Not a big deal either way but I get to see the names but get 0 visitors showing. Cheers.
Deeming Regulations have been released!!!!
- Thread starter Oliver
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Do share please. I don't understand that either.
Excellent point, rothenbj!
CASAA even has a PayPal link which lets you set up monthly automatic charges for your donation. That way, you can't forget.
Vaping creates new businesses, decreases unemployment, and is less harmful than cigarettes. Should be a no-brainer. So, we're back to BT is scared and doesn't want to share a single one of the population that inhales. Super greed.
On page 22:
" E-liquids that do not contain tobacco or nicotine or are not derived from tobacco or nicotine do not meet the definition of "covered tobacco product," as described throughout this final rule, and will not be required to carry an addiction warning or to submit a self-certification. "
So in theory there would be no issue stockpiling nicotine and adding it to 0% flavors after the regs kick in.
There is the fact that a good bit of this is against constitutional rights to name just one legal aspect of a court case. There are more than just damages to consider. You can't win if you don't fight.
Hell, if you are going to look at things that way, what about lost sales? So many different reasons that I could see here.
What about the damage being done to the health of adults that will be forced back into smoking cigs? All in the name of protecting the children who should be the responsibility of their parents. Not to mention that there are already laws out there that should protect them and don't work.
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Sans nicotine the product still contains tobacco as it has been deemed a tobacco
product. In this case the nicotine warnings do not apply as there is no nicotine.
I know this sounds stupid but,this is my understanding.
Folks I hope it's becoming clear that while nicotine is a important factor in how
and why the FDA wrote the regulations the way they did, it is no more important
than any other single component of the hardware or individual component in the juice.
If vaping worked with out nicotine and or nicotine was never used in vaping products,
if it interfered with tobacco sales we would still be right where we are today.
For those that believed that nicotine would be the lynch pin for controlling the
industry only got it part right. Every individual component of the juice and
hardware is it's own lynch pin.Replace the coil with a sonic vibrator the vibrator
becomes tobacco. Replace the juice tank with a compressed aerosol container
the container and everything in it becomes a tobacco product. etc.,etc. .
Regards
Mike
Right about now ... some people with really deep pockets are probably looking to make the best nicotine the Black Market could ever find ... interesting times ahead.
Sent via iPhone
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I just Don't Know? Or fully Understand the Procedural Steps involved.
And it Hasn't even been Verified by CASAA or SFATA or anyone who Should Know that this Rule Set has to go to Congress under the Congressional Review Act.
I know the Scope and Extent to which the FDA's PMTA for ENDS has caught everyone Off Guard. And has been a Kick in the Gut. But after waiting this Long for "Deeming" to hit, I really thought that when the Rule Set was Released, someone would come forth and say Exactly what the next/remaining Procedural Steps are.
It is my understanding that in order sue for harm caused by the regulatory process
the harm must be caused first. You cannot sue for potential harm only actual harm.
Of course there may be other legal remedies.
Regards
Mike
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If "Big Daddy" really cared about the health & welfare it's children it would try to mitigate video game/electronica addiction.
It very well could be that your Local Vape Shop has already done the work to fulfill all the Requirements to sell "Tobacco Products" on the State/County/State/Federal level. Many Shops who have followed all this Have in the hopes that when the FDA released it's Final Rule set, that they could continue to Operate for some length of time.
But just Carding people for 18+ Isn't Enough.
I have had an automatic payment of $10 taken out each month for the past 2-3 years now. It's not much but each bit helps.
@Tucsonbroker If you are mixing juice for individual sale you are a manufacturer
and fall under the regulations as such.
Regards
Mike
and fall under the regulations as such.
Regards
Mike
Something Else that should be Noted is that when you buy a LDPE Bottle (or any "Plastic" Bottle), there is No Guarantee unless stated, and has a Traceable Cert, that the Bottle is made from "1st Use" Raw Stock.
This brings to mind I think of what would be a sensible regulation.
Do not use bottles that could leach or pass through things that could
contaminate the juice. Glass bottles would meet this requirement with out
undue burden . some plastics should.
regards
Mike
My understanding of the regulation process is that the expected industry harm must be listed as part of the regulation documentation and if it can be shown to be significantly wrong can be challenged before actual harm occurs. But in this case, the FDA has estimated that 99.9% the industry will be eliminated by the regulations, so I don't think there is a gross mis-characterization of the expected harm to the industry. But, IANAL, so take my advice with a grain of salt.
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