Deeming Regulations have been released!!!!

Kent C

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Found another one.....
The Rest of the Story: Tobacco News Analysis and Commentary

What Does This All Mean?

especially the last part ^^^^


What a jumbled mess.

I've always said what is said here - that the standard isn't "derived from tobacco", instead the standard is "intended or reasonably expected to be used with or for human consumption" :

"As it relates to e-liquids that contain zero nicotine, generally, if your zero-nicotine product is not made or derived from tobacco, it may still be a tobacco product subject to FDA regulation if it is intended or reasonably expected to be used with or for the human consumption of a tobacco product; or intended or reasonably expected to alter the performance, composition, constituents, or characteristics of a tobacco product (with certain exceptions relating to controlling moisture or temperature for storage and initiating external heat source), your product is subject to FDA regulation. These products will be evaluated on a case-by-case basis. This applies to closed and open system devices that contain zero-nicotine.

As a tobacco product, your product will automatically be subject to all of the requirements in Chapter IX of the Federal Food, Drug, and Cosmetics Act and its implementing regulations relating to tobacco products when the deeming rule becomes effective on August 8, 2016. "
 
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Sugar_and_Spice

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Found another one.....
The Rest of the Story: Tobacco News Analysis and Commentary

What Does This All Mean?

especially the last part ^^^^

No body knows................
What a jumbled mess.

I've always said what is said here - that the standard isn't "derived from tobacco", instead the standard is "intended or reasonably expected to be used with or for human consumption" :

As it relates to e-liquids that contain zero nicotine, generally, if your zero-nicotine product is not made or derived from tobacco, it may still be a tobacco product subject to FDA regulation if it is intended or reasonably expected to be used with or for the human consumption of a tobacco product; or intended or reasonably expected to alter the performance, composition, constituents, or characteristics of a tobacco product (with certain exceptions relating to controlling moisture or temperature for storage and initiating external heat source), your product is subject to FDA regulation. These products will be evaluated on a case-by-case basis. This applies to closed and open system devices that contain zero-nicotine.

As a tobacco product, your product will automatically be subject to all of the requirements in Chapter IX of the Federal Food, Drug, and Cosmetics Act and its implementing regulations relating to tobacco products when the deeming rule becomes effective on August 8, 2016.
This same article even made it into Forbes today too.....woot...means a much wider audience.....

The FDA's Incomprehensible Answer To A Crucial Question About Its E-Cigarette Regulations
 

Sugar_and_Spice

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What a jumbled mess.

I've always said what is said here - that the standard isn't "derived from tobacco", instead the standard is "intended or reasonably expected to be used with or for human consumption" :

As it relates to e-liquids that contain zero nicotine, generally, if your zero-nicotine product is not made or derived from tobacco, it may still be a tobacco product subject to FDA regulation if it is intended or reasonably expected to be used with or for the human consumption of a tobacco product; or intended or reasonably expected to alter the performance, composition, constituents, or characteristics of a tobacco product (with certain exceptions relating to controlling moisture or temperature for storage and initiating external heat source), your product is subject to FDA regulation. These products will be evaluated on a case-by-case basis. This applies to closed and open system devices that contain zero-nicotine.

As a tobacco product, your product will automatically be subject to all of the requirements in Chapter IX of the Federal Food, Drug, and Cosmetics Act and its implementing regulations relating to tobacco products when the deeming rule becomes effective on August 8, 2016.
Yes @Kent C you are correct,,,,however since it is such a jumbled mess maybe the courts will also view it that way. One can only hope.
:)
 

Verb

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I love the logic. Even if it's NOT intended or reasonbly expected for the zero nicotine eLiquid to have nicotine added, it is intended or reasonbly expected to be used in a vaporizer. Since someone else may use a similar device with nicotine, the zero nicotine eLiquid is a tobacco product.
 

zoiDman

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I love the logic. Even if it's NOT intended or reasonbly expected for the zero nicotine eLiquid to have nicotine added, it is intended or reasonbly expected to be used in a vaporizer. Since someone else may use a similar device with nicotine, the zero nicotine eLiquid is a tobacco product.

Yeah... It's like when you Use the Hypothesis to Support the Data. And then turn around and say the Data Supports the Hypothesis.

What a Perfect Circle Jerk.
 

DC2

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I love the logic. Even if it's NOT intended or reasonbly expected for the zero nicotine eLiquid to have nicotine added, it is intended or reasonbly expected to be used in a vaporizer. Since someone else may use a similar device with nicotine, the zero nicotine eLiquid is a tobacco product.
Well, you have to love the logic.
It's brilliant, if you're a ..... or a politician.
:laugh:

If that stands up to court challenges, it's time to move.
I hear Costa Rica is popular these days.
 

Ipster

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I love the logic. Even if it's NOT intended or reasonbly expected for the zero nicotine eLiquid to have nicotine added, it is intended or reasonbly expected to be used in a vaporizer. Since someone else may use a similar device with nicotine, the zero nicotine eLiquid is a tobacco product.
Huh???
:lol:
 

Sugar_and_Spice

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I love the logic. Even if it's NOT intended or reasonbly expected for the zero nicotine eLiquid to have nicotine added, it is intended or reasonbly expected to be used in a vaporizer. Since someone else may use a similar device with nicotine, the zero nicotine eLiquid is a tobacco product.
And I expect and reasonably assume that elected officials will do the jobs they were elected to do too. How's that been working out?
 

Verb

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If a tobacco free substance is to be placed for use in a tobacco free tobacco product, the tobacco free substance is a tobacco product. I wonder if they are going to extend this same logic to pipes. Big Pharma is gearing up to roll out several [Other Stuff] derived pharmaceuticals.
 
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Ipster

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If a tobacco free substance is to be placed for use in a tobacco free tobacco product, the tobacco free substance is a tobacco product. I wonder if they are going to extend this same logic to pipes. Big Pharma is gearing up to roll out several [Other Stuff] derived pharmaceuticals.
Here too....we've approved two new dispensaries on my island/county...more state wide but you cant vape/smoke/drink
til 21...18 for cannabis.
 
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choochoogranny

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It is simple really. The nannies in gov. do not want to see you do the "act" of vaping/smoking at all. Remember the candy cigarettes? Where'd they go and for what reason? No hand to mouth unless it is food or drink. They have demonized smoking enough now that they would find it hard to see someone do the "act".........then along comes vaping and undoes all their hard work of finally stuffing you in a dark closet.......for which you paid handsomely for their efforts AND the closet.
 

skoony

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Right, I meant it might have that on the bottom because if you turn the cap over you can still use it, but it's no longer child resistant.

Perhaps your Container does not Comply to any Recognized CRP Standards?

ie the "Caution Not child Resistant" discloser.

vials-group-animation2.gif

Something like the one on the left is what I was thinking.
The one on the left for sure.
the cap will not turn until the tab on the bottle is depressed. My surprise was I was not told nor did I request non-compliant CRC's. Please note I am not complaining either. I assumed my prescriptions would be in compliant bottles.
Regards
Mike
 
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Rossum

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I love the logic. Even if it's NOT intended or reasonbly expected for the zero nicotine eLiquid to have nicotine added, it is intended or reasonbly expected to be used in a vaporizer. Since someone else may use a similar device with nicotine, the zero nicotine eLiquid is a tobacco product.
By that logic, the coffee I'm drinking right now is an alcohol product, because I'm drinking it in a cup that COULD be used to consume an alcoholic beverage.

Any reasonable court would shoot this down. But i'm not sure whether there are many reasonable courts left, or whether it will make much difference by the time a case works its way through the system. :(
 

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