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Comments to FDA on Health Warning Labels for Cigarettes

The Food and Drug Administration (FDA) is proposing to place new, more effective health warning labels on cigarette packages and advertisements. We submitted comments supporting the proposal and suggesting ways the agency can strengthen its assessment of the new labels’ costs and benefits.

FDA’s rule would replace existing Surgeon General’s Warnings on cigarette packages with larger labels that incorporate graphic images and more detailed, up-to-date information on the health consequences of smoking. The agency establishes a compelling need for the change by making evidence-based findings that cigarette smoking has severe health consequences, that market failures affect consumers’ decisions to smoke, and that enhanced warning labels would help correct these market failures. Our comments encourage FDA to provide a quantitative estimate of the new labels’ informational value to consumers. We also recommend that the agency consider developing an additional analysis that focuses directly on the proposal’s potential to dissuade consumers from smoking and, in turn, improve their health.