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Cigar Tip: Submit Your Comment to the FDA to Protect Handmade Cigars

19 Jun 2014

FDA-cigars-large

In April the FDA took a big step towards regulating cigars in a way that could be devastating to the handmade cigar industry, and initiated a public comment period that will run until August 8. With time running out to submit your comment, here are a few tips to use when you register your comment here.

Don’t Lose Sight of the Goal

The point here is to protect cigars, not just vent anger at the FDA. If your comment includes lots of words in ALL CAPS, multiple exclamation marks, or frequent references to nazis and fascism, it may make you feel better when you hit submit, but it will probably be more easily dismissed by the bureaucrats at the FDA. Unfortunately, the FDA has already been granted the authority to regulate cigars, so the only questions now are if it will use that authority, and, if so, what form the regulations will take and what exemptions the FDA may create.

Don’t Bury the Lede

I doubt I’m going to single-handedly disillusion any readers about our government here, but odds are your comment won’t individually get a careful, thorough consideration. Rather, the FDA uses the comment period to hear from prominent stakeholders and to generally gauge the opinions of those who take the time to comment. So be clear upfront about your position. And feel free to repeat it at the end.

Emphasize the Key Points

Cigar Rights of America has a helpful list of message themes here. You should definitely read the whole thing and feel free to borrow from it while writing your comment. (There are no extra points for originality.) To their excellent points, I would add two additional ones. First, there is no reason for treating flavored or infused cigars differently from non-flavored premium, handmade cigars (for more on that point check out this piece I wrote a few weeks ago). Second, given the FDA’s limited budget and the fact that it has only ruled on 34 of thousands of outstanding new tobacco products waiting for approval, the agency’s resources would be better off focusing on products other than handmade cigars. Of course, most of all, be sure to point out that you are a responsible adult who smokes in moderation.

Pause Before You Hit Submit

Proofreading is important. A comment full of spelling or grammatical errors or, worse yet, sentences that don’t make sense, will undercut your message. As someone who edits quite a bit of writing, I can tell you it’s always tougher to edit and proof your own writing, so don’t hesitate to ask a friend to look it over.

Don’t Wait Until Tomorrow

A rhetorical masterpiece complete with citations to relevant scientific research is great if you can pull it off, but lets not kid ourselves: This is in large part a numbers game. A short, to-the-point comment is infinitely more helpful than the long, in-depth comment you never get around to actually submitting. To that end, if you know someone who would be willing to submit a comment but probably doesn’t have the time to write it up, send them a comment they can use along with the link where they can submit it.

Patrick S

photo credit: Stogie Guys

Drew Estate

14 Responses to “Cigar Tip: Submit Your Comment to the FDA to Protect Handmade Cigars”

  1. Mike Thursday, June 19, 2014 at 9:26 am #

    Excellent points, Patrick. And as someone who edits and writes for a living, your suggestions are good ones.

  2. Ricky Thursday, June 19, 2014 at 9:32 am #

    So nothing wrong with simply copy and pasting the CRA text? If this is a numbers game for the most part, I assume that's not an issue then?

    • Patrick Semmens Thursday, June 19, 2014 at 10:18 am #

      Some personalization is nice, but if the choice is between copy&paste or nothing at all, then yes copy/paste.

      Frankly, there are advantages to having many different people send the same comment in. It demonstrates not only do cigar smokers think this issue is important, but that they are organized. That can only amplify their voice.

    • Mike Friday, June 20, 2014 at 9:03 am #

      I haven't seen CRA's most recent form letter, but I hope it would not include anything about government regulation, secondhand smoke, the Obama administration, etc. Those topics are not really relevant to the debate at this stage, despite many of the posts I've seen on social media and news sites about this issue.

  3. Scott Thursday, June 19, 2014 at 1:15 pm #

    Comment submitted. Thanks for the reminder Patrick.

  4. Mike H in Kingsville Thursday, June 19, 2014 at 4:33 pm #

    done and submitted. If you like them, protect them.

  5. George E. Friday, June 20, 2014 at 7:27 pm #

    It's no reason to delay filing your comments, but the FDA has extended the deadline for comments. You can read about it here http://www.fda.gov/TobaccoProducts/Labeling/ucm388395.htm?source=govdelivery&utm_medium=email&utm_source=govdelivery

  6. James Roberts Thursday, July 3, 2014 at 7:34 pm #

    Smoking a cigar is a freedom of choice issue. I smoke a cigar about twice a month and it always is a high quality, hand rolled jewel of a cigar. I DO NOT want my government interfering in my life more than it already is. PLEASE LEAVE THE QUALITY HANDMADE cigar industry alone!
    Thank you,
    James Roberts

  7. Lloyd Friday, July 4, 2014 at 8:03 am #

    Smoking a cigar is a freedom of choice issue. I smoke a cigar about twice a month and it always is a high quality, hand rolled jewel of a cigar. I DO NOT want my government interfering in my life more than it already is. PLEASE LEAVE THE QUALITY HANDMADE cigar industry alone!
    it should be our choice without regulating it thru the government of it! thanks ….Lloyd

  8. William Hughes Sunday, July 6, 2014 at 5:10 pm #

    Several great points were pointed out above and I agree with them. I believe in our freedom in this great country, USA. I believe that we should havethe freedom and right to smoke a nice cigar when and where we please so long as it is not interfering with anyone elses right to not smoke and/or breathe second hand smoke. Those who choose not to smoke a cigar have the option to move away from those of us that choose to smoke quality cigars. I am a regular 3-4 cigars a week and I very much want to continue to be able to do just exactly that.

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