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Brownstone Institute

Is the WEF the Headquarters of Evil?

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This article is printed with permission of the Brownstone Institute
Back in 1983, Ronald Reagan colorfully described the Soviet Union as “the focus of evil in the modern world.” Today, it seems we have a new candidate for the headquarters of all evil: the World Economic Forum headed by Klaus Schwab.

The WEF has no borders, includes all nationalities, embraces governments, NGOs and big business, has no military, nuclear arsenal, flag or anthem, and purports to solve all the world’s problems at its annual conference each year while delegates down champagne and caviar. It sponsors a leadership training program that boasts such covid cultists as Emmanuel Macron, Jacinda Ardern and Justin Trudeau. Is Klaus Schwab the first honest-to-goodness Bond villain, bent on taking over (or depopulating) the world?

Professor Schwab certainly looks the part with his German accent and his prize place on top of the Swiss mountains. He also certainly pretends to run the world. In fact, he has been pretending to run the world since the 1970s, when he started his yearly conferences, hoping to get noticed. Getting noticed took decades. Many of the WEF Young Leaders program graduates presently in power around the world only entered his ‘classes’ 30 years after the WEF started. For decades Klaus has lived the ‘fake it till you make it’ adage. Has he finally made it?

The title of Klaus’ 2020 book “The Great Reset”, coauthored with Thierry Malleret, was catchy enough to be taken on as a slogan during 2020-21 by a slew of political leaders wanting to communicate for myriad local political reasons that the pandemic has opened up some kind of grand reinitialization opportunity in global politics.

Few of these leaders will have read the book though, because if they had, they would have been taken aback by some of its contents. For example: “First and foremost, the post-pandemic era will usher in a period of massive wealth redistribution, from the rich to the poor and from capital to labour.”

Such a view is not commonly spouted by the über-rich barons running global corporations or the governments they influence, for the obvious reason that it constitutes a direct attack on their stash. Certainly they might publicly express the wish for less inequality – who wouldn’t? – but many would baulk at a “massive wealth redistribution,” Robin-Hood style, to labourers and away from capitalists like themselves.

In fact, over the last two years the exact opposite has happened: the world now contains more billionaires and more poor people. “You will own nothing and be happy,” another oft-quoted and much-maligned Schwabism, also describes the opposite of what has actually happened, which can be summarized instead as “the rich own lots more while the poor own nothing and are miserable.”

This year, the WEF meeting in Davos, Switzerland held from May 22-26 triggered the usual outpouring of hatred on Twitter and other platforms. The gossip implies that the WEF is secretly plotting to take over the world by means of a secret collaboration between government and big business, as if rich and powerful people needed a vehicle like the WEF for that. It feels satisfying to those wronged by covid policy to think they have identified the head of the snake responsible for the mess.

The WEF, they claim, is the coordinating platform for all the secret deals that make the rich richer and the entrenched heads of government more powerful, while national and local sovereignty is being clandestinely forfeited, leaving the ordinary person to rot away slowly with neither resources nor rights.

These accusations against the WEF are accompanied by misrepresentation and outright fakery. Photos were recently circulated on social media of hundreds of private planes lined up on an airfield, claimed to be those of attendees at Davos 2022 who were (for shame!) flouting their own pretensions to reduce carbon emissions. According to Reuters, one of the two widely circulated photos was in fact taken years ago at Las Vegas Airport around the time of a boxing title fight between Floyd Mayweather Jr. and Manny Pacquiao, while another was taken in January 2016 at a Swiss air force base that is often used by Davos attendees and was probably associated with the event that year.

None of us was able personally to fly to Davos this year (though some of us have attended such events in the past), but no matter: every session of the 2022 meeting from May 22-26 was posted online.  This included the opening address, via video link, by none other than Ukrainian president Volodymyr Zelensky, resplendent in his trademark brown tee and staring down the camera with unblinking intensity. Invigorated by the President’s defiant address, attendees turned their attention to the remaining 220 or so sessions that covered every weighty and worldly topic under the sun.

