There is no tax due on finished DIY, similar to beer and wine. Possession is not a crime, because the "proper tax" was paid. Same with old gear and juice in your cupboard, the "proper tax" was paid. Tax is due when a sale is made from a wholesaler to a retailer or when a consumer exercises the "unclassified importer" option.
Raw materials and consumer produced products are not mentioned in the statue. Liquid nicotine is a grey area. If concentrated enough, it can't be used in a device to simulate smoking. None-the-less, I expect, nicotine will be the raw material that ends up getting taxed when clarifying language is released. VG, PG, and flavoring that is intended to be mixed might also be added. The problem with raw materials other than nicotine is retailers of non-tobacco products in PA will violate the law if I buy a bottle of VG, I plan on vaping. When purchased from an in-state retailer, the statute states I can assume the wholesale tax was paid. In addition, VG will cause some issues because some use it as a finished "tobacco product" and some use it as a raw material in producing their own tobacco product. Raw materials for DIY mods seem out of reach other than vape specific chip sets and maybe 510 connectors.
Sale was expanded to include gift, but in the penalties section, "unlicensed sale" is only a crime and punishments are only listed for when a person engages in a "for profit" sale.
I'm not seeing them be so generous. There are numerous things they placed in the act that could be used to nail DIY guys. For the record I do myself and fully intend to continue to. But just their definition of tobacco products is damning because it covers anything that is put into any device that fits the definition of an electronic cigarette. I agree there could be a grey area there regarding finished product vs components of product, but the term "any" is generally inclusive. This is not a sales tax so the only place where that matters is what transferred to whom and when. Compounding the issue is this...a "manufacturer" is defined as "any person that produces tobacco products". That's it, no mention of "for sale or profit" or who the final user of the product is. So by this early definition in the act, at minimum a DIYer may need to pay for a manufacturer's license to comply. In this case, your ultimate intentions for the final product would likely be irrelevant, by their definition of you make a tobacco product of any kind you are a manufacturer, and manufacturers need a license to "operate" in the state. Saying "it's for my own use"...well, I imagine their response would be "sure that's what you all say".
But wow there ARE so many grey areas that could result in taxes being paid by mistake at numerous levels...imo so many mistakes that the whole section of Article 12A needs to be removed completely. And they top the whole thing of with their own catch-all, that any tobacco product that has not somewhere along the line netted them 40% is contraband and possession of it is a criminal offense. The funny thing is as you pointed out they missed a lot of product in their definitions, certainly not going to go into details on that here until after this, if it remains intact as written by then, officially takes effect. There may also be ways the FDA regs screw up things for these states that jumped the gun.