Regulatory Impact Analysis: The Tool That Could Transform Nicotine Policy—If Anyone Used It
Regulatory impact analysis requires agencies to estimate the costs and benefits of proposed regulations. For nicotine, it's rarely done—and when it is, the analysis is selective. A rigorous RIA requirement would change policy.
A regulatory impact analysis of a flavor ban would estimate: the reduction in youth vaping, the potential increase in adult smoking, the net health effect, and the distribution of costs and benefits across populations. **The FDA is not required to conduct this analysis for tobacco product regulations. The result: regulations are justified by their intended effects without systematic evaluation of their unintended consequences. A rigorous RIA requirement would force agencies to confront the tradeoffs their regulations create.**
