Deeming Regulations have been released!!!!
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Just so you know, ECF was mentioned in the FRIA:
"The comments stated that nearly all these businesses are small, and that they account for 65,000 jobs. A comment also noted that the Electronic Cigarette Forum has nearly 1,700 e-cigarette and e-liquid businesses (including importers) on record, not including the hundreds of manufacturers of hardware components.
"Comments pointed out that vape shops have been sprouting up everywhere; some have “vape bars.” Comments state that over 1,000 or over 5,000 such shops are listed on vaporsearchusa.com. In comments, the CEO of Vape World is cited as saying there are more than 3,500 independent vape shops in the U.S. Comments cited industry analysts estimating that there are 5,000 to 10,000 vape shops in the U.S. In comments, an individual from a trade association is said to estimate that there are 14,000 to 16,000 brick and mortar vape shops in the U.S. The Tobacco Vapor Electronic Cigarette Association estimates that brick and mortar stores will sell more than $1 billion in vaping equipment and products in 2014.
"The comments also state that the e-cigarette (or ENDS) industry in the U.S. has roughly doubled every year since its inception. Although the companies are small, they are growing. Comments cited industry estimates that current U.S. sales of e-cigarette (or ENDS) products were expected to be between $2.2 and $3 billion in 2014 and expected to pass $10 billion by 2017."
The FDA's Response?
[Response]: While an estimate of the number of ENDS manufacturers was developed for the required Paperwork Reduction Act burden analysis, we did not estimate the number of manufacturers for the PRIA due to the high level of uncertainty. As the comments describe, the industry is in a state of flux; during the time that the proposed rule was in review, and since the proposed rule was published, the ENDS industry has grown and additional vape shops have opened. The comments on the number of ENDS manufacturers did not provide concrete data sources, but rather industry estimates for which the bases were not given. In the case of non- retail manufacturers, comments did not always specify whether the cited numbers included both domestic and foreign manufacturers, or only domestic manufactures. Therefore, considerable uncertainty remains as to the number of domestic non-retail manufactures. Similarly, comments did not address the number of non-retail importers.
They were given data, but decided it didn't meet the criteria they just invented. So instead they decided to do this:
In the RIA for this final rule, based on logo counts from trade association websites and FDA listening sessions, we estimate that there are 168 to 204 manufacturers of ENDS products, other than retailers who mix their own e-liquids, selling goods in the US market. We also estimate that there are 14 importers of ENDS products.
"Based on logo counts from trade association websites and FDA listening sessions (I'm guessing CASAA)" they think they have accurate information? I mean, logo counts?? WTH.
Shouldn't that read, "Based on logo counts from trade association websites, we estimate that there are 168 to 204 manufacturers of ENDS products that have logos and are members of trade associations?"
"The comments stated that nearly all these businesses are small, and that they account for 65,000 jobs. A comment also noted that the Electronic Cigarette Forum has nearly 1,700 e-cigarette and e-liquid businesses (including importers) on record, not including the hundreds of manufacturers of hardware components.
"Comments pointed out that vape shops have been sprouting up everywhere; some have “vape bars.” Comments state that over 1,000 or over 5,000 such shops are listed on vaporsearchusa.com. In comments, the CEO of Vape World is cited as saying there are more than 3,500 independent vape shops in the U.S. Comments cited industry analysts estimating that there are 5,000 to 10,000 vape shops in the U.S. In comments, an individual from a trade association is said to estimate that there are 14,000 to 16,000 brick and mortar vape shops in the U.S. The Tobacco Vapor Electronic Cigarette Association estimates that brick and mortar stores will sell more than $1 billion in vaping equipment and products in 2014.
"The comments also state that the e-cigarette (or ENDS) industry in the U.S. has roughly doubled every year since its inception. Although the companies are small, they are growing. Comments cited industry estimates that current U.S. sales of e-cigarette (or ENDS) products were expected to be between $2.2 and $3 billion in 2014 and expected to pass $10 billion by 2017."
The FDA's Response?
[Response]: While an estimate of the number of ENDS manufacturers was developed for the required Paperwork Reduction Act burden analysis, we did not estimate the number of manufacturers for the PRIA due to the high level of uncertainty. As the comments describe, the industry is in a state of flux; during the time that the proposed rule was in review, and since the proposed rule was published, the ENDS industry has grown and additional vape shops have opened. The comments on the number of ENDS manufacturers did not provide concrete data sources, but rather industry estimates for which the bases were not given. In the case of non- retail manufacturers, comments did not always specify whether the cited numbers included both domestic and foreign manufacturers, or only domestic manufactures. Therefore, considerable uncertainty remains as to the number of domestic non-retail manufactures. Similarly, comments did not address the number of non-retail importers.
