26 Jun 2014
I tried to follow Patrick’s excellent advice, especially to be brief and focused. I’d add only one suggestion to his—sign your name. A signed comment is worth dozens of anonymous ones.
I took a somewhat different tack than most filers, focusing on suggestions that I believe could increase the likelihood of getting an exemption with minimal impact on the industry.
Since I shared my recent letter to the FDA’s tobacco czar, I thought I’d do the same with these comments:
I am an adult cigar smoker and fully support an FDA exemption for premium, hand-rolled cigars. I’ll let others enumerate the reasons this should be done. Instead, I’ll focus on three areas that I believe both sides could accept and that would facilitate reaching an agreement on an exemption.
- Enact a federal minimum age of 21 for purchasing premium, hand-rolled cigars. This would both demonstrate the industry’s sincerity that it does not market to underage youth and allay fears of tobacco opponents.
- Require officers and directors of cigar companies whose products are exempted to annually attest, under penalty of perjury, that their companies and products adhere to the requirements of the exemption.
- Ensure that the exemption is clear and unambiguous, and does not, under any circumstances, allow creation of other exempted products, such as lower-cost cigarette alternatives.
I do feel compelled to comment on one specific component of the proposal: the $10 price floor. This would be devastating, leaving an industry so diminished as to require no more regulation than luxury-priced dark chocolate truffles. I urge that rules be enacted without an impractical, ruinous price floor.
Thank you for your consideration.
I hope everyone will file their own comments. Feel free to copy, adapt, or use any portion of mine. Read through our (many) previous articles on the subject for other ideas and sources. But don’t miss the opportunity to register your views here.
photo credit: Stogie Guys