We took the time to watch a few, and found them to share a few characteristics.  First, those involved expressed overblown expectations of what would be achieved during the discussions.  Second, the discussions themselves were intelligent and informative. Third, the discussions all led to no particular kind of action.

The basic model of a WEF conference session is to subsidize smart people (the presenters) to say smart things to rich people (the audience), who themselves pay the exorbitant conference registration fees in order to network with each other and have smart people pretend to take them seriously for a few days.

In a word, Klaus Schwab is a glorified and very talented conference planner selling flattery. He pretends that $60,000 provides the attending customer with access to crucial world decisions, all made in 4 days. The hordes paying the entry fee schmooze together, down vast quantities of wine and canapes, and participate in panel discussions that purport to solve problems associated with the world’s economy, environment, and society in end-on-end blocks of 45 minutes each. (Actually, it is closer to 35 minutes, because of 10 minutes of Q&A from the audience squeezed in at the end of each session.  Given the price tag of attendance, the organizers rightly expect some delegates to feel justified in having their moment on the mic.)

Typical of the level of ambition evident in WEF conference sessions, in his introduction to this year’s session on global taxation, host Geoff Cutmore announced that the incipient panel discussion was about getting to a point where “we all feel comfortable about what we’re paying, and we feel comfortable about what other people are paying and we feel comfortable about what corporations are paying and we all feel comfortable about where that tax revenue is ultimately going.”

Whoa.  He might have added, “And if we have a few minutes left over at the end, we’ll work out how to restore the Amazonian rain forest.” The panel consisted of the heads of both Oxfam and the OECD, plus a heavily masked economics professor from Harvard. Imagine what the head of Oxfam would have thought about Cutmore’s pronouncements, given how critical Oxfam has been of the tax evasion and self-enrichment of elites, particularly in the last 2 years.  If only he could get the conference delegates to pay their taxes and stop robbing poor people, he could axe Oxfam altogether!

Some sessions do make the stomach turn. For example, in one, Pfizer announced an “Accord for a Healthier World,”  with its CEO sitting alongside Bill Gates and two African potentates. Announcements like this are made at the WEF, but would they really not exist if not for the WEF? Unlikely. By providing a platform for such announcements, however, it becomes a lightning rod for suspicion. The WEF styles itself an “International Organization for Public-Private Cooperation,” and like any large entity of its kind, it wants to get even bigger and more influential. But at heart, this is business. Klaus Schwab’s business.

The WEF claims serious positive impacts. For example, its ‘First Movers Coalition’ consists of 50 companies that have committed to investing in green technologies and removing carbon. Sounds great, right? The snag, of course, is that they have set up the measurement in such a way that they are able to decide themselves what is meant by ‘green’ or by ‘removing’ carbon. You can count caretaking a forest today as ‘removing’ carbon, and as long as the audience doesn’t know that you cut down and burned a mature forest in the same place last year, they will applaud!

Similarly, the WEF champions a system of reporting called ‘Stakeholder Capitalism Metrics’ (containing environmental, social, and governance, or “ESG,” measures), developed in a cooperative effort with major accounting firms and adopted by 70 companies. Paying a reasonable amount of taxes is not in those KPIs. Nor is free speech. Metrics, but not as you know them.

But what about the smoking gun represented in the many top politicians of today’s world who graduated from the WEF’s Young Leaders program? What about the creepy 2019 WEF conference about what to do in a pandemic?

On the Young Leaders program, it is undoubtedly true that the WEF has become a very successful job networking organization. But it did not invent networking. Networking societies for the rich and powerful have existed for centuries. Think of the Freemasons, the Rotary society, Chatham House, private high schools, Oxbridge, or the Ivy League. The rich and powerful will network with each other, come hell or high water, WEF or no WEF.

