My colleagues at UCSF and Stanford and I have submitted this public comment to the FDA supporting a product standard limiting nicotine in tobacco products and opposing exceptions for heated tobacco products and waterpipe (PDF). The Comment Tracking Number in regulations.gov is mfj-vc5x-sbgb
.FDA’s proposed tobacco product standard setting a maximum level of nicotine in tobacco products will help prevent youth from becoming addicted to conventional cigarettes, help adult smokers quit, and will reduce tobacco-related diseases and deaths
Docket No. FDA-2024-N-5471 for “Tobacco Product Standard for Nicotine Yield of Cigarettes and Certain Other Combusted Tobacco Products.”
Pamela Ling, MD; MPH; Stanton A. Glantz, PhD; Lauren Lempert JD, MPH; Dorie E. Apollonio PhD MPP; Maya Vijayaraghavan MD, MAS; Vira Pravosud, PhD, MPH, MS; Neal Benowitz, MD; Wendy Max, PhD; Stella Bialous, RN, DrPH; Lynn D. Silver, MD, MPH; Heather Leutwyler, RN, PhD, FNP-BC, CNS; Sharon Hall, PhD; Jeremiah Mock, MSc, PhD; Janice Tsoh, PhD; Bonnie Halpern-Felsher, PhD, FSAHM; Valerie Yerger, ND; Matt Springer, PhD; Benjamin W. Chaffee, DDS MPH PhD
University of California, San Francisco
Stanford University School of Medicine
September 13, 2025
- We enthusiastically support FDA’s proposed tobacco product standard that would regulate nicotine yield by establishing a maximum nicotine level in tobacco products.
We enthusiastically support the FDA’s proposed rule setting the maximum level of nicotine in conventional cigarettes and other combusted tobacco products at 0.7 mg/g in a single step. This rule would reduce nicotine in combustible tobacco products to non-addictive levels, advancing a policy first proposed in July 2017 during the first Trump Administration[1] and endorsed by scientists, medical experts, and public health advocates since the implementation of the Family Smoking Prevention and Tobacco Control Act (TCA) in 2009.
2. FDA’s proposed standard would protect public health by limiting the addictiveness of toxic tobacco products.
The Family Smoking Prevention and Tobacco Control Act section 907 gives the FDA the authority to implement a tobacco product standard that reduces nicotine to non-addictive levels if the proposed regulation meets the standard that it is “appropriate for the protection of the public health.” To meet this standard, the FDA must demonstrate the risks and benefits to the entire population, including the likelihood that non-users, particularly youth, will start using tobacco products, and that current users will change their behavior—whether by stopping, reducing, or increasing their usage of tobacco products in ways that may cause greater harm. Additionally, to set a standard requiring the reduction of a constituent (such as nicotine), the FDA must demonstrate that the proposed standard will reduce or eliminate the risk of illness or injury.
In the preamble to its proposed rule, FDA appropriately documents the significant body of scientific evidence demonstrating that reducing the maximum level of nicotine to 0.7 mg of nicotine per gram of total tobacco would protect public health by making it more likely that non-users, including youth, and former users will not initiate tobacco use and that current users will quit. As the FDA explains, regardless of whether the nicotine itself is toxic, it is the nicotine in tobacco products that creates and sustains addiction, and tobacco products have been deliberately designed by tobacco companies to control nicotine delivery in a way that creates and sustains addiction. By setting a maximum level of nicotine permitted in tobacco products, the proposed standard would limit the addictiveness of tobacco products, which are themselves toxic and responsible for 490,000 smoking-attributable deaths each year.[2] FDA clearly met its statutory burden of demonstrating that the proposed standard is appropriate for the protection of the public health.
The UCSF TCORS submitted a comment to the Advance Notice of Proposed Rulemaking (ANPRM) related to a tobacco product standard for nicotine level in July 2018[3] in which we detailed the scientific evidence supporting a reduction in nicotine levels. We attach and incorporate that comment by reference.
