“…These concerns are especially heightened for children. 3 The experience with Juul, a vaping product that was inappropriately marketed and fueled a youth vaping crisis in 2018, without MRTP authorization, underscores the risks associated with these products. 4 Reflecting these concerns, the FDA has been cautious in granting MRTP authorizations, and the pathway for demonstrating that a product meets the strict standards is challenging.…”