They were given data, but decided it didn't meet the criteria they just invented. So instead they decided to do this:
In the RIA for this final rule, based on logo counts from trade association websites and FDA listening sessions, we estimate that there are 168 to 204 manufacturers of ENDS products, other than retailers who mix their own e-liquids, selling goods in the US market. We also estimate that there are 14 importers of ENDS products.
"Based on logo counts from trade association websites and FDA listening sessions (I'm guessing CASAA)" they think they have accurate information? I mean, logo counts?? WTH.
Shouldn't that read, "Based on logo counts from trade association websites, we estimate that there are 168 to 204 manufacturers of ENDS products that have logos and are members of trade associations?"
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Siegel:
"To their credit, the tobacco companies...are supporting changing the grandfather date to be the effective date of the regulation." (May 10, 2016)
Why? "One is, I think, the companies want to see a vigorous vaping market." and..."I think the companies understand if these regulations go through as they are and no changes are made, that the overall market is going to shrink... and having a large market share of a small market is not as good as having a smaller share of a huge market".
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Mostly people get along really great here...but sometimes people need to learn when to just drop it, let it go and get over it instead of acting like a gorilla thumping it's chest.
It can't thump its chest, it's dead.
I was wondering why SJ changed his avatar and user name--after 9 years.
I noticed the avatar change, but not his user name. doink.
but...but...WHY? Its not like we are replacing food with vaping.......wait.....well, maybe desserts.....
just...just...
they have ABSOLUTELY NO idea how large the business end of e-cigs is
NO idea at ALL !
I was wondering why SJ changed his avatar and user name--after 9 years.
Nope,this is what he said the other day :
" "Oliver" is easier to say "
I was wondering why SJ changed his avatar and user name--after 9 years.
I figured to avoid "smoke" as in Smokey.... and the cigarette in the James Dean pic.
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'The purpose of the review of PMTAs is to ensure that new tobacco products are appropriate for the protection of the public health. However, FDA acknowledged in the PRIA that premarket submission requirements could lead to significant product exit and reduced entry. As we note in Table 12 of the PRIA and the associated discussion, a reduction in the supply of electronic cigarettes could under some conditions yield negative health benefits.
In particular, if, going forward, electronic cigarettes are proven safer than other tobacco products and are substitutes for other tobacco products, and if the effect of premarket requirements on the supply and price of electronic products were large enough, then the welfare effects of a reduction in supply of electronic cigarettes due to the rule could potentially be negative.
Counterbalancing this, however, is that the PMTA requirement helps ensure that new tobacco products are appropriate for the protection of the public health."
In particular, if, going forward, electronic cigarettes are proven safer than other tobacco products and are substitutes for other tobacco products, and if the effect of premarket requirements on the supply and price of electronic products were large enough, then the welfare effects of a reduction in supply of electronic cigarettes due to the rule could potentially be negative.
Counterbalancing this, however, is that the PMTA requirement helps ensure that new tobacco products are appropriate for the protection of the public health."
...we have more than that as Registered Suppliers and Forum Suppliers just here
They don't have a freaking clue how off they are !
Agreed, but to be fair, not too many people do. They have a good idea of sales through convenience stores and tobacco shops, but not for vapeshops and online, non at all. That is one of the reasons for the registration requirement i believe. They want the market to be consolidated ( a lot ), so they can control it.just...just...
they have ABSOLUTELY NO idea how large the business end of e-cigs is
NO idea at ALL !
...we have more than that as Registered Suppliers and Forum Suppliers just here
They don't have a freaking clue how off they are !
The FDA disagrees with your ability to count.
Nowhere in the any of the reports I've read does the FDA acknowledge how many people have quit smoking.
They have an answer for just about everything......and they really DON'T know what they are talking about......Just looking at their figures of guess-ination in their tables are way too low. I guess its their way of belittling us yet again....first as smokers, now as vapers.'The purpose of the review of PMTAs is to ensure that new tobacco products are appropriate for the protection of the public health. However, FDA acknowledged in the PRIA that premarket submission requirements could lead to significant product exit and reduced entry. As we note in Table 12 of the PRIA and the associated discussion, a reduction in the supply of electronic cigarettes could under some conditions yield negative health benefits.
In particular, if, going forward, electronic cigarettes are proven safer than other tobacco products and are substitutes for other tobacco products, and if the effect of premarket requirements on the supply and price of electronic products were large enough, then the welfare effects of a reduction in supply of electronic cigarettes due to the rule could potentially be negative.
Counterbalancing this, however, is that the PMTA requirement helps ensure that new tobacco products are appropriate for the protection of the public health."
They won't control it, BT will control it.
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