Flaws in FDA's regulatory impact analysis on graphic warning labels (GWL)
| 1 | FDA used cigarette excise taxes rather than actual prices paid by smokers, which reduced the estimated impact of GWLs on smoking prevalence | ||
| Canada | USA | ||
| Inflation-adjusted average cigarette taxes (2001–2009) | Increased by 123% | Increased by 117% | |
| Average inflation-adjusted official cigarette price indices (2001–2009) | Increased by 64% | Increased by 42% | |
| Average cigarette prices actually paid by smokers (2002–2011) | Decreased by 4% | Increased by 25% | |
| 2 | FDA did not utilise all available data points in the entire study period (1991–2009) in projecting smoking prevalence in the USA and Canada | ||
| 3 | It is impossible to ascertain whether the estimated impact of GWLs on smoking prevalence from FDA's approach is statistically different from zero. | ||
| 4 | FDA's approach does not allow causal interpretations of the effect of GWLs on smoking prevalence | ||
FDA, Food and Drug Administration.