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- Nicotine Next (JUUL Labs Reg Intel) - Vapor and Nicotine Regulatory Intelligence Insights for November 11, 2024
Nicotine Next (JUUL Labs Reg Intel) - Vapor and Nicotine Regulatory Intelligence Insights for November 11, 2024
Deep Dive - Understanding Excess Lifetime Cancer Risk (ELCR)

Welcome to Nicotine Next, the premier source for regulatory intelligence and surveillance in the rapidly evolving nicotine product landscape. The mission is to provide timely, in-depth insights on regulatory compliance challenges, industry innovations and policy shifts impacting e-cigarettes, tobacco, and novel nicotine products worldwide. By delivering expert analysis and actionable information, Nicotine Next empowers stakeholders to stay informed and navigate the marketplace of the future.

Recent Regulatory Intelligence Recap
Key Developments:
1. Regulatory & Policy:
Multiple countries (UK, Gibraltar, Jersey) announcing plans to ban disposable vapes
New tax measures being implemented on vaping products in UK, Poland, and Italy
France announcing plans to ban nicotine pouches
FDA updating import alerts and warning against "smart" e-cigarettes
2. Market Performance:
Altria Q3 revenue slightly down (-0.4%) to $6.3B, with NJOY gaining market share
Japan Tobacco (JT) reporting Q3 net profit down 11.5% YoY to $900M
BAT Malaysia showing positive results with 14% profit increase driven by Vuse sales
Turning Point Brands reports increased sales and profits.
Haypp Group experiences a 25% rise in sales.
3. Illicit Trade:
Multiple reports of illegal vape seizures across countries
Growing concerns about black market following flavor bans
The Philippine Finance Department estimates a $900 million annual impact from tobacco and e-cigarette smuggling, with recent seizures valued at $14 million.
Key Research Themes:
1. Health Impact Studies:
New research on vaping's effects on cardiovascular health
Studies on nicotine's impact on brain development
Research on e-cigarette use in specific populations (older adults, youth)
2. Behavioral Research:
Multiple studies on quitting behaviors and cessation effectiveness
Research on social media's influence on vaping behavior
Studies on stress, anxiety, and depression related to e-cigarette use
Active Focus Areas:
Youth vaping prevention
Smoking cessation programs
Nicotine delivery systems evaluation
Behavioral interventions for quitting

The Modified Risk Claim:
Using General Snus instead of cigarettes puts you at a lower risk of mouth cancer, heart disease, lung cancer, stroke, emphysema, and chronic bronchitis.
The FDA granted an 8-year authorization renewal (versus original 5-year) based on:
Well-established health risk evidence
Continued low youth initiation risk
Demonstrated appropriate consumer understanding
Fulfilled post-market requirements
Need for longer assessment period of switching behavior
Consumer Comprehension (from the Patterns of Use Study):
Understanding of Risk Reduction:
69.8% of baseline participants correctly understood the basic risk reduction message
Understanding remained high (72.5% to 77.8%) across all study waves
Comprehension levels aligned with or exceeded those seen in peer-reviewed literature
Understanding of Continued Health Risks:
Consumers understood General Snus still carries health risks
For mouth cancer risk perception:
34.9% perceived low risk
34.6% perceived moderate risk
13.1% perceived very low risk
For heart disease risk perception:
39.1% perceived low risk
34.1% perceived moderate risk
18.1% perceived very low risk
Understanding of Exclusive Use Requirement:
Among those who understood the basic claim (69.8% of participants):
80.3% correctly understood they must use "zero cigarettes" to reduce risk
This understanding remained stable across study waves
Participants perceived dual use (cigarettes + snus) as more harmful than exclusive snus use
Study Limitations:
All participants were General Snus users at baseline
Significant study attrition occurred
Participants weren't shown the claim during the study to avoid biasing the sample
Demographics differed somewhat from general population of cigarette smokers
The FDA concluded that the evidence shows:
Most users understand the relative risk reduction compared to smoking
Users understand the products still pose health risks
Users comprehend the need for exclusive use to achieve risk reduction
The claim continues to be "understood by consumers in the context of total health and in a manner that could reduce individual risk and benefit population health"
Timeline to Authorization
July 17, 2023
Swedish Match U.S.A., Inc. submitted MRTP renewal application
December 1, 2023
FDA made MRTPA renewal available for public comment
June 2024
TPSAC meeting held to discuss renewal application
Committee discussed health effects, marketing strategy, and recommendations for future post-market surveillance
August 14, 2024
Public comment period closed
FDA received 11 unique submissions:
10 contained relevant comments
1 was not relevant
Comments focused on legal issues, consumer understanding, study methods, and marketing concerns
November 6, 2024
Environmental assessment and FONSI (Finding of No Significant Impact) completed
November 7, 2024
FDA issued Modified Risk Granted Order (MRGO)
8-year authorization granted
Notable timing elements:
Total review time: approximately 16 months
Public comment period: approximately 8.5 months
TPSAC meeting held about 6 months after submission
Authorization granted about 3 months after public comment period closed

The seminar led by Dr. Benjamin Toll, titled “E-cigarettes in the US: Use by Physicians, Prevalence, Intentions to Quit, and Findings from Several Trials Investigating Methods for Quitting,” provided a comprehensive look at e-cigarette use, especially among young adults, and presented research on cessation methods. Here’s an overview:
Speaker Background:
Dr. Toll, a prominent figure in tobacco treatment, shared his extensive experience working in public health and advocacy, particularly in treating tobacco dependence.
Healthcare Considerations for E-Cigarettes:
Dr. Toll discussed the importance of behavioral counseling and FDA-approved medications as first-line treatments for tobacco cessation. He noted that for individuals unable to quit smoking through these methods, e-cigarettes might serve as an alternative to reduce exposure to harmful chemicals.
Focus on Young Adults:
The seminar emphasized the significance of e-cigarette use among 18-24-year-olds, a demographic the tobacco industry targets due to its potential for long-term brand loyalty.
Studies on Cessation Intentions and Efforts:
Data from the PATH study (a large, nationally representative survey) was reviewed to illustrate patterns in e-cigarette use and intentions to quit. Findings indicated a substantial interest in quitting, though success rates varied across user types (e.g., dual users versus e-cigarette-only users).
Pilot Studies on Cessation Aids:
Dr. Toll shared results from two pilot studies:
Nicotine Replacement Therapy (NRT): A trial using NRT (patches and lozenges) showed modest success in helping e-cigarette users quit.
Varenicline vs. Placebo: This study, conducted at two sites, indicated that varenicline could be effective for e-cigarette cessation, with significant quit rates observed at the 8- and 12-week marks.
Dual Users:
Findings suggested that dual users (those who smoke both cigarettes and e-cigarettes) had more difficulty quitting and might require higher NRT doses. This highlighted the need for more robust cessation interventions for this group.
Future Directions:
Upcoming studies plan to expand on the varenicline trial with a larger sample size and include biological markers of oncogenesis. These trials aim to refine and validate effective cessation strategies for those dependent on e-cigarettes.
Summary Points:
Dr. Toll concluded with key takeaways: FDA-approved methods remain the primary recommendation, but e-cigarettes could serve as harm reduction for persistent smokers. The urgency for quality research in e-cigarette cessation was underscored, as the popularity of e-cigarettes continues to rise in the U.S.
The seminar emphasized both the potential role of e-cigarettes in harm reduction and the critical need for effective cessation support, particularly for young adults and dual users