July 6, 2026
RE: Agency Information Collection Activities; Proposed Collection; Comment Request; National Youth Tobacco Survey (Docket No. FDA-2026-N-3070)
The National Center for Health Research (NCHR) appreciates the opportunity to comment on the FDA’s proposed information collection for the National Youth Tobacco Survey (NYTS) 2027-2029. NCHR is a nonprofit, nonpartisan organization that uses scientific and medical evidence to inform health policies that protect patients, consumers, and communities.
The NCHR enthusiastically supports the continuation of the NYTS, a national school-based survey of middle and high school students. The NYTS is an essential source of accurate, reliable, and timely information on youth tobacco and nicotine product use, including e-cigarettes, nicotine pouches, and other emerging products. At a time when the tobacco and nicotine marketplace is changing rapidly, the need for this rigorous annual survey focused specifically on youth tobacco use is especially urgent.
Tobacco use remains the leading cause of preventable death in the United States, and most tobacco use begins during adolescence. For that reason, the FDA needs high-quality national data to identify youth trends early, guide prevention efforts, evaluate the impact of tobacco policies, and inform enforcement priorities. The NYTS provides critical information on product use, prevalence, youth knowledge and attitudes, access to tobacco products, exposure to tobacco industry advertising and marketing, and factors that contribute to initiation and continued use. These data are essential for policymakers, public health professionals, educators, researchers, and community organizations working to prevent youth nicotine addiction and related harm to the health of our children now and in the future.
The NYTS has repeatedly served as an early warning system for emerging public health threats. For example, NYTS data helped document the epidemic in youth e-cigarette use, making clear the need for stronger prevention, education, and regulatory action. The survey has also helped track the emergence of nicotine pouch use among youth, a trend that needs to be studied in this survey, given the rapid growth and marketing of these products. As new products enter the market and existing products evolve, the NYTS must continue to assess youth use of e-cigarettes, nicotine pouches, heated tobacco products, smokeless tobacco, cigars, hookah, and other tobacco or nicotine products that have the potential to appeal to young people. Importantly, the survey should also assess how the use of these new products affects youth use of combustible cigarettes, including whether they contribute to initiation, dual use, sustained nicotine addiction, or transitions between products.
Nicotine pouches provide a timely example of why the NYTS is indispensable. These products are discreet, flavored, and easy for students to use without detection, including in schools. NYTS data show that hundreds of thousands of middle and high school students are already using these highly addictive products. Without annual, school-based surveillance, the FDA and public health officials could miss the early stages of a new youth nicotine epidemic and its possible impact on smoking and vaping until it is much more difficult to control. The NYTS is therefore essential not only for documenting current use, but also for identifying emerging products early enough to guide prevention, enforcement, education, and regulatory action.
We urge the FDA to maintain the annual administration of the NYTS and ensure that the survey remains comprehensive, scientifically rigorous, and comparable across years. Consistency is important because policymakers and researchers need to distinguish true changes in youth behavior from changes caused by survey methods or question wording. At the same time, the survey must be updated as needed to capture emerging products, new marketing strategies, online access, social sources of tobacco products, flavored products, and youth exposure to digital and social media advertising.
The current tobacco control environment makes the NYTS even more important. Federal, state, and local tobacco control programs depend on timely data to make evidence-based decisions. However, uncertainty in public health funding, changes in tobacco policy, and the continued introduction of new nicotine products all increase the need for reliable national surveillance. Without the NYTS, FDA and other public health stakeholders would have less ability to identify harmful trends, respond quickly, and evaluate whether current laws, programs, and enforcement are adequately protecting young people.
Timely analysis and dissemination of NYTS findings are also essential. The FDA should ensure that survey results, methodology, questionnaires, and key findings are made publicly available as quickly as possible while protecting confidentiality. Delays in reporting reduce the usefulness of the data, particularly when youth product trends and marketing practices can change quickly.
In summary, NCHR strongly supports the FDA’s continued collection of NYTS data for 2027-2029. NYTS is essential, has clear practical utility, and plays a vital role in evaluating and protecting children and adolescents from tobacco and nicotine-related harm. The FDA should continue this annual survey, maintain its scientific rigor and transparency, and ensure that the data are released in a timely manner to support evidence-based tobacco control policies and programs.
Respectfully,
National Center for Health Research
Washington, D.C.