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Scientific Policy Memoranda about FDA Review of Tobacco Product Applications

Memoranda to assist reviewers with evaluation of tobacco product applications. This information adds detail about key areas of regulatory science.

FDA’s policy memoranda provide details about key areas of regulatory science and were written to assist reviewers with the evaluation of new tobacco product applications.  FDA has made these documents public because they may provide useful information for the preparation of tobacco product applications.

Information contained in these memos is subject to change based on advances in policy, the regulatory framework, and regulatory science, and is not binding on FDA or the public. These memos may serve as a useful additional reference, however, they should not be used as a comprehensive manual for preparing or anticipating review of tobacco product applications, as they represent FDA’s approach at the time these memos were written.  


  1. Unique Identification of Portioned Moist Snuff and Snus Products
  2. Unique Identification of Tobacco Products


  1. SE Review: Toxicological Implications of Fire Standards Compliant (FSC) Paper
  2. SE Review: Evaluation of Estimated HPHC Impact of Single Ingredient (saccharides) Pyrolysis
  3. SE Review: Evaluation of Multiple Ingredient Changes
  4. SE Review: Use of Propylene Glycol in Smokeless Tobacco Products
  5. Use of Surrogate Tobacco Products in SE Reports
  6. SE Review: Evaluating Carcinogenic HPHC Increases and Assumption of Linearity for Low Dose Extrapolation
  7. Use of Cigarette Designer and Other Models to Predict HPHC Yields in SE Reports
  8. Effects of Increases of Ammonia and Other Basic Compounds on the Transfer of Free-Base Nicotine to Tobacco Smoke 
  9. Equivalence Testing for SE Evaluations
  10. Distribution of Menthol in Cigarettes and Smoke Transfer 
  11. Use of Reverse Engineering to Reproduce Tobacco Products that are No Longer Manufactured or For Which Characteristics are Not Available
  12. Review of Saccharides as Tobacco Ingredients: Effects on Smoke Chemistry 
  13. Dissolution as a Critical Comparison of Smokeless Product Performance: SE Requirements and Recommendations for the Review of Dissolution Studies 
  14. Harmful and Potentially Harmful Constituent (HPHC) Comparison and Evaluation Procedure for Comparing Two Tobacco Products in the Substantial Equivalence Reports
  15. Use of Reference Values in the Toxicological Evaluation of Inhaled Tobacco Products


  1. Engineering Review of Substantial Equivalence (SE) Reports for Originally Regulated Products

Social Science

  1. Product Quantity Changes in Substantial Equivalence Reports (SE Reports) for Statutorily Regulated Tobacco Products
  2. Effects of Tobacco Product Package Shape on Consumer Perceptions, Initiation, and Cessation

Behavioral and Clinical Pharmacology

  1. BCP Reviews of Characteristic Changes in SE Reports


  1. Substantial Equivalence Reports: Recommended requirements for stability testing of smokeless tobacco products

FDA recommends the following tools serve as primary resources for the preparation of SE Reports, requests for Exemption from SE, or Premarket Tobacco Product Applications:

Learn more about the various pathways to market and distribute a tobacco product.

Additional Resources