3. FDA’s proposed standard would help to prevent youth from initiating with and becoming addicted to tobacco products.
Reducing the nicotine yield in tobacco products to minimally or non-addictive levels will prevent youth from becoming addicted. The FDA’s own population health model estimates that by the year 2100, the proposed rule would prevent 48 million youth and young adults in the US from starting to smoke, and would lead to approximately 19.5 million people quitting smoking within five years of implementation, thereby averting 1.8 million tobacco-related deaths by 2060, and 4.3 million deaths by the end of the century.[4]
A randomized controlled trial studying the effects of reduced nicotine cigarettes in adolescent smokers found that very low nicotine cigarette use resulted in fewer cigarettes smoked per day and was associated with lower levels of craving, suggesting that the proposed reduced standard may result in reduced smoking in adolescent smokers.[5]
4. FDA’s proposed standard would help to reduce smoking and protect the health of a wide range of individuals and populations.
Reducing nicotine in conventional cigarettes and other combustible tobacco products to minimally addictive or nonaddictive levels is likely to reduce smoking across a wide range of individuals and populations who are disproportionately impacted by tobacco use,2 ,[6] including among low-income populations and those with mental health conditions and substance abuse disorders.[7],[8],[9],[10],[11]
5. Substantial scientific evidence supports the FDA’s proposed nicotine limit of 0.7 mg/g.
Scientific evidence supports the FDA’s proposed approach to setting a maximum nicotine content level of 0.7 mg of nicotine per gram of total tobacco because it would reduce nicotine dependence and increase quit attempts and cessation without increasing craving, withdrawal, or compensatory smoking.7 8 9 10
6. FDA’s proposed immediate reduction approach is supported by significant scientific evidence.
Scientific evidence supports the FDA’s proposed immediate nicotine reduction approach to reach the proposed maximum nicotine level, rather than a gradual reduction or stepped-down approach. 4 [12] [13]
7. FDA should not exempt Heated Tobacco Products (HTPs)
FDA has specifically requested “comments, data, and research regarding the proposal to exclude noncombusted cigarettes (such as HTPs that are cigarettes) from the scope of this proposed rule, including any data that could justify otherwise.”[14] The available evidence does not support the exclusion of HTPs. In fact, as detailed below, the available evidence requires that HTPs be included in the rule.
HTPs such as IQOS, which Philip Morris International’s own scientists describe as “an electrically heated cigarette smoking system” produce harmful emissions composed of a wide range of chemicals.[15] [16] Although HTPs are promoted by the tobacco companies as being safer because they emit lower concentrations of some harmful substances on the FDA’s outdated list of Harmful and Potentially Harmful Constituents (HPHC) than conventional cigarettes, HTPs in fact release many other toxic and potentially harmful compounds that are not on the HPHC list at much higher levels than conventional cigarettes.[17]
The current HPHC list was released by the FDA 13 years ago, in 2012. This list contains 93 compounds, mostly carcinogens in conventional cigarette smoke. The FDA proposed updating the HPHC list in 2019 by adding 19 compounds to the list[18] that go beyond carcinogens and reflect important toxins in new products, such as propylene glycol, which is in at least some HTPs. As summarized in a public comment the UCSF TCORS submitted at the time,[19] these additions were well-justified. The FDA should not be using the existing HPHC as a de facto product standard for assessing HTPs.
An August 2025 literature review of 55 current research studies on the health impacts of HTPs found significant effects of HTP use on the cardiovascular system, respiratory diseases, and the reproductive system.[20] Studies on the cardiovascular system found smoking HTPs increased blood pressure, heart rate, platelet clot formations, and an enhanced inflammatory response, often followed by endothelial dysfunction. The studies showed a correlation between HTP smoking and negative effects on lung physiology, human bronchial epithelial cells, acute eosinophilic pneumonia, allergies, and asthma. HTP smoking during pregnancy was associated with health effects on the fetus, newborn, and mothers.
