Natalie Hansen - Comment

The FDA should not amend 21 CFR Part 1140 to allow a tobacco product that shares a trade or brand name with a non-tobacco product to continue to use the name if the tobacco product was sold in the United States before June 22, 2009 , instead of January 1, 1995. Such an amendment to the rule could harm the American people, specifically children and teenagers. The rationale behind the original rule was to prevent brand name association of a tobacco product with a nontobacco product that might appeal to children or teenagers. For example, Eclipse is one of the tobacco products that would be grandfathered in under the revised version of the rule. However, Eclipse shares its name with a popular brand of gum and a wildly popular movie and book that is clearly marketed towards children and teens. The Eclipse movie, part of the Twilight series, grossed $698,491,347 in box office sales (IMDB.com) and is very popular among teens especially. If a child or teen were to see that a tobacco product shared the same as one of their favorite movies, that child might be more likely to try the tobacco product. As stated in the rule notice, over 80% of adult smokers began smoking before the age of 18. Changing the grandfather date to over 14 years later is unnecessary and carries with it too great of a cost. Certain products that should have to change their name will not, putting the health and welfare of America’s youth at risk.