On March 11, 2026, the FDA published a draft guidance that fundamentally changes how flavored e-cigarette products will be evaluated under the PMTA process. The guidance (Docket No. FDA-2026-D-1817, 91 Fed. Reg. 11,980) creates a two-tier flavor risk system, and just weeks later, the FDA authorized the first-ever non-tobacco, non-menthol flavored ENDS products — Glas G2 Gold (mango) and Sapphire (blueberry) — using device access restriction (DAR) technology. Twenty-one state attorneys general ar