Have you submitted your comment to the FDA regarding flavored tobacco products yet? Have your customers?
If not, send this blog post to them so they can understand why it’s so important and how to submit a good comment.
What Is This “Comment Period”? What Am I Commenting On?
The FDA is currently considering rules for regulating flavored tobacco products, which will impact vaping flavors for many years to come. If it’s anything like San Francisco’s approach to flavored tobacco regulations, it may even crush the vape industry.
Before they finalize the rules on how they will regulate flavored tobacco, the FDA will collect feedback in the form of public comments during what they call an “Advanced Notice Of Proposed Rule Making” (ANPR) period.
The current ANPR period for flavored tobacco products is scheduled to end July 19th, 2018.
So far, the number of comments collected compared to the number of vapers is quite a big difference… the vaping community needs to step up and submit as many comments as possible.
But how do you go about submitting an effective comment? How do you get your customers to do it? This blog post will help.
What Is The FDA Trying To Do With Our Flavors?
The short answer is, we don’t know yet.
According to this statement by Scott Gottlieb, and this document on the comment page, the FDA wants to know the effect that flavors have on attracting youth to trying tobacco products, but they also mention repeatedly that they understand how flavors are also helping adults quit smoking. We do not have specifics on what the regulations will ultimately do to vape flavors, but we cannot risk being left in the dust without our voice being heard.
How Can I Submit A Comment That The FDA Will Consider?
That’s precisely what this post is trying to answer.
The FDA has said they are seeking comments SPECIFICALLY about these topics.
- The role that flavors play in initiation and patterns of tobacco use, particularly among youth and young adults;
- The role that flavors may play in helping some adult cigarette smokers reduce cigarette use and/or switch to potentially less harmful tobacco products;
- The role that flavors in non-combusted tobacco products may play in quitting combusted tobacco products use, quitting all tobacco use or starting to use more than one type of tobacco product;
- Consumer perceptions of health risks and addictiveness of flavored tobacco products;
- Whether certain flavors used in tobacco products present potential adverse health effects to users or others; and
- The impact of local, state and international efforts to restrict the sale or marketing of flavored tobacco products.
There are also numerous other topics you can address such as potentially toxic flavor ingredients like diacetyl and acetyl propionyl, or the argument that flavors cause kids to become regular tobacco users.
See below for our guidelines on submitting an effective comment to the FDA.
DO: Give The FDA Data, Not (Just) Anecdotes
Many of the comments I’ve seen are personal stories with no reference to a scientific article. While these are important for context, the FDA has specifically asked for DATA, not anecdotes.
Here is what Gottlieb said specifically about data when submitting a comment:
“Now I know anecdotes aren’t the same as data. And the ANPRM specifically seeks data on this issue. But these personal stories are important to me as we shape our overall approach to smoking cessation”
This means you need to cite relevant, scientific data on how flavors help smokers switch to vaping.
Go to the above document and pick a scientific study to read, then submit a link to it in your comment. (If you have one that you want to add to this collection, please email me a [email protected])
DO NOT: Rant And Rave. Give A Thoughtful, Respectful And Informed Opinion
Time to put on your college essay hats! The FDA has stated in their “Tips For Submitting Effective Comments” doc that:
“A constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.”
Furthermore, the FDA said your comment should:
- Base your justification on sound reasoning, scientific evidence and/or how you will be impacted
- Be concise and support your claim
- Address trade-offs and opposing views
- The comment process is not a vote – one well supported comment is often more influential than a thousand form letters
- If a rule raises many issues, do not try to comment on every one. Select those that concern and affect you the most.
DO: Ask Questions If You Have Them
The FDA wants you to understand the ANPR you are commenting on. If you have questions, it’s better that you understand the issue so it comes from a place of informed opinion, otherwise your comment could be dismissed.
DO NOT: Use Form Letters Or Treat This As A Vote – Quality Is Better Than Quantity
A single, well-written response will likely have more impact than thousands of poorly written “comments”. Take your time and think a lot!
Also, DO NOT use form letters! Again, it’s not a vote, it’s an informed discussion about an important topic.
DO: Identify Credentials And Credibility Markers That Give You Clout
If you are a scientist, economist, attorney, business owner, professor or public health expert, you should note that in your comment. This way the FDA will consider your comment more seriously.
DO NOT: Submit A Big Pile Of Text With No Spaces!
This may seem like a weird request, but this is an important tip in effective letter writing.
The #1 thing I learned when studying how to write is to use the return key early and often. You want to keep your paragraphs short and your sentences concise.
Break up your comment into digestible “chunks” so the person reading the comment can easily “skim” through the major points if needed. (See how I put that sentence on another line? It helped you read it easier, huh?)
At the end of the day, your goal is to sway the opinion of the FDA regulator that is reading the comment, so you need to write it in a way that affects an individual person.Would you want to read a big pile of text with no spaces? Neither does the FDA.
This is actually a skill that can be honed and developed. Read this quick article about how to persuade people with your copywriting.
(NOTE: notice how often the author uses the return key. Almost every thought is on a new line. It’s easy to read, huh?)
DO: Proof-Read Your Final Comment
Again, you are trying to submit a credible and effective comment that will persuade an individual to listen to your position. In order to do this you need to appear intelligent and well-read.
Bad grammar is the ULTIMATE credibility killer. Luckily, it’s the 21st century and we have robots to help us look smarter.
Hey Vapreneurs: Do You Need Help Motivating Your Customers To Submit A Comment?
I bet you do!
In order to help you convince your customer to submit their comment, we have two very important resources for you:
- First, share this article and video with your customer
- Second, use our email template to persuade them to submit a comment
We’ve prepared an email template that you can copy and paste, then send it out to your customers.
It’s written so that when they submit proof that they’ve submitted a comment, they can come into your shop for a 10% off coupon.
Hope this helps!
Author: Jesse Plautz
Jesse is the Digital Marketing Director at VapeMentors and Chief Technology Mentor. He is an ecommerce and internet marketing expert with a background in business and technology.