Perhaps those who met at the WEF have gelled together on an evil ideology that is bad for the world, but that ideology is clearly not the “Great Reset” ideology articulated by Schwab, since they are not following it in the slightest. Why then does Schwab not protest at how politicians are pretending to enact a Great Reset that is the very opposite of what he advocated in his book? Because he does not really care about his own ideas. A puffed-up conference organizer, Schwab follows his flock of customers rather than leading them. He is being used as a stooge.

OK, but what about that 2019 pandemic simulation conference? Again, you can read all about it online, a level of publicity for their plans that is surely not what you would expect of Bond villains. In these simulations, the WEF folks came to the conclusion that during a pandemic, movement and trade should not be disrupted because of the high costs to society. Yes, you read that right.  Once again, this is the very opposite of what was actually done.

The WEF pandemic conference was just one of the many ‘war games’ simulations that entertain people continuously all around the world. Pandemic simulations this week, asteroid simulations next week, killer bee simulations after that. Rather a lot of problems can be covered off in 220 sessions, and one of them is bound to be tomorrow’s news.

The total disconnect between what his pandemic conference said should be done and what actually happened during covid times is once again proof that Klaus is not led by his principles.  If he were, he would have been loudly protesting what has gone on over the past two years. Instead, he is merely riding his “good luck” that the leaders who came to drink champagne at his events have now embraced him as their supposed figurehead.

Since he is well into his 80s, Klaus probably figures that if an angry world population came to believe that he was responsible for the disaster that has befallen them, he’d be dead long before they came for justice. Thierry Malleret, his younger co-author on “The Great Reset,” has more to worry about in that regard!

The WEF, in sum, is hot air all the way.  It is led by a man who epitomizes pomp, which is nothing new in the circles of the rich and powerful. WEF-approved hot air is no different to the regular variety.

Sure, it’s a place where schmoozing and coordination happen, but the WEF invented neither schmoozing nor the idea of an old-boys club. It is simply the current clubhouse. The real culprits will find another venue the day after the WEF’s shingle is taken down.

Authors

  • Paul Frijters is a Professor of Wellbeing Economics at the London School of Economics: from 2016 through November 2019 at the Center for Economic Performance, thereafter at the Department of Social Policy

  • Gigi Foster, senior scholar of Brownstone Institute, is a Professor with the School of Economics at the University of New South Wales, having joined UNSW in 2009 after six years at the University of South Australia.

  • Michael Baker has a BA (Economics) from the University of Western Australia. He is an independent economic consultant and freelance journalist with a background in policy research.

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Brownstone Institute

The Unmasking of Vaccine Science

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From the Brownstone Institute

By Maryanne DemasiMaryanne Demasi  

I recently purchased Aaron Siri’s new book Vaccines, Amen.  As I flipped though the pages, I noticed a section devoted to his now-famous deposition of Dr Stanley Plotkin, the “godfather” of vaccines.

I’d seen viral clips circulating on social media, but I had never taken the time to read the full transcript — until now.

Siri’s interrogation was methodical and unflinching…a masterclass in extracting uncomfortable truths.

In January 2018, Dr Stanley Plotkin, a towering figure in immunology and co-developer of the rubella vaccine, was deposed under oath in Pennsylvania by attorney Aaron Siri.

The case stemmed from a custody dispute in Michigan, where divorced parents disagreed over whether their daughter should be vaccinated. Plotkin had agreed to testify in support of vaccination on behalf of the father.

What followed over the next nine hours, captured in a 400-page transcript, was extraordinary.

Plotkin’s testimony revealed ethical blind spots, scientific hubris, and a troubling indifference to vaccine safety data.

He mocked religious objectors, defended experiments on mentally disabled children, and dismissed glaring weaknesses in vaccine surveillance systems.

A System Built on Conflicts

From the outset, Plotkin admitted to a web of industry entanglements.

He confirmed receiving payments from Merck, Sanofi, GSK, Pfizer, and several biotech firms. These were not occasional consultancies but long-standing financial relationships with the very manufacturers of the vaccines he promoted.

Plotkin appeared taken aback when Siri questioned his financial windfall from royalties on products like RotaTeq, and expressed surprise at the “tone” of the deposition.

