Although FDA officials (unless they come to their senses during the next two or three years) aren't likely to approve New Tobacco Product applications for bottles of e-liquid, Lorillard has more expertise, experience and money than any other e-liquid manufacturer (and I suspect Johnson Creek still makes most/all e-liquid for blu/Lorillard) to submit successful New Tobacco Product applications to FDA for e-liquid products.
Lorillard has led the scientific evidence campaign to prevent (so far) FDA from banning or limiting menthol in cigarettes, and Lorillard has already submitted at least several dozen SE applications to FDA (and has convinced FDA to approve several of its SE applications for subbrands of Newport cigarette, which Altria and Reynolds haven't yet achieved). Lorillard has an excellent regulatory compliance staff, who have (since 2009) attended all of FDA's tobacco regulatory meetings, and have submitted comments on dozens of FDA tobacco regulatory dockets.
Kent wrote
What will be interesting is if the deeming doc is as solid as some think, if (or how) they'll attempt SE for the Pro Kit. Other vendor might want to pick one up to see exactly how it is made, just in case it would happen to get SE approval. ...looks like a standard Kanger
I strongly doubt the FDA will change the February 15, 2007 grandfather date in the agency's proposed deeming reg (not only because its in the FSPTCA, but also because the FDA doesn't want to deal with hundreds or thousands of SE applications for different e-cig products).
Not sure when Johnson Creek started manufacturing e-liquid, but I began communicating and collaborating with Christian Berkey in 2009 when FDA banned e-cig imports.
Please note that the same e-cig manufacturers that will be submitting new product applications to UK MHRA (for approval as medicines) will (if the FDA issues a Final Rule for the deeming regulation) be submitting similar new product applications to the FDA (for approval as a tobacco product).