An April 2025 systematic review of available data on the effects of HTP smoking on biomarkers of potential harm and adverse events did not provide a clear indication of the benefits of smoking HTPs compared with smoking conventional cigarettes, even though most of the 40 interventional clinical trials included were industry-affiliated and at high risk of bias.[21]
Of particular concern, studies show that most HTP smokers are dual users. For example, in Italy, where the IQOS HTP has been available since 2014, a May 2025 comprehensive systematic review found that HTPs are especially popular among youth, and more than two-thirds of HTP users are dual users smoking both HTPs and conventional cigarettes.[22]
In Japan, a national survey conducted by the Ministry of Health, Labour, and Welfare showed that dual smoking of conventional cigarettes and HTPs has become a significant problem. In 2023, male among smokers of conventional cigarettes and HTPs ages 20-29, 23.3% reported dual use.[23]
We know that the use of multiple tobacco products does not reduce and may increase harm. An analysis of National Health Interview Survey data linked to the National Death Index compared “exclusive cigarette users,” “dual users of cigarettes and cigars/pipes,” “dual users of cigarettes and smokeless tobacco,” and “poly-users who used cigarettes, cigars/pipes, and smokeless tobacco” and found that smokers of conventional cigarettes who additionally used other tobacco products smoked as many if not more conventional cigarettes per day than exclusive conventional cigarette smokers, and smokers of conventional cigarettes who additionally used other tobacco products had mortality risks that were as high as and sometimes higher than those of exclusive smokers of conventional cigarettes.[24] An analysis of data from 2,679 adult participants from Wave 5 of the Population Assessment on Tobacco and Health Study, including individuals reporting current exclusive smoking of conventional cigarettes (n = 1,913), exclusive e-cigarette use (n = 316), and dual use (n = 450) found that dual users had higher levels of toxicant exposure than smoking conventional cigarettes alone.[25] A study of HTP smokers and dual users in Hong Kong found that dual users of conventional cigarettes and HTPs smoked fewer conventional cigarettes per day than exclusive smokers of conventional cigarettes, but consumed more tobacco in total.[26] Dual- or poly-use of other tobacco products concurrently with smoking conventional cigarettes is more dangerous than smoking conventional cigarettes alone.[27] [28] [29]
Although HTP smoking is currently not as high among middle and high school students in the US as e-cigarette use, youth trends can change quickly and unexpectedly, as happened with the 2018 youth vaping epidemic driven by JUUL, especially when the tobacco industry adjusts its focus and targets its marketing and promotions towards young people. In any case, the 2024 National Youth Tobacco Survey (NYTS)[30] found that a higher percentage of middle and high school students reported smoking HTPs (1.6%) compared to smoking pipe tobacco (1.5%), yet HTPs are excluded from the scope of the proposed regulation, while pipe tobacco is included.
IQOS HTPs are currently available in the US in two menthol flavors, which may make them more attractive to current menthol smokers who would otherwise quit smoking conventional cigarettes with reduced nicotine levels. Flavored HTP-specific cigarettes produced by Philip Morris International (PMI), British American Tobacco, and Japan Tobacco International for other markets like Japan can be purchased easily by US consumers through the internet, including IQOS-specific Shine Pearl cigarettes that PMI describes as “a bursting flavor with rich and fruity aroma” that have flavor capsules embedded in the filter.
Moreover, HTP smoking does not help smokers of conventional cigarettes quit beyond short-term quitting, and HTP smoking does not prevent former smokers of conventional cigarettes from relapsing.[31] [32]
The FDA should not be making policy based on unproven assumptions about smoking HTPs being less harmful than smoking conventional cigarettes, especially when the available reliable scientific evidence is not consistent with those assumptions.
8. FDA should not exempt waterpipe tobacco.
The FDA requested comment on its proposal to exclude waterpipe (Draft rule, page 5101). FDA justifies this decision as follows:
FDA considered including waterpipe tobacco products within the scope of this proposed product standard; however, the Agency has determined that waterpipe tobacco involves profoundly different use behaviors than combusted cigarettes, which makes it an unlikely substitute for cigarettes. We therefore do not propose including waterpipe tobacco products within the scope of this proposed rule.
Data on frequency of use differentiates waterpipe tobacco from cigarettes. For instance, according to the 2024 NYTS, 0.7 percent of middle and high school students (or approximately 190,000 students) reported using waterpipe tobacco within the previous 30 days, compared with estimates for previous 30-day cigarette use (1.4 percent; 380,000 students) and cigar use (1.2 percent; 330000 students) (Ref. 3). However, waterpipe tobacco is significantly less likely to be smoked daily. In fact, given the relative infrequency of waterpipe use, it is often reported in terms of monthly versus less than monthly use, rather than daily versus non-daily. Data from Waves 1 (2013–2014) and 2 (2014–2015) of the PATH Study indicated that, among adults who used waterpipes in the past year, 77.1 percent reported less than monthly use at Wave 1; by Wave 2, 44.9 percent of these adults continued using waterpipe less than monthly, while 6.4 percent progressed to monthly or more frequent use (Ref. 643). For comparison, 59.1 percent of adults in the 2018 NHIS who smoke cigarettes report daily use (Ref. 644). Wave 3 (2015–2016) PATH Study data also indicate the infrequency of daily waterpipe use: 0.1 percent of youth, 0.3 percent of young adults, and 0 percent of adults 25 and older reported daily waterpipe use (Ref. 645). Comparatively, analysis from Wave 3 of the PATH study found that 0.6 percent of youth, 11.4 percent of young adults, and 15.3 percent of adults older than 25 reported daily cigarette smoking (Ref. 646).