Siri pressed on: “You didn’t anticipate that your financial dealings with those companies would be relevant?”

Plotkin replied: “I guess, no, I did not perceive that that was relevant to my opinion as to whether a child should receive vaccines.”

The man entrusted with shaping national vaccine policy had a direct financial stake in its expansion, yet he brushed it aside as irrelevant.

Contempt for Religious Dissent

Siri questioned Plotkin on his past statements, including one in which he described vaccine critics as “religious zealots who believe that the will of God includes death and disease.”

Siri asked whether he stood by that statement. Plotkin replied emphatically, “I absolutely do.”

Plotkin was not interested in ethical pluralism or accommodating divergent moral frameworks. For him, public health was a war, and religious objectors were the enemy.

He also admitted to using human foetal cells in vaccine production — specifically WI-38, a cell line derived from an aborted foetus at three months’ gestation.

Siri asked if Plotkin had authored papers involving dozens of abortions for tissue collection. Plotkin shrugged: “I don’t remember the exact number…but quite a few.”

Plotkin regarded this as a scientific necessity, though for many people — including Catholics and Orthodox Jews — it remains a profound moral concern.

Rather than acknowledging such sensitivities, Plotkin dismissed them outright, rejecting the idea that faith-based values should influence public health policy.

That kind of absolutism, where scientific aims override moral boundaries, has since drawn criticism from ethicists and public health leaders alike.

As NIH director Jay Bhattacharya later observed during his 2025 Senate confirmation hearing, such absolutism erodes trust.

“In public health, we need to make sure the products of science are ethically acceptable to everybody,” he said. “Having alternatives that are not ethically conflicted with foetal cell lines is not just an ethical issue — it’s a public health issue.”

Safety Assumed, Not Proven

When the discussion turned to safety, Siri asked, “Are you aware of any study that compares vaccinated children to completely unvaccinated children?”

Plotkin replied that he was “not aware of well-controlled studies.”

Asked why no placebo-controlled trials had been conducted on routine childhood vaccines such as hepatitis B, Plotkin said such trials would be “ethically difficult.”

That rationale, Siri noted, creates a scientific blind spot. If trials are deemed too unethical to conduct, then gold-standard safety data — the kind required for other pharmaceuticals — simply do not exist for the full childhood vaccine schedule.

Siri pointed to one example: Merck’s hepatitis B vaccine, administered to newborns. The company had only monitored participants for adverse events for five days after injection.

Plotkin didn’t dispute it. “Five days is certainly short for follow-up,” he admitted, but claimed that “most serious events” would occur within that time frame.

Siri challenged the idea that such a narrow window could capture meaningful safety data — especially when autoimmune or neurodevelopmental effects could take weeks or months to emerge.

Siri pushed on. He asked Plotkin if the DTaP and Tdap vaccines — for diphtheria, tetanus and pertussis — could cause autism.

“I feel confident they do not,” Plotkin replied.

But when shown the Institute of Medicine’s 2011 report, which found the evidence “inadequate to accept or reject” a causal link between DTaP and autism, Plotkin countered, “Yes, but the point is that there were no studies showing that it does cause autism.”

In that moment, Plotkin embraced a fallacy: treating the absence of evidence as evidence of absence.

“You’re making assumptions, Dr Plotkin,” Siri challenged. “It would be a bit premature to make the unequivocal, sweeping statement that vaccines do not cause autism, correct?”

Plotkin relented. “As a scientist, I would say that I do not have evidence one way or the other.”

The MMR

The deposition also exposed the fragile foundations of the measles, mumps, and rubella (MMR) vaccine.

When Siri asked for evidence of randomised, placebo-controlled trials conducted before MMR’s licensing, Plotkin pushed back: “To say that it hasn’t been tested is absolute nonsense,” he said, claiming it had been studied “extensively.”

Pressed to cite a specific trial, Plotkin couldn’t name one. Instead, he gestured to his own 1,800-page textbook: “You can find them in this book, if you wish.”

