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In 2016, pursuant to this authority, FDA promulgated regulations (known as "the deeming rule") that extended the agency's authority over all tobacco products that were not already subject to the FFDCA, including ENDS

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The letter went so far as to claim that the paucity of evidence of serious harm to e-cigarette users since they were first marketed in 2006, with millions sold, was proof in itself.[xxxii] We are here obliged to recall the aphorism, often attributed to astrophysicists Martin Rees or Carl Sagan, that "absence of evidence is not evidence of absence".[xxxiii] Absence of evidence is not evidence of absence