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The FDA Nicotine Pouch Pilot

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ARAC shared perspective with 2FIRSTS on FDA’s new pilot program for nicotine pouch PMTAs — and why the fundamentals still stand.


While the pilot aims to streamline review and allow some category-level data, the evidentiary bar hasn’t changed: applicants must still demonstrate that products are appropriate for the protection of public health through rigorous, product-specific data.


In short: faster doesn’t mean easier. Robust switching studies, clear marketing plans, and strong behavioral evidence remain essential to success — especially as FDA tests new pathways toward efficiency without compromising public health.


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