
Diane Moore
Tobacco Free Action Communities
New York
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504
I am writing to comment on the FTC's proposed study of electronic cigarettes marketing and sales. The information gathered will be very useful to me and my colleagues. As the coordinator of a youth tobacco prevention program, I work with young people to educate communities about the problem of tobacco use, including how industry marketing drives that use. I currently use data supplied by the Federal Trade Commission (FTC) to educate the community about tobacco industry marketing. Additionally, it allows me to inform policymakers who are developing evidence-based policies that counter industry activities and will protect the community, especially children from the dangers of addiction. I would like to stress how important it is for the study to focus on all forms of electronic nicotine delivery systems (ENDS), not just those that resemble cigarettes. I hear from community members, schools, youth, parents, etc. that the prevalence of ENDS is of great concern to them. As my work centers on the effect of point of sale marketing on tobacco use, I am especially interested in data on marketing expenditures, and various media used by product marketers. It will be useful as I plan public health initiatives designed to counter industry activities that increase the use of these addictive and detrimental products. Tobacco point of sale marketing has been an effective industry tactic to recruit new "replacement" smokers, most of which are youth. Retail tobacco marketing increases the likelihood that adolescents will initiate tobacco use. Current ENDS marketing mimics traditional cigarette marketing of the past and may have similar effects on initiation of youth ENDS use. Among youth and young adults, there is high awareness of ENDS advertising, particularly at the point of sale. At the same time there has been a sharp increase in the use of ENDS among this age demographic. While ENDS are relatively new to the market, they are a toxic, addictive product and are yet another form of tobacco (with nicotine derived from tobacco leaves). Therefore, it is imperative for community members, public health professionals and policymakers to know how marketing and sales affect the community, particularly as it pertains to rising youth use of ENDS.