From Record Lows to Targeted Enforcement: Reading the 2025 U.S. Youth Tobacco Survey Data

On June 23 and 24, 2026, the FDA released two sets of data in succession: the results of the 2025 National Youth Tobacco Survey (NYTS) with an accompanying peer-reviewed paper, and a significant study demonstrating the effectiveness of its public health advertising. The timing was deliberate. Just as the FDA's capacity to authorize flavored e-cigarettes and to act against illegal products was being repeatedly questioned, the data supplied regulators with a self-consistent rationale: youth tobacco use continues to decline and the advertising interventions are demonstrably effective, so newly authorized flavored products rest on a reasonable basis.

Within the same data, however, lies a warning of real importance to Chinese vape exporters: in the 2025 NYTS ranking of brands most commonly used by youth e-cigarette users, Chinese-manufactured brands took the top four places, with one brand alone accounting for more than 60% of youth users. That official survey data is now providing the targeting basis for the FDA's current and future enforcement. This note reviews the substance of the releases and reads the legal signals of practical significance to exporters. It is a general overview and does not constitute legal advice on any particular matter.

I. What Was Released

1. NYTS 2025: Record-Low Youth Tobacco Use, but Flavor and Brand Composition Remain Serious

On June 23, 2026, the FDA published the 2025 NYTS data and announced a peer-reviewed paper in Nicotine & Tobacco Research. The survey covers U.S. middle and high school students. Principal findings:

• In 2025, 7.2% of U.S. middle and high school students — about 2 million — reported current use (any use in the past 30 days) of any tobacco product, a record low.
• From 2022 to 2025, overall youth tobacco use, e-cigarette use, and cigarette use all declined steadily.
• E-cigarettes remain the most used category, with 5.2% of students (about 1.44 million) reporting current use — down from 5.9% in 2024, though the two-year change was not statistically significant.
• About 90% of current e-cigarette users used flavored products, with fruit flavors the most popular.
• The brands most commonly used by youth e-cigarette users in 2025: Geek Bar (64.1%), Elf Bar (21.5%), Lost Mary (19.8%), Raz (19.5%), Vuse (15.9%) — the top four all Chinese-manufactured.
• Nicotine pouch use was 1.7%, essentially flat against 2024 and low overall.
• Among nicotine pouch users, ZYN led at 69.2% and on! was second at 14.6%; more than 90% used flavored products, with menthol the most popular.

2. "The Real Cost" Prevention Campaign: 444,000 Youth Prevented From Starting; $42 Million in Illegal Sales Averted

On June 24, 2026, the FDA announced a special issue of the American Journal of Preventive Medicine presenting ten years of results from "The Real Cost" youth e-cigarette prevention campaign. The issue contains twelve peer-reviewed papers and a commentary from Bret Koplow, Acting Director of the FDA's Center for Tobacco Products. Principal findings:

• Headline result: one study found the campaign prevented approximately 444,000 U.S. youth from beginning e-cigarette use between 2023 and 2024.
• Economic quantification: the FDA estimates that prevention also averted more than $42 million in illegal e-cigarette purchases over the same period.
• Reach: 75% of youth surveyed saw at least one e-cigarette prevention advertisement during the study period; the campaign also drove more than 253,000 visits to the National Cancer Institute's youth smoking cessation site in 2021–2022.
• Ten-year analysis: a decade of advertising testing data shows the FDA's tobacco prevention advertising has been consistently effective in changing youth attitudes and perceptions, with e-cigarette prevention advertising particularly so.

The FDA is exploring extending this advertising strategy to adult smokers — preventing youth access while helping adult smokers understand how to reduce tobacco harm.

II. Reading the Signals: Three Practical Trends

1. NYTS Data Now Serves Both Enforcement and Authorization Decisions

The timing of the release repays attention. On one hand, continued declines in youth e-cigarette use directly support the FDA's earlier authorization of Glas flavored products: use is at a manageable level, and introducing flavored products with device access restriction (DAR) technology does not harm public health but rather provides an alternative for adults seeking to quit.

