Abstract
The US Food and Drug Administration is considering mandating a substantial reduction in the nicotine level of cigarettes and possibly other combusted tobacco products to render them minimially addictive. This would likely result in several public health benefits, including increased cessation, decreased progression to dependence, and reduced consumption of combusted tobacco products. However, findings from clinical trials of reduced-nicotine cigarettes suggest that many smokers consuming low nicotine-content cigarettes sought out regular nicotine-content cigarettes, even when they were asked to only smoke free low-nicotine cigarettes. If this policy were implemented without ensuring that cessation treatments and appealing alternative products (e.g., e-cigarettes) were readily available, some consumers would be likely to seek banned regular nicotine-content combusted tobacco products from illicit sources: retail, online, and individuals. Left unchecked, this illicit market could undermine the public health benefits of the policy. We describe supply and demand factors in an illicit market. Informed by the literature on controlling Internet tobacco sales and reducing illicit trade in low-cost cigarettes when there are price differentials, we recommend tracking and tracing products and greater surveillance and enforcement efforts to minimize illicit trade in normal nicotine products under a low-nicotine tobacco product standard.