Tobacco 21: Policy Evaluation For Comprehensive Tobacco Control Programs


Tobacco use is the leading cause of preventable and premature death in the United States (USDHHS, 2014).1 Nearly all tobacco use begins during youth and young adulthood (USDHHS, 2012). People who begin smoking at a young age are more likely to become addicted, to progress to daily smoking, and to smoke more heavily in adulthood (USDHHS, 2012). In addition, the use of nicotine by adolescents and young adults can harm the developing brain, including the parts of the brain that control attention, learning, mood, and impulse control (USDHSS, 2016).

Policies to increase the MLSA for tobacco products have been shown to contribute to reductions in tobacco use and dependence among youth (Institute of Medicine, 2015).  Increasing the MLSA for tobacco to 21 years could reduce the likelihood of high school students legally purchasing tobacco products for themselves, other students, and underage friends, thus reducing the secondary risks of harm on youth brain development and early addiction.

According to the Institute of Medicine’s 2015 report (Institute of Medicine, 2015), once the MLSA for tobacco products increases to 21 years nationally, it is projected that:

  • Tobacco use will decrease by 12 percent by the time today’s teenagers become adults; smoking-related deaths will decrease by 10 percent.
  • Smoking initiation will be reduced by 25 percent for 15-17-year-olds and by 15 percent for 18-20-year-olds.
  • Nationwide, 223,000 premature deaths will be prevented among people born between 2000 and 2019, including 50,000 fewer deaths from lung cancer.

On December 20, 2019, the Federal Food, Drug, and Cosmetic Act was amended to reflect a change in the MLSA for tobacco products from 18 to 21 years of age, effective immediately. Prior to the enactment of the national T21 law, nineteen states had passed T21 laws: Arkansas, California, Connecticut, Delaware, Hawaii, Illinois, Maine, Maryland, Massachusetts, New Jersey, New York, Ohio, Oregon, Pennsylvania, Texas, Utah, Vermont, Virginia, and Washington. Guam and Palau had also raised the MLSA for tobacco products to 21 years. Many cities adopted city-wide T21 laws as well, such as New York, Washington D.C., Chicago, and St. Louis (Counter Tobacco, 2019).

Policy evaluation can help inform program efforts by identifying potential gaps or deficiencies within the policy, and the effects that those gaps can have on the policy’s implementation or intended impact. Furthermore, policy evaluation can help assess support and compliance with the implemented policy, demonstrate the value of the policy, and can help inform the evidence for future policies at the state, local, territorial, tribal, and national levels. It also can provide accountability for resources appropriated.

Evaluating the impact of the federal T21 law within a specific jurisdiction can help answer questions about impact in various domains, for example, to what extent does the policy prevent initiation?; how does the policy affect youth access to tobacco products?; how does the policy affect social norms on tobacco use?; and, what is the economic impact of the policy? Additionally, tobacco control programs can consider examining whether differences exist between T21 laws enacted in their jurisdictions and the national T21 law and the extent to which different provisions affect the implementation and effects of the law.

1 “Tobacco” in this document refers specifically to the use of manufactured, commercial tobacco products and not the sacred and traditional use of tobacco by American Indians and other groups.

Guidance Sections