90 days
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Ahh. In 90 days you cannot sell any vape stuff to minors.
In 90 days you cannot sell any vape stuff that you did not sell before the 90 day date. Or that was not sold in the USA.
You can sill sell the same stuff. But not that 500Watt single 18650 mod that boomsalot came out with on 90 days +1. Or the new juice flavor that gagamaggot came out with. Or even a New diamond ceramic coil that goes in the leaksalot tank that you have been selling for a year.
For all the existing vape products you have 2 years to file to get that device legal to sell in the US. the manufacturer or modifyer of the device/juice is the one that files. If a vape shop makes their own juice they file, but for the Clowdz fer DAze brand of juice the the gagamaggot company makes and the vape shop just sells, the gagsamaggot company needs to file for that one.
After 2 years if what you are selling has not either been approved or ad not been filed for with the FDA it can no longer be sold.
However when something is filed you have 1 Year or until it is approved or disapproved to sell it.
So if you file right at the 90 days + 2 year date you can theoretically get up to 3 years before it cannot be sold unless approved.
clear as mud.
In 90 days you cannot sell any vape stuff that you did not sell before the 90 day date. Or that was not sold in the USA.
You can sill sell the same stuff. But not that 500Watt single 18650 mod that boomsalot came out with on 90 days +1. Or the new juice flavor that gagamaggot came out with. Or even a New diamond ceramic coil that goes in the leaksalot tank that you have been selling for a year.
For all the existing vape products you have 2 years to file to get that device legal to sell in the US. the manufacturer or modifyer of the device/juice is the one that files. If a vape shop makes their own juice they file, but for the Clowdz fer DAze brand of juice the the gagamaggot company makes and the vape shop just sells, the gagsamaggot company needs to file for that one.
After 2 years if what you are selling has not either been approved or ad not been filed for with the FDA it can no longer be sold.
However when something is filed you have 1 Year or until it is approved or disapproved to sell it.
So if you file right at the 90 days + 2 year date you can theoretically get up to 3 years before it cannot be sold unless approved.
clear as mud.
Pretty much...but let's say at the end of two years, you submit all of the applications and pay the money...your application must be approved within a year for the products to remain on the market. They don't have to 'dissaprove' the application, thye can let it sit for a year, never bother to open it, and you still have to pull your products.
Legal innovation comes to a screaming halt in 90 days. Things on currently on the market can remain on the market for two years and 90 days. Companies with big bucks can buy another year.sigh.
Legal innovation comes to a screaming halt in 90 days. Things on currently on the market can remain on the market for two years and 90 days. Companies with big bucks can buy another year.sigh.
Actually you pay the money for testing and such before you submit the application. YOU are responsible for all the testing not the FDA. And for one ejuice it can take maybe 1000 tests and as long as the listed shelf life on your ejuice is.
I' not talking about the cost of the testing, though that too is going to be a huge part of the costs, but the application fees.
And my point was that they don't have to act in in a timely manner in response to the application. lack of action = denial.
Seems like this conversation would make more sense in the context of one the threads in the FDA section...rather than in this little visited, out of the way alabama subsection of the forum. Calls to action, how to help support etc. make sense here. There is support in the form of a local association for our local vendors, but most aren't active on ecf.
Besides, i hope to gosh no one is going to try to navigate the poorly constructed and ill-defined process without legal advice and a much more detailed read of the regulations than we could hash out here.
And my point was that they don't have to act in in a timely manner in response to the application. lack of action = denial.
Seems like this conversation would make more sense in the context of one the threads in the FDA section...rather than in this little visited, out of the way alabama subsection of the forum. Calls to action, how to help support etc. make sense here. There is support in the form of a local association for our local vendors, but most aren't active on ecf.
Besides, i hope to gosh no one is going to try to navigate the poorly constructed and ill-defined process without legal advice and a much more detailed read of the regulations than we could hash out here.
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The million dollar figure is based on the testing.
Watch this and pay attention about juice testing.
I'm aware of the costs, and the figures. Thanks for the link, i hear it's a very good webinar. Siegel's blogs are generally pretty good.
There are testing costs, there are application fees, and they're based on the fact that everry formulation is considered a separate product. You have paid all of it and submit your application. Thye can still let it sit and whether or not they have acted, your products must be pulled.
There are testing costs, there are application fees, and they're based on the fact that everry formulation is considered a separate product. You have paid all of it and submit your application. Thye can still let it sit and whether or not they have acted, your products must be pulled.
I guess, since i'm not a vendor, and i'm sure we can all agree that this is FUBAR, that i'd prefer discuss the actions we can take, rather than the minutia of an ill-defined regulatory process that are likely to change as the FDA continues to make it up as they go along.
the first thoughts I've read from a venders.Mountain Oak Vapors E-Cigarette Blog
Looks like the BEAA (representing a subset of local vendors) has made comments too Blog | Breath Easy Alliance of Alabama
I there's a post in the BEAA members group on FB that indicates legal action...
I there's a post in the BEAA members group on FB that indicates legal action...
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