As part of the latter I filed another FOIA request related to "The changes that FDA is allowing to these labels reflect the fact that although any nicotine-containing product is potentially addictive, decades of research and use have shown that NRT products sold OTC do not appear to have significant potential for abuse or dependence.
The changes being recommended by FDA include a removal of the warning that consumers should not use an NRT product if they are still smoking, chewing tobacco, using snuff or any other product that contains nicotine—including another NRT."
This statement used to be present on the FDA web site but was recently removed: see this.
I began interacting with the FDA FOIA people (interestingly this request went directly to a fellow with "JD" after his title who was relatively aggressive in responding).
In the end here's where it ended up: "Good Morning Todd,