Please note that Altria urged the FDA to impose a defacto ban on all “open tank systems” and “e-liquids” that are sold separately to consumers by urging FDA to:
- to “require manufacturers of non-tobacco components and parts that are sold directly to consumers to be subject to . . . premarket authorization requirements” and other FSPTCA requirements,
- to “apply premarket authorization and constituent reporting requirements to manufacturers of empty “tanks”, “tank systems”, and other e-vapor components intended for distribution or sale directly to consumers . . . in a way that accounts for each probable combination of tobacco-derived nicotine-containing liquid and each such “tank” or “tank system” and the aerosols produced by such combinations.”
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to analyze “the interaction between a particular liquid and any empty “tank” or “tank system” and any liquid which could be used therein.”
- define “finished tobacco product” to differentiate “components, parts or raw materials” from tobacco products that are ready for human consumption,
- to define “component and part” as any “raw material, additive, substance, piece, item, unit, section, assembly, or sub-assembly that is intended for incorporation into a finished tobacco product, ”
Regulations.gov