FDA acknowledges that the health consequences of waterpipe usage are far from innocuous. People who use waterpipes are exposed to many of the same toxicants as people who smoke cigarettes, and due to the extended duration of each waterpipe session (i.e., approximately 1 hour), waterpipe use may lead to higher toxicant exposure per session than toxicant exposure from one cigarette (Refs. 647 and 648). Thus, people who use waterpipes are likely subject to many of the same severe negative health effects as people who smoke cigarettes (Ref. 649).
However, FDA does not anticipate significant migration to waterpipe usage under the proposed product standard. Waterpipes as currently marketed are generally large and require time consuming preparation, leading to an approximate waterpipe smoking session of 1 hour (Ref. 650). The limited accessibility and mobility of waterpipes as generally currently used contribute to their predominant intermittent usage patterns (Ref. 650). FDA assesses that these aspects of waterpipe design would similarly substantially limit their utility as a substitute for cigarettes and other combusted tobacco products that would be subject the proposed product standard, especially as compared to the portability and ease of use of many HTP, ENDS, and other noncombusted tobacco products that are currently legally marketed and not subject to the proposed product standard.
FDA’s argument that because of different behaviors associated with waterpipe use, it would be an “unlikely substitute for cigarettes” is not compelling. Hookah lounges are proliferating in the US and are especially popular with young adults, with many jurisdictions that otherwise prohibit smoking in commercial establishments allowing smoking at hookah cafes.
The FDA does not address dual use or how the existence of waterpipes that deliver high levels of nicotine could affect cessation of conventional cigarette smoking or relapse.
Waterpipe tobacco is almost always fruit- or candy-flavored, which would make it an attractive alternative to tobacco-flavored, very low-nicotine cigarettes under the proposed rule. Flavored waterpipe is even available in jurisdictions where other flavored tobacco products are prohibited.[33]
The FDA should not be making policy based on unproven assumptions about smoking waterpipe tobacco being less harmful than smoking conventional cigarettes, especially when the available reliable scientific evidence is not consistent with those assumptions.
9. Conclusion
We strongly support the FDA’s proposed standard setting the maximum level of nicotine in cigarettes and other combusted tobacco products at 0.7 mg/g in a single step. FDA’s proposed rule limiting nicotine levels to minimally- or non-addictive levels is an important step that will significantly reduce cigarette smoking and initiation and increase cessation, thereby reducing smoking-related death and disease. The FDA should not exclude HTPs and waterpipe tobacco from maximum nicotine level standards. The FDA should, instead, establish maximum levels of nicotine for HTPs and waterpipe tobacco that are at parity with the maximum levels of nicotine the FDA establishes for conventional cigarettes.
If, at some point in the future, evidence emerges that allowing higher levels of nicotine in HTPs and/or waterpipe tobacco would not result in youth use and be appropriate for the protection of public health, the FDA could amend the standard.
[1] Protecting American Families: Comprehensive Approach to Nicotine and Tobacco, Remarks by Scott Gottlieb, MD, Commission, Food and Drug Administration, July 28, 2017. Available: https://www.fda.gov/news-events/speeches-fda-officials/protecting-american-families-comprehensive-approach-nicotine-and-tobacco-06282017
[2] U.S. Department of Health and Human Services. Eliminating Tobacco-Related Disease and Death: Addressing Disparities—A Report of the Surgeon General: Executive Summary. Atlanta, GA: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Center for Chronic Disease Prevention and Health Promotion, Office on Smoking and Health, 2024.
[3] Glantz SA, Benowitz N, Chaffee B, Gotts J, Halpern-Felsher B, Jacob P, Ling PM, Max W, Moazed F, Springer M, St.Helen G, Vogel E, Lempert L. Tobacco Product Standard for Nicotine Level: The FDA Should Set a Nicotine Level to be Achieved in a Single Step for All Combusted Tobacco Products. Docket No. FDA-2017-N-6189. July 12, 2018.
