FDA Response to my inquiry from Nicotine Supplier

[KODIAK (TM)]

As you can respect, we have not fully digested the entire 499 pages of regulations. However, we don’t see an issue at the moment as our supplier is registered as a tobacco manufacturer and we only sell diluted nicotine solutions which can be used in a variety of applications other than vaping. We do not consider it “e-liquid” until it has been blended with flavorings and as such, we do not sell e-liquids.

We see no issues, but are continuously working towards better understanding our compliance obligations, if any, and then taking the necessary steps to become compliant in whatever area’s may be needed.

A "safe" response I suppose and I really didn't expect anything else. A legal, cheap and readily available supply of Nic is key to U.S. DIY'ers. (And I really don't want to set up a cryogenics facility in my shed to start hoarding this stuff).

 

[englishmick]

Interesting comment in there about "which can be used in a variety of applications other than vaping". If that is true it could make a difference to the outcome. I'm not aware of anyone else who buys nic in VG/PG, at least not retail.

 

[KODIAK (TM)]

And another response from a different lab:

At this time it is unclear how the FDA deeming regulations will affect
chemical suppliers of raw materials such as nicotine solutions used in the
manufacture of e-liquids. The scope and expense of product registration
fees, and the outcome of the final grandfather date for newly deemed tobacco products, which is currently under debate in the US House (HR 2058 and US House Appropriations Committee), are both important factors in how the deeming regulations will impact the vaping community and industry.

These regulations will not affect our pricing strategies.

I'm omitting the names of these labs because in all honesty, it's probably unfair and too soon to put them on the spot like this.

 

[sofarsogood]

They don't know because the FDA can make any rule they want any time they want for any reason they want. That kind of power isn't prone to corruption, it's the definition of corruption. Everybody who supplies us is going to keep up a brave front. If I were them I'd be scared to stand up for myself for fear of retaliation. Congress or the courts need to fix this.

 

[CharTech]

Interesting responses. Thanks for sharing.

 

[Jim_ MDP]

I'm not aware of anyone else who buys nic in VG/PG, at least not retail.

Nor am I and I've asked a few times before.

Mods and attys are going to get the treatment... whatever that turns out to be.

We're not the largest consumers of PG, VG, wire or wick. Not even close, so I see no reason to hoard those.
Vape oriented vendors may gouge... but they're hardly the cheapest option, even today.

Nic on the other hand... we are the entire market for retail liquid nic. As far as I know.

 

[Jminton1985]

As you can respect, we have not fully digested the entire 499 pages of regulations. However, we don’t see an issue at the moment as our supplier is registered as a tobacco manufacturer and we only sell diluted nicotine solutions which can be used in a variety of applications other than vaping. We do not consider it “E-Liquid” until it has been blended with flavorings and as such, we do not sell e-liquids.

We see no issues, but are continuously working towards better understanding our compliance obligations, if any, and then taking the necessary steps to become compliant in whatever area’s may be needed.

A "safe" response I suppose and I really didn't expect anything else. A legal, cheap and readily available supply of Nic is key to U.S. DIY'ers. (And I really don't want to set up a cryogenics facility in my shed to start hoarding this stuff).

I know nicotine has been used as a pesticide in the past, and it has also been used in medicine to treat bee stings and such. Perhaps this is what they were meaning by "Other uses".

 

[Jim_ MDP]

I know nicotine has been used as a pesticide in the past, and it has also been used in medicine to treat bee stings and such. Perhaps this is what they were meaning by "Other uses".

New regs wont affect a medical use (I'm allergic and had never heard that one), and as far as I know nic as pesticide (or is it herbicide?) isn't viable economically. Certainly it isn't done much anymore.

 

[Jminton1985]

New regs wont affect a medical use (I'm allergic and had never heard that one), and as far as I know nic as pesticide (or is it herbicide?) isn't viable economically. Certainly it isn't done much anymore.

Doesn't mean that that can't be the use listed on the shipping label.

 

[KODIAK (TM)]

Seems one of the lab reps has become my e-pal. Been giving me updates on how the hoarders and preppers are running them out.

Reminds me of blizzard warnings here. First, the milk is gone... then the bread. (But the liquor stores are always my first stop so maybe I'm just late).

