Core Viewpoint - The proposed FDA standard for nicotine yield in tobacco products could prevent 4.3 million deaths and save $600 billion annually in economic damages related to smoking [1][3]. Company Position - 22nd Century Group supports the FDA's proposed rule, emphasizing that it could lead to the complete replacement of conventional high-nicotine products with Very Low Nicotine Content (VLNC) products within two years [1][3]. - The company has developed proprietary non-GMO reduced nicotine tobacco plants, which contain 95% less nicotine than traditional tobacco, enabling the production of consumer-acceptable combusted tobacco products [8][9]. Health Impact - The FDA's population health model suggests that adopting the proposed rule could prevent smoking initiation in approximately 48 million youth and young adults and avert 1.8 million tobacco-related deaths by 2060 [3][4]. - Clinical evidence supports that limiting nicotine in combusted tobacco products leads to reduced cigarette consumption, decreased dependence on tobacco, and increased cessation attempts [3][4]. Industry Support - Over 75 health care organizations, including the American Medical Association and the American College of Cardiology, endorse the proposed rule, citing the urgent need for such a standard [4]. - Some organizations argue that the rule should extend to limit nicotine in Heated Tobacco Products (HTPs) as well [4]. Opposition - Major legacy tobacco producers oppose the proposed standard, citing concerns over economic disruption and potential illicit trade [5]. - The company argues that the opposition from these producers contradicts their stated goals of transitioning smokers to less harmful products [5].