[4] Tobacco Product Standard for Nicotine Yield of Cigarettes and Certain Other Combusted Tobacco Products, 90 FR 5032 (January 16, 2025).
[5] Cassidy RN, Tidey JW, Jackson KM, Cioe PA, Murphy SE, Krishnan-Sarin S, Hatsukami D, Colby SM. The Impact of Reducing Nicotine Content on Adolescent Cigarette Smoking and Nicotine Exposure: Results From a Randomized Controlled Trial. Nicotine Tob Res. 2023 Apr 6;25(5):918-927. doi: 10.1093/ntr/ntac279. PMID: 36482794; PMCID: PMC10077938.
[6] Tidey JW, Snell LM, Colby SM, Cassidy RN, Denlinger-Apte RL. Effects of very low nicotine content cigarettes on smoking across vulnerable populations. Preventive medicine. 2022 Dec 1;165:107099.
[7] Donny EC, White CM. A review of the evidence on cigarettes with reduced addictiveness potential, Int J Drug Policy. 2022;99:103436.
[8] Foulds J, et al. The effects of reduced nicotine content cigarettes on biomarkers of nicotine and toxicant exposure, smoking behavior and psychiatric symptoms in smokers with mood or anxiety disorders: a double-blind randomized trial. PLoS One. 2022;1711):e0275522.
[9] Meier E., et al. Immediate switching to reduced nicotine cigarettes in a US-based sample: the impact on cannabis use and related variables at 20 weeks. Nicotine Tob Res. 2023;25(5):867-874.
[10] Gaalema DE, et al. Potential effects of nicotine content in cigarettes on use of other substances. Prev Med. 2022;165(pt B):107290.
[11] Peters EN, et al., Effect of very low nicotine content cigarettes on alcohol drinking and smoking among adult smokers who are at-risk alcohol drinkers. Exp Clin Psychopharmacol. 2023;31(3):733-744.
[12] Li Q, Chen X, Li X, Gorowska M, Li Z, Li Y. The Effects of Immediate vs Gradual Reduction in Nicotine Content of Cigarettes on Smoking Behavior: An Ecological Momentary Assessment Study. Front Psychiatry. 2022 May 11;13:884605. doi: 10.3389/fpsyt.2022.884605. PMID: 35633808; PMCID: PMC9130591.
[13] EM, Luo X, Jensen J, al’Absi M, Cinciripini PM, Robinson JD, Drobes DJ, McClernon J, Strasser AA, Strayer LG, Vandrey R, Benowitz NL, Donny EC, Hatsukami DK. Smoking abstinence and cessation-related outcomes one month after an immediate versus gradual reduction in nicotine content of cigarettes. Prev Med. 2022 Dec;165(Pt B):107175. doi: 10.1016/j.ypmed.2022.107175. Epub 2022 Jul 20. PMID: 35870575; PMCID: PMC10676511.
[14] Proposed rule, page 5101.
[15] Schorp MK, Tricker AR, Dempsey R. Reduced exposure evaluation of an Electrically Heated Cigarette Smoking System. Part 1: Non-clinical and clinical insights. Regul Toxicol Pharmacol. 2012;64(2 Suppl):S1-S10. doi:10.1016/j.yrtph.2012.08.008
[16] Zenzen V, Diekmann J, Gerstenberg B, Weber S, Wittke S, Schorp MK. Reduced exposure evaluation of an Electrically Heated Cigarette Smoking System. Part 2: Smoke chemistry and in vitro toxicological evaluation using smoking regimens reflecting human puffing behavior. Regul Toxicol Pharmacol. 2012;64(2 Suppl):S11-S34. doi:10.1016/j.yrtph.2012.08.004
[17] St.Helen G, Jacob P III, Nardone N, Benowitz NL. IQOS: examination of Philip Morris International’s claim of reduced exposure. TobControl. 2018;27(Suppl1):s30–s36.
[18] Food and Drug Administration. Harmful and Potentially Harmful Constituents in Tobacco Products; Established List; Proposed Additions. Posted by the Food and Drug Administration on Aug 5, 2019. https://www.regulations.gov/document/FDA-2012-N-0143-0002.
