Don't quote me, but I'm pretty sure that the deeming regs and the last shipping ban bill cover all kinds of nicotine, not only the tobacco-derived kind.
That's were it Starts Raining Lawyers.
Because the FDA gets it's Authority to Regulate a "Tobacco Product" Not from Deeming. But from the FSTCA. And the FSTCA defines a "Tobacco Product" as something that is "Made from or Derived from Tobacco".
Face it. The whole Hardware is a "Tobacco Product" when it is
Reasonably Expected to be used with a "Tobacco Product" is a BS Overreach. But Judge Jackson and Judge Grimm allowed it via Judicial Deference to the FDA. Their Reasoning appeared to be that there was Only One Degree of Separation. And people could use a "Ball and or a Box" for Different Purposes including using it with something made from or derived from Tobacco.
But a Closed System/Non-Refillable Doesn't pass that "Ball and or Box" test that Judge Jackson alluded to. So why does the FDA have Authority over it under the FSTCA?
BTW - The Stoner Execs/Millionaires will be Watching this Very Closely. Might even want Enjoin in a Lawsuit. Because this is Directly tied to their Get High with Vaping market.
Which, of course, will just Add More Drama and Hype to the Whole Thing.