I have a feeling you are correct.
Not only here, but remember when CASAA and other groups where in those closed door meetings with the FDA? The ones where CASAA and other groups and individuals were not allowed to disclose what was said? I bet a lot of their information came from there too.
The FDA can get their information from almost any avenue. It is not secret what we
vape, how we vape, where we
buy our stuff. They have ears everywhere.
So here ya go FDA

YOU!
Those folks at the FDA must be pretty good actors not to have shown their hand
in these closed door meetings. If any of the .orgs that had a closed door meeting
with the FDA and had any kind of heads up on what we were in for they had better
have a good explanation.
Not Challenging what you are say'n...
But How Exactly would a Vape Shop prove to the FDA that the e-Liquids they are Mixing on a given Day is Exactly the Same as what they were Mixing at some Previous time?
Now that I have had time to mull this over some more I believe the FDA can do this and
it is in the regulations. I haven't been wearing my tinfoil hat for couple of days so forgive
me for not thinking of this sooner.
The part where they say each blend of juice no mater how minor the change is
considered a new product. Bingo. Most of the shops i have seen that make juice behind the
counter use big squeeze bottles pre filled with bases and pretty much just eyeball it.
Ergo,there is the minor change the FDA refers to in the reg.'s. This also has the extra
added benefit for the FDA to have a hidden extra form of regulation to add further
regulatory burdens that are not in the regulations. All the juice will have to be made
with automated computer precision bottling equipment to insure compliance.
Now that my tinfoil hat is on i feel confident I will not be so lackadaisical with
my assessments in the future. I should be getting my fifth gold sticky star
as soon as the next Republican is elected President.

Regards
Mike