NCHR Public Comment on the Continued Implementation of the National Youth Tobacco Survey

August 15, 2025

Re: Proposed Data Collection Submitted for Public Comment and Recommendations; Docket No. CDC–2024–0106

The National Center for Health Research (NCHR) appreciates the opportunity to submit these comments in strong support of the continued implementation of the National Youth Tobacco Survey (NYTS) for the 2026-2028 cycle. 

NCHR is a nonprofit think tank committed to advancing evidence-based policies that improve the health of adults and children. We focus on evaluating medical products, prevention strategies, and public health surveillance systems to ensure they are safe and effective. We are very concerned about the health risks associated with youth tobacco and nicotine use.

We strongly support the continued implementation of the National Youth Tobacco Survey (NYTS) for the 2026-2028 cycle. NYTS is the cornerstone of public health surveillance in this field. Discontinuing or significantly weakening it would create an irreversible gap in the nation’s health data infrastructure. The sustained operation of NYTS is an essential prerequisite for the effective implementation of public health strategies, and an essential component of the MAHA movement.

NCHR Recommendations

We respectfully urge CDC and FDA to jointly support and implement the National Youth Tobacco Survey for the 2026–2028 cycle, including the following priorities:

  1. Retain core trend measures to ensure continuity in time-series analysis, while expanding items that address emerging products (e.g., nicotine pouches, synthetic nicotine);
  2. Ensure oversampling of key populations, including but not limited to under-represented age groups, racial/ethnic minorities, and adolescents with mental health risks;
  3. Release the full public use dataset for each wave promptly and restore datasets from 2020–2023 which were recently removed from public websites; and
  4. Preserve CDC’s scientific leadership in survey design and analysis, while supporting strong interagency collaboration with FDA to ensure funding and continuity.

NYTS Is Irreplaceable for National Youth Tobacco Surveillance

Since its annual implementation beginning in 2004, the NYTS has remained the sole nationally representative source on tobacco and nicotine use among middle school students (grades 6–8) and the most comprehensive dataset for high school students (grades 9–12) [1]. NYTS captures a full spectrum of tobacco and nicotine products. These include traditional cigarettes, cigars, e‑cigarettes, heated tobacco, nicotine pouches, and newer synthetic products [2]. This dataset allows for the tracking of both established and emerging patterns of use. NYTS also measures behavioral variables, such as exposure to pro‑ and anti‑tobacco messaging, social norms, perceived harms, peer influence, pathways of access, dependence indicators, and cessation behaviors, along with contextual factors like mental health and school connectedness [1]. 

The NYTS is the only national survey that provides this level of detail on an annual basis. Surveys such as the Population Assessment of Tobacco and Health (PATH), which focuses on longitudinal regulatory research; the Youth Risk Behavior Surveillance System (YRBSS), which is limited to high schoolers and conducted biennially; and the National Survey on Drug Use and Health (NSDUH), which covers broader substance use across age groups, offer valuable data. However, none of them match the NYTS in comprehensive youth-specific tobacco surveillance [3]. The rapid release cycles of NYTS support timely and responsive policy action. For example, when JUUL’s popularity surged among youth between 2017-2019, NYTS was the only system capturing the magnitude and speed of adoption, a responsiveness that remains unmatched in national surveillance [4] [5].

NYTS Has a Proven Track Record and Will Contribute to MAHA Goals

NYTS data have driven some of the most consequential youth tobacco policies. For example, between 2017 and 2019, NYTS data showed that current e-cigarette use among high school students more than doubled, rising from 11.7% to 27.5%, prompting the FDA to declare youth vaping an “epidemic” and initiate enforcement actions restricting flavored products [6] [7]. These findings also informed the federal Tobacco 21 law, raising the minimum purchase age to 21, which is a milestone policy supported by evidence showing youth nicotine use trends [1] [8]. Furthermore, NYTS data underpinned evaluation of FDA’s “The Real Cost” campaign by tracking shifts in youth perceptions and behavior over time [1] [9] [10]. NYTS has also provided evidence that some youth are more at risk than others, which provides state and local governments with the information they need to develop policies to improve the health of all their children [1]. Taken together, NYTS has served as the early warning system that benefits federal and state health strategies.

