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Regulation News

It is VERY IMPORTANT that you take the time to comment on the proposed deeming regulations. If you do not, then the FDA will assume all of you just don’t care. The truth is that we all care deeply about vape being available to the public in the way that we all envision, and that is juice with flavors, the continuation of technology innovation, and the ability to vape outside of designated smoking sections. No one wants to breathe second hand smoke including us!

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This is a link to the 241 page proposed deeming regulations for our entire industry. After page 191, the rest is just references. It’s easy to scroll through and only read about the sections that pertain to e-cigs. The other sections pertain to cigarettes and tobacco. Please if any of you desire to make an impact for the support of the entire vape industry, follow the directions on how to place a comment through the instructions below. Remember, all of these regulations will affect our position in this industry, so let’s do something about it!

YOU HAVE UNTIL AUGUST 8TH, 2014 TO RESPOND!

https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-09491.pdf

You can go to either link to submit comments. It has instructions on how to do this:

http://www.regulations.gov/#!documentDetail;D=FDA-2014-N-0189-0001

http://www.fda.gov/TobaccoProducts/Labeling/ucm388395.htm

First and foremost, the vape industry should have it’s own framework for regulation. The fact that we are grouped together with conventional cigarettes and cigars just doesn’t make sense. Nicotine may be derived from tobacco, but our products do not burn plant matter. There is no smoke being created. The Tobacco Act was created because cigarettes have been proven to kill. Vape should not lie within this framework. It has been shown to be a harm reduction product which helps the CDC and FDA achieve their goals of harm reduction to the general public.

With a separate framework, the FDA can implement better regulations that are appropriate and rational. On the issue of age restriction. This is necessary and we are not resistant to this. Only adults should be making choices on what habits to obtain. (pg.47 talks about the effect of nicotine on teens.)

They want to limit the way we market our products. This is aligned with the appeal to minors.

Currently, the prosed regulations state that all devices will have to have a substantial equivalent to a predicate product as of February 15, 2007. This means that all devices that were created afterwards may not be able to enter the market if we cannot show a “predicate product” as of February 15, 2007. The FDA wants to hear your opinion about a possible different regulatory mechanism for newer proposed products that cannot use the SE (substantial equivalent) pathway. (pg.11)

The FDA feels that having flavors in the e-juice appeals to children. They want to eliminate flavors for our juice. E-juice itself do not come with a flavor. It is flavorless. Since when does a human consumable item not have flavor? Perhaps the solution is to ask the FDA to define what child flavors are. Then the industry could just make all the other flavors. It’s impossible for all flavors in the world to be geared only to children. Adults love different flavors as well. (pg. 61) At the end of the day, what teens and children are doing is a direct refection of what environments surrounds those children. It’s the parents’ responsibility to provide a solid foundation for children to make good educated decisions.

On page 59, they are concerned about the contents of the juice. They want to regulate the consumable items. We are not against this. We want our products to be safe. The issue is that our industry desires these regulations to be appropriate and rational.

The FDA states that vaping can be a portal to conventional cigarettes. Definitely share you thoughts on this.

The last paragraph of page 23, the FDA recognizes that e-cigarettes may have the potential to reduce the death and disease toll from overall tobacco product use depending of who uses the product and how they are used. But they mention if people become dual users of e-cigs and cigarettes, then the health impact could be negative. Share your thoughts on whether or not you feel this is true for dual users.

These are a few of the issues being addressed in the proposed deeming regulations. Take a moment to submit your comments since the approval of this proposed deeming regulations would greatly affect our industry, not in a good way.