Siri replied that he wanted an actual peer-reviewed study, not a reference to Plotkin’s own book. “So you’re not willing to provide them?” he asked. “You want us to just take your word for it?”

Plotkin became visibly frustrated.

Eventually, he conceded there wasn’t a single randomised, placebo-controlled trial. “I don’t remember there being a control group for the studies, I’m recalling,” he said.

The exchange foreshadowed a broader shift in public discourse, highlighting long-standing concerns that some combination vaccines were effectively grandfathered into the schedule without adequate safety testing.

In September this year, President Trump called for the MMR vaccine to be broken up into three separate injections.

The proposal echoed a view that Andrew Wakefield had voiced decades earlier — namely, that combining all three viruses into a single shot might pose greater risk than spacing them out.

Wakefield was vilified and struck from the medical register. But now, that same question — once branded as dangerous misinformation — is set to be re-examined by the CDC’s new vaccine advisory committee, chaired by Martin Kulldorff.

The Aluminium Adjuvant Blind Spot

Siri next turned to aluminium adjuvants — the immune-activating agents used in many childhood vaccines.

When asked whether studies had compared animals injected with aluminium to those given saline, Plotkin conceded that research on their safety was limited.

Siri pressed further, asking if aluminium injected into the body could travel to the brain. Plotkin replied, “I have not seen such studies, no, or not read such studies.”

When presented with a series of papers showing that aluminium can migrate to the brain, Plotkin admitted he had not studied the issue himself, acknowledging that there were experiments “suggesting that that is possible.”

Asked whether aluminium might disrupt neurological development in children, Plotkin stated, “I’m not aware that there is evidence that aluminum disrupts the developmental processes in susceptible children.”

Taken together, these exchanges revealed a striking gap in the evidence base.

Compounds such as aluminium hydroxide and aluminium phosphate have been injected into babies for decades, yet no rigorous studies have ever evaluated their neurotoxicity against an inert placebo.

This issue returned to the spotlight in September 2025, when President Trump pledged to remove aluminium from vaccines, and world-leading researcher Dr Christopher Exley renewed calls for its complete reassessment.

A Broken Safety Net

Siri then turned to the reliability of the Vaccine Adverse Event Reporting System (VAERS) — the primary mechanism for collecting reports of vaccine-related injuries in the United States.

Did Plotkin believe most adverse events were captured in this database?

“I think…probably most are reported,” he replied.

But Siri showed him a government-commissioned study by Harvard Pilgrim, which found that fewer than 1% of vaccine adverse events are reported to VAERS.

“Yes,” Plotkin said, backtracking. “I don’t really put much faith into the VAERS system…”

Yet this is the same database officials routinely cite to claim that “vaccines are safe.”

Ironically, Plotkin himself recently co-authored a provocative editorial in the New England Journal of Medicineconceding that vaccine safety monitoring remains grossly “inadequate.”

Experimenting on the Vulnerable

Perhaps the most chilling part of the deposition concerned Plotkin’s history of human experimentation.

“Have you ever used orphans to study an experimental vaccine?” Siri asked.

“Yes,” Plotkin replied.

“Have you ever used the mentally handicapped to study an experimental vaccine?” Siri asked.

“I don’t recollect…I wouldn’t deny that I may have done so,” Plotkin replied.

Siri cited a study conducted by Plotkin in which he had administered experimental rubella vaccines to institutionalised children who were “mentally retarded.”

Plotkin stated flippantly, “Okay well, in that case…that’s what I did.”

There was no apology, no sign of ethical reflection — just matter-of-fact acceptance.

Siri wasn’t done.

He asked if Plotkin had argued that it was better to test on those “who are human in form but not in social potential” rather than on healthy children.

Plotkin admitted to writing it.

Siri established that Plotkin had also conducted vaccine research on the babies of imprisoned mothers, and on colonised African populations.

Plotkin appeared to suggest that the scientific value of such studies outweighed the ethical lapses—an attitude that many would interpret as the classic ‘ends justify the means’ rationale.