In the nicotine pouch category, ZYN — with years of market leadership and the first-mover advantage of PMTA authorization — has built a substantial compliance barrier. Brands entering later must show through data that their user base is predominantly adult with low youth penetration; that is among the baseline thresholds for PMTA review.

2. Youth Use Is at a Record Low — but Their Leading Brand Is Unauthorized

Following the release, the major U.S. public health organizations — the American Heart Association, the Campaign for Tobacco-Free Kids, Truth Initiative, and others — responded consistently: the decline in youth tobacco use is genuine progress and should be acknowledged, but it cannot obscure a troubling fact — most of what youth users hold remains product the FDA has never authorized.

Put differently, the decline in overall youth use comes principally from the combined effect of public education and enforcement; the share of illegal product in youth channels has not contracted correspondingly. Geek Bar leads at 64.1% of youth users and remains without PMTA authorization — a paradigm illegal product on sale. That indicates enforcement remains limited in effect: large volumes of unauthorized product continue to circulate normally, and it is precisely that product youth encounter most.

The American Heart Association also observed that the data was released immediately after the FDA authorized mango and blueberry flavored e-cigarettes — timing that is itself a concern, given that nearly 90% of youth e-cigarette users use flavored products and fruit flavors are the most popular.

Against that background, the FDA's decision to expand flavor authorizations will inevitably invite questions about whether it will increase youth exposure to flavored products.

For Chinese exporters the message is clear: the room to maintain a market presence on the assumption that illegal products are too numerous, regulatory resources too limited, and enforcement too slow to reach you is being systematically compressed. Multi-agency enforcement will only intensify.

3. Build Adult-Use Evidence Now, Against the Youth Appeal Criteria in PMTA Review

NYTS has now told the public and PMTA reviewers plainly that fruit and candy/dessert flavors are the most popular among youth. For companies whose business rests on those flavors, a PMTA must contain adequate data establishing that the real target users are adult smokers rather than youth. Concretely: design and accumulate usage data across age groups in advance — user profiles, purchase channels, reasons for use, and cessation outcomes — and proactively avoid any visual or flavor element in product design and marketing materials that could be found appealing to youth. The earlier and more solidly that work is done, the lower the risk of deficiency letters or denial in PMTA review.

Closing

The two data releases of June 23–24, 2026 present, on their face, the interim results of U.S. youth tobacco control. In substance they may have clarified the direction of the next stage of enforcement: the fact that Chinese-manufactured brands dominate youth e-cigarette consumption has now formally entered the FDA's enforcement field of view in the form of official survey data. For the companies concerned, that is not a badge of market influence but a reference coordinate for targeted regulatory pressure. Undertaking a compliance assessment and planning strategically in advance is the response of greatest value now.

References

1. American Heart Association, "As youth tobacco use declines, flavored e-cigarettes and nicotine pouches are a continued concern" (June 24, 2026)
2. Campaign for Tobacco-Free Kids, "National Survey Shows Long-Term Drop in Youth Tobacco Use" (June 23, 2026)
3. Eunice Park-Lee et al., "Tobacco product use among middle and high school students in the United States: NYTS 2025," Nicotine & Tobacco Research, ntag116 (June 23, 2026)
4. Truth Initiative, "New Federal Study Highlights Progress on Youth E-Cigarette Use, but Nicotine Addiction Risks for Young People Remain" (June 24, 2026)
5. U.S. FDA, "National Youth Tobacco Survey: FDA Publishes Peer-Reviewed Journal Article, Releases 2025 Findings" (June 23, 2026)
6. U.S. FDA, "Results from the Annual National Youth Tobacco Survey (NYTS)" (updated June 23, 2026)
7. U.S. FDA, "Studies Show FDA Educational Efforts Help Prevent Youth From Starting E-Cigarette Use, Illegal E-Cigarette Sales" (June 24, 2026)

This article addresses general legal questions only and does not constitute legal advice on any specific matter.