NYTS provides the empirical foundation the FDA needs to fulfill its statutory mandate under the Family Smoking Prevention and Tobacco Control Act of 2009 to prioritize youth protection in tobacco regulation [4] [11]. Without it, the agency lacks a reliable means to monitor youth use trends, assess product-specific risk, or measure regulatory impact. Additionally, NYTS informs at least seven Healthy People 2030 objectives [2]. These include tracking adolescent use of e‑cigarettes, cigarettes, flavored products, and other nicotine-containing products [2]. In addition, state Youth Tobacco Surveys can be compared with NYTS data to better evaluate local progress.

In conclusion, youth nicotine and tobacco use are serious and constantly changing public health concerns. NYTS is the most reliable national system for identifying emerging trends and guiding effective prevention strategies. Discontinuing or weakening this survey would severely undermine efforts to reduce youth exposure to nicotine and tobacco products and to prevent long-term addiction.

We strongly support the full approval and continued implementation of this essential survey. For questions or further discussion, we can be reached at info@center4research.org

 

References

 

  1. Gentzke AS, Wang TW, Cornelius M, et al. Tobacco product use and associated factors among middle and high school students — National Youth Tobacco Survey, United States, 2021. MMWR Surveill Summ. 2022;71(5):1-29. doi:10.15585/mmwr.ss7105a1
  2. Centers for Disease Control and Prevention. About National Youth Tobacco Survey (NYTS). CDC Smoking and Tobacco Use. Updated May 15, 2024. Accessed Aug 11, 2025. https://www.cdc.gov/tobacco/about-data/surveys/national-youth-tobacco-survey.html
  3. Boakye E, Erhabor J, Obisesan O, et al. Comprehensive review of the national surveys that assess E-cigarette use domains among youth and adults in the United States. Lancet Reg Health Am. 2023;23:100528. doi:10.1016/j.lana.2023.100528
  4. Wang TW, Gentzke AS, Creamer MR, et al. Tobacco product use and associated factors among middle and high school students — United States, 2019. MMWR Surveill Summ. 2019;68(12):1-22. doi:10.15585/mmwr.ss6812a1
  5. Cullen KA, Gentzke AS, Sawdey MD, et al. e-Cigarette use among youth in the United States, 2019. JAMA. 2019;322(21):2095-2103. doi:10.1001/jama.2019.18387
  6. Creamer MR, Jones SE, Gentzke AS, Jamal A, King BA. Tobacco product use among high school students — Youth Risk Behavior Survey, United States, 2019. MMWR Suppl. 2020;69(1):56-63. doi:10.15585/mmwr.su6901a7
  7. US Food and Drug Administration. Spotlight on Science – Winter 2020. Updated January 9, 2020. Accessed Aug 11, 2025. https://www.fda.gov/tobacco-products/ctp-newsroom/spotlight-science-winter-2020
  8. Agaku IT, Nkosi L, Agaku QD, Gwar J, Tsafa T. A rapid evaluation of the US Federal Tobacco 21 (T21) law and lessons from statewide T21 policies: findings from population-level surveys. Prev Chronic Dis. 2022;19:210430. doi:10.5888/pcd19.210430
  9. The ASCO Post Staff. The Real Cost campaign may have prevented thousands of youths from initiating e-cigarette use. The ASCO Post. March 18, 2025. Accessed Aug 11, 2025. https://ascopost.com/news/march-2025/the-real-cost-campaign-may-have-prevented-thousands-of-youths-from-initiating-e-cigarette-use/ 
  10. Kowitt SD, Sheldon JM, Vereen RN, et al. The impact of The Real Cost vaping and smoking ads across tobacco products. Nicotine Tob Res. 2023;25(3):430-437. doi:10.1093/ntr/ntac206
  11. US Food and Drug Administration. Family Smoking Prevention and Tobacco Control Act – An Overview. Updated August 29, 2024. Accessed Aug 11, 2025. https://www.fda.gov/tobacco-products/rules-regulations-and-guidance-related-tobacco-products/family-smoking-prevention-and-tobacco-control-act-overview