But that logic fails the most basic test of informed consent. Siri asked whether consent had been obtained in these cases.

“I don’t remember…but I assume it was,” Plotkin said.

Assume?

This was post-Nuremberg research. And the leading vaccine developer in America couldn’t say for sure whether he had properly informed the people he experimented on.

In any other field of medicine, such lapses would be disqualifying.

A Casual Dismissal of Parental Rights

Plotkin’s indifference to experimenting on disabled children didn’t stop there.

Siri asked whether someone who declined a vaccine due to concerns about missing safety data should be labelled “anti-vax.”

Plotkin replied, “If they refused to be vaccinated themselves or refused to have their children vaccinated, I would call them an anti-vaccination person, yes.”

Plotkin was less concerned about adults making that choice for themselves, but he had no tolerance for parents making those choices for their own children.

“The situation for children is quite different,” said Plotkin, “because one is making a decision for somebody else and also making a decision that has important implications for public health.”

In Plotkin’s view, the state held greater authority than parents over a child’s medical decisions — even when the science was uncertain.

The Enabling of Figures Like Plotkin

The Plotkin deposition stands as a case study in how conflicts of interest, ideology, and deference to authority have corroded the scientific foundations of public health.

Plotkin is no fringe figure. He is celebrated, honoured, and revered. Yet he promotes vaccines that have never undergone true placebo-controlled testing, shrugs off the failures of post-market surveillance, and admits to experimenting on vulnerable populations.

This is not conjecture or conspiracy — it is sworn testimony from the man who helped build the modern vaccine program.

Now, as Health Secretary Robert F. Kennedy, Jr. reopens long-dismissed questions about aluminium adjuvants and the absence of long-term safety studies, Plotkin’s once-untouchable legacy is beginning to fray.

Republished from the author’s Substack

Maryanne Demasi

Maryanne Demasi, 2023 Brownstone Fellow, is an investigative medical reporter with a PhD in rheumatology, who writes for online media and top tiered medical journals. For over a decade, she produced TV documentaries for the Australian Broadcasting Corporation (ABC) and has worked as a speechwriter and political advisor for the South Australian Science Minister.

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Brownstone Institute

Bizarre Decisions about Nicotine Pouches Lead to the Wrong Products on Shelves

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From the Brownstone Institute

  Roger Bate  

A walk through a dozen convenience stores in Montgomery County, Pennsylvania, says a lot about how US nicotine policy actually works. Only about one in eight nicotine-pouch products for sale is legal. The rest are unauthorized—but they’re not all the same. Some are brightly branded, with uncertain ingredients, not approved by any Western regulator, and clearly aimed at impulse buyers. Others—like Sweden’s NOAT—are the opposite: muted, well-made, adult-oriented, and already approved for sale in Europe.

Yet in the United States, NOAT has been told to stop selling. In September 2025, the Food and Drug Administration (FDA) issued the company a warning letter for offering nicotine pouches without marketing authorization. That might make sense if the products were dangerous, but they appear to be among the safest on the market: mild flavors, low nicotine levels, and recyclable paper packaging. In Europe, regulators consider them acceptable. In America, they’re banned. The decision looks, at best, strange—and possibly arbitrary.

What the Market Shows

My October 2025 audit was straightforward. I visited twelve stores and recorded every distinct pouch product visible for sale at the counter. If the item matched one of the twenty ZYN products that the FDA authorized in January, it was counted as legal. Everything else was counted as illegal.

Two of the stores told me they had recently received FDA letters and had already removed most illegal stock. The other ten stores were still dominated by unauthorized products—more than 93 percent of what was on display. Across all twelve locations, about 12 percent of products were legal ZYN, and about 88 percent were not.

The illegal share wasn’t uniform. Many of the unauthorized products were clearly high-nicotine imports with flashy names like Loop, Velo, and Zimo. These products may be fine, but some are probably high in contaminants, and a few often with very high nicotine levels. Others were subdued, plainly meant for adult users. NOAT was a good example of that second group: simple packaging, oat-based filler, restrained flavoring, and branding that makes no effort to look “cool.” It’s the kind of product any regulator serious about harm reduction would welcome.

