But just like the FDA needed the FSPTCA to give them Authority over e-Cigarettes/e-Liquids via Deeming, it Wouldn't surprise me if the ATF/TTB needed to do something Also to include e-Cigarettes/e-Liquids into Their authority.
The FDA has deemed e-cigarettes tobacco products ergo,
'Tobacco traffickers move black market contraband cigarettes and/or other tobacco products (OTP) purchased from low tax states to be sold in higher tax states."
Fact Sheet - Tobacco Enforcement | Bureau of Alcohol, Tobacco, Firearms and Explosives
This seems to cover only products that are taxed but,there's this also,
Title 18, United States Code, Section 2320 – Trafficking in counterfeit cigarettes.
"(1)
traffics in goods or services and knowingly uses a counterfeit mark on or in connection with such goods or services,
(2)
traffics in labels, patches, stickers, wrappers, badges, emblems, medallions, charms, boxes, containers, cans, cases, hangtags, documentation, or packaging of any type or nature, knowing that a counterfeit mark has been applied thereto, the use of which is likely to cause confusion, to cause mistake, or to deceive,"
IMHO this covers BT's .... once they have what ever is left of the e-cig market.
The use of which is likely to cause confusion, to cause mistake, or to deceive.
This covers more territory than just using Vuse's name. Having witnessed the Gov's
penchant for overly broad interpretation any thing having to word e-anything on them
could possibly get caught up in this net.
Granted it also gives authority to after fake EGO's,Suicide Bunny or, 5P's.
18 U.S. Code § 2320 - Trafficking in counterfeit goods or services
I do not desire going so cheap as to get sulfuric acid shipped to me as nicotine or some such.
?! IMHO I will never understand why people assume that any vendor would do such
a thing. There are laws against this.Civil,fraud,misrepresentation,etc. . Criminal if
it causes harm.
Well, those are some of the loopholes they're closing with this deeming. Pipe tobacco is now covered. Also, e-liquid flavoring, as a component, is subject to the regulations.
This is of course just my opinion, but I seriously think the only distinction is: For sale to manufacturer, or For sale to consumer. If it's sold to the consumer, it's covered.
I think your assessment is correct. This also protects who ever is left.(who would they be)
They will be able to get their materials at much less current prices to increase
profit margins on their overly priced products in a much smaller market.
"Get your FDA approved e-cigarettes from us."
This brings up an interesting question.
Will those that do manage to get and keep their products on the market
get to use the FDA logo and or statements of approval on their labels.
Unlike cigarettes on the market today the FDA in fact would have approved
them from scratch.

Regards
Mike