Understood and Agreed - although one question: would an
eliquid supplier even need to do that? As long as they are purchasing nic base from a manufacturer that already is approved - it's just a pass
through at that point?
Technically, I guess that is true. According to what I'm reading now, the final retailer would not be responsible for PMTA actions unless they are the manufacturer (e.g. in-shop mixing).
I'm assuming the point of the rules is to ensure WYSIWYG - meaning, if the bottle is labeled xx mg nic base, that it truly is xx mg nic base and nothing else.
Well, I think some of us here would argue the true point of this deeming. I have compiled a mental list from my perspective, in which product safety, accurate labeling, and and actual care for people's health starts down somewhere around #147, but I digress....
Based on this train of thought, though, seems like the idea of selling concentrated proprietary flavoring would be out. I suppose they could sell pass through flavors (straight from FA, TFP, etc), and pass through PG and VG. Maybe eliquid shops can make little "kits" of nothing but pass thru components. They could get bulk contracts with flavoring manufacturers to produce tiny little pre-measured vials each individual flavor in a recipe and then sell the kit: "Build your Jon Wayne here - this kit is $199 but makes 300 ML of juice if you just pour exactly what is contained in these little vials into the same container together and shake." ;-) (Of course, then everyone would know the recipe ratio......)
Certainly this could be done, and has been discussed before. Flavor manufacturers have a) been around a lot more longer than vaping, and b) generally been very careful, with the exception of FlavourArt, to distance themselves from using their products for vaping. So I certainly don't see how the FDA could include raw flavors as in-scope.
I still contend that the FDA has left it open, with the somewhat strange wording of that paragraph on page 222, to be able to stop this if they feel there is some level of intent to mix with nicotine. Intent could be as simple as a previous eliquid manufacturer suddenly selling "flavoring kits for drinks" that matches their previous flavor profiles.
Certainly DIY, assuming you can get nic base, is wide open as far as I can tell... no different than baking a cake.
Ugh...this is all making my head hurt. I used to DIY. Ain't got time for that. I suppose I will be making time for that again, though.
I hear ya! I've contemplated DIY, but I barely have enough time/energy to rebuild my RTAs, let alone play with recipes. Plus, I don't have the best sense for how to make things that taste well... I was never a good cook.