Enforcement Works

To the FDA’s credit, enforcement does make a difference. The two stores that received official letters quickly pulled their illegal stock. That mirrors the agency’s broader efforts this year: new import alerts to detain unauthorized tobacco products at the border (see also Import Alert 98-06), and hundreds of warning letters to retailers, importers, and distributors.

But effective enforcement can’t solve a supply problem. The list of legal nicotine-pouch products is still extremely short—only a narrow range of ZYN items. Adults who want more variety, or stores that want to meet that demand, inevitably turn to gray-market suppliers. The more limited the legal catalog, the more the illegal market thrives.

Why the NOAT Decision Appears Bizarre

The FDA’s own actions make the situation hard to explain. In January 2025, it authorized twenty ZYN products after finding that they contained far fewer harmful chemicals than cigarettes and could help adult smokers switch. That was progress. But nine months later, the FDA has approved nothing else—while sending a warning letter to NOAT, arguably the least youth-oriented pouch line in the world.

The outcome is bad for legal sellers and public health. ZYN is legal; a handful of clearly risky, high-nicotine imports continue to circulate; and a mild, adult-market brand that meets European safety and labeling rules is banned. Officially, NOAT’s problem is procedural—it lacks a marketing order. But in practical terms, the FDA is punishing the very design choices it claims to value: simplicity, low appeal to minors, and clean ingredients.

This approach also ignores the differences in actual risk. Studies consistently show that nicotine pouches have far fewer toxins than cigarettes and far less variability than many vapes. The biggest pouch concerns are uneven nicotine levels and occasional traces of tobacco-specific nitrosamines, depending on manufacturing quality. The serious contamination issues—heavy metals and inconsistent dosage—belong mostly to disposable vapes, particularly the flood of unregulated imports from China. Treating all “unauthorized” products as equally bad blurs those distinctions and undermines proportional enforcement.

My small Montgomery County survey suggests a simple formula for improvement.

First, keep enforcement targeted and focused on suppliers, not just clerks. Warning letters clearly change behavior at the store level, but the biggest impact will come from auditing distributors and importers, and stopping bad shipments before they reach retail shelves.

Second, make compliance easy. A single-page list of authorized nicotine-pouch products—currently the twenty approved ZYN items—should be posted in every store and attached to distributor invoices. Point-of-sale systems can block barcodes for anything not on the list, and retailers could affirm, once a year, that they stock only approved items.

Third, widen the legal lane. The FDA launched a pilot program in September 2025 to speed review of new pouch applications. That program should spell out exactly what evidence is needed—chemical data, toxicology, nicotine release rates, and behavioral studies—and make timely decisions. If products like NOAT meet those standards, they should be authorized quickly. Legal competition among adult-oriented brands will crowd out the sketchy imports far faster than enforcement alone.

The Bottom Line

Enforcement matters, and the data show it works—where it happens. But the legal market is too narrow to protect consumers or encourage innovation. The current regime leaves a few ZYN products as lonely legal islands in a sea of gray-market pouches that range from sensible to reckless.

The FDA’s treatment of NOAT stands out as a case study in inconsistency: a quiet, adult-focused brand approved in Europe yet effectively banned in the US, while flashier and riskier options continue to slip through. That’s not a public-health victory; it’s a missed opportunity.

If the goal is to help adult smokers move to lower-risk products while keeping youth use low, the path forward is clear: enforce smartly, make compliance easy, and give good products a fair shot. Right now, we’re doing the first part well—but failing at the second and third. It’s time to fix that.

Author

Roger Bate

Roger Bate is a Brownstone Fellow, Senior Fellow at the International Center for Law and Economics (Jan 2023-present), Board member of Africa Fighting Malaria (September 2000-present), and Fellow at the Institute of Economic Affairs (January 2000-present).

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