[19] Lempert LK, St.Helen G, Gotts J, Kozlovich S, Springer M, Halpern-Felsher B, Glantz SA. In addition to the 19 constituents FDA proposes to add to the list of Harmful and Potentially Harmful Constituents, FDA should also add compounds that may be carcinogenic or cause pulmonary or cardiovascular harms when inhaled, especially oils and chemicals and chemical classes found in e-cigarette flavorants, and FDA should use as additional criteria California’s Proposition 65 list of carcinogens and reproductive toxicants and the California Air Resources Board’s list of Toxicant Air Contaminants. FDA Docket No. FDA-2012-N-0143. October 2, 2019. Regulations.gov tracking number 1k3-9cij-8wgr.
[20] Znyk M, Kaleta D. The Health Effects of Heated Tobacco Product Use—A Narrative Review. In Healthcare 2025 Aug 18 (Vol. 13, No. 16, p. 2042). MDPI.
[21] Braznell S, Dance S, Hartmann-Boyce J, Gilmore A. Impact of heated tobacco products on biomarkers of potential harm and adverse events: a systematic review and meta-analysis. Tobacco Control. 2025 Apr 30.
[22] Scala M, Dallera G, Gorini G, Achille J, Havermans A, Neto C, Odone A, Smits L, Zambon A, Lugo A, Gallus S. Patterns of use of heated tobacco products: a comprehensive systematic review. Journal of Epidemiology. 2025 May 5;35(5):213-21.
[23] Japan Ministry of Health, Labour and Welfare (2024) Summary of the National Health and Nutrition Survey Results, page 21. https://www.mhlw.go.jp/content/10900000/001338334.pdf
[24] Kelvin Choi, Maki Inoue-Choi, Timothy S McNeel, Neal D Freedman, Mortality Risks Associated With Dual– and Poly–Tobacco-Product Use in the United States, American Journal of Epidemiology, Volume 191, Issue 3, March 2022, Pages 397–401, https://doi.org/10.1093/aje/kwz143
[25] Zheng Xue, Eva Orr-Souza, Nigar Nargis, Minal Patel, Tyler Nighbor, Nicotine and Toxicant Exposure among Individuals using both Combustible Cigarettes and E-cigarettes Based on Level of Product Use, Nicotine & Tobacco Research, Volume 27, Issue 9, September 2025, Pages 1591–1599, https://doi.org/10.1093/ntr/ntaf053
[26] Zhang X, Sun Y, Cheung YTD, et al. Cigarettes, heated tobacco products and dual use: exhaled carbon monoxide, saliva cotinine and total tobacco consumed by Hong Kong tobacco users. Tobacco Control 2024;33:457-463.
[27] Glantz SA, Nguyen N, Oliveira da Silva AL. Population-Based Disease Odds for E-Cigarettes and Dual Use versus Cigarettes. NEJM Evid. 2024 Mar;3(3):EVIDoa2300229. doi: 10.1056/EVIDoa2300229. Epub 2024 Feb 27. PMID: 38411454; PMCID: PMC11562742.
[28] Pisinger C, Rasmussen SKB. The Health Effects of Real-World Dual Use of Electronic and Conventional Cigarettes versus the Health Effects of Exclusive Smoking of Conventional Cigarettes: A Systematic Review. Int J Environ Res Public Health. 2022 Oct 21;19(20):13687. doi: 10.3390/ijerph192013687. PMID: 36294263; PMCID: PMC9603628.
[29] Coleman SRM, Piper ME, Byron MJ, Bold KW. Dual Use of Combustible Cigarettes and E-cigarettes: a Narrative Review of Current Evidence. Curr Addict Rep. 2022 Dec;9(4):353-362. doi: 10.1007/s40429-022-00448-1. Epub 2022 Oct 17. PMID: 36467719; PMCID: PMC9718538.
[30] Jamal A, Park-Lee E, Birdsey J, et al. Tobacco Product Use Among Middle and High School Students — National Youth Tobacco Survey, United States, 2024. MMWR Morb Mortal Wkly Rep 2024;73:917–924. DOI: http://dx.doi.org/10.15585/mmwr.mm7341a2
[31]Odani S, Tsuno K, Agaku IT, Tabuchi T. Heated tobacco products do not help smokers quit or prevent relapse: a longitudinal study in Japan. Tobacco Control. 2024 Jul 1;33(4):472-80.
[32] Kim SH, Lee JA, Cho HJ. Association between heated tobacco product use and quitting combustible cigarette smoking among Korean adults. Nicotine and Tobacco Research. 2025 Feb 8:ntaf030.
[33] California Health and Safety Code – HSC § 104559.5.
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