 

[Rossum]

Seems one of the lab reps has become my e-pal. Been giving me updates on how the hoarders and preppers are running them out.

They ain't seen nothing yet. Wait until the vape shops start closing....

 

[Hulamoon]

I thought that nicotine was already regulated, thus the reason the FDA was given the giant raspberry by the courts when they tried seizing shipments last time round. I could be wrong, and basically government does as it pleases anyway. But if that IS the case, then it makes the FDA deeming even more PD stupid and already defunct as it's all based on the "nicotine theory".

 

[KODIAK (TM)]

I thought that nicotine was already regulated, thus the reason the FDA was given the giant raspberry by the courts when they tried seizing shipments last time round. I could be wrong, and basically government does as it pleases anyway. But if that IS the case, then it makes the FDA deeming even more PD stupid and already defunct as it's all based on the "nicotine theory".

Yes but now nicotine is considered to be tobacco.

 

[Hulamoon]

Not unless it's gone through the judicial process. All the more reason to back the Cole-Bishop amendment and tell them how much we appreciate their good judgement and wisdom.

 

[KODIAK (TM)]

Not unless it's gone through the judicial process.

I'm confused. Barring an injunction from the private sector, there is no judicial process.

the more reason to back the Cole-Bishop amendment and tell them how much we appreciate their good judgement and wisdom.

Well, I'm kind of "done" showing my appreciation for hollow and feel-good gestures these past 2 years. If by some miracle the amendment goes through then great. But from here on out it's all about setting up a supply line for me and those in my small circle of ex-smokers.

 

[Myrany]

I'm confused. Barring an injunction from the private sector, there is no judicial process.
Well, I'm kind of "done" showing my appreciation for hollow and feel-good gestures these past 2 years. If by some miracle the amendment goes through then great. But from here on out it's all about setting up a supply line for me and those in my small circle of ex-smokers.

I am with you on that Big bear buddy.

I won't quit fighting but at the same time I am going to do what I have to in order to never smoke another cigarette.

 

[zoiDman]

I'm confused. Barring an injunction from the private sector, there is no judicial process.
...

This Isn't Exactly True. There are Cases where the FDA has been Successfully Sued.

Not say'n that it Isn't a Very Steep Uphill Battle. Or that the Timeframes involved are Short. But there is Judicial Recourse.

 

[DC2]

I know nicotine has been used as a pesticide in the past, and it has also been used in medicine to treat bee stings and such. Perhaps this is what they were meaning by "Other uses".

https://archive.epa.gov/pesticides/reregistration/web/pdf/nicotine_red.pdf

The registrant of the sole remaining nicotine pesticide product requested the cancellation of its registration on February 25, 2008, to be effective on December 31, 2013, with existing stocks permitted to be sold by dealers and distributors for one additional year.

 

[KODIAK (TM)]

Well, this "nicotine as a pesticide" discussion explains why the mosquitoes up here seem to leave me alone. (And all along I thought it was just my 100 proof blood type. )

 

[mostlyclassics]

(And I really don't want to set up a cryogenics facility in my shed to start hoarding this stuff).

KODIAK, you don't have to set up a cryogenics facility. All you need is a cheapie top-load freezer, sometimes called chest freezers.

About 30 years ago we bought one. It was about $125 new, came from the Land of the Yugo (even though it has a famous brand name on it), and it holds about 7½ cubic feet.

Less than half of the space is populated with 10 liters of 100 mg./ml. rocket juice, all in glass bottles. It holds the temp at minus 10 to minus 15 Farenheit, according to the thermometer I keep in it.

The other half of the space has steaks, chops and such. Once I lost a pack of tube steaks in it for about five years: they were fine after I thawed them. You could keep moose steaks and whale blubber in yours. <snicker>

A couple of months ago I checked a 2012 "vintage" bottle, my oldest. The nic was in perfect condition, even four years later.

I figure 10 liters is enough to last me until I'm 95. But just to be safe, I recently ordered another two liters.

Here's one that's similar to our clunker, though a bit smaller:

http://www.amazon.com/cu-ft-Chest-Freezer-White/dp/B0198ZXHEI?ie=UTF8&keywords=chest freezer&qid=1463452526&ref_=sr_1_10&s=appliances&sr=1-10