FDA FDA deeming regulation proposals

[Jman8]

If everything is as good as you suggest,

Please quote where I have said everything is good. Or what you are getting at.

it would seem like writing responses and fighting back (against what?) would be a waste of time.

Against what = against proposals that seek to regulate eCigs/vaping industry under the tobacco act. FDA doesn't know how to regulate these new innovative products and are seeking comments on this, with a whole bunch of items that one can comment on.

vaping community is in prime position to shape things to come. And politically aware vapers know that we have opposition that will be seeking to do the same thing. Thus commenting, in large numbers, that are to some degree organized, is best thing we can do right now, and for next 75 days.

 

[Jman8]

I'm more concerned about forced industry consolidation, which can stifle competition & innovation..

Imagine if the vaping industry had not flourished & advanced like it did since 2007... Because if it hadn't, right now we'd be vaping on some pretty lousy, nasty, ineffective products at exorbitant prices...

Betting many of us would go back to smoking..


The market & the industry have done a pretty good job on their own so far without any regulation...

And the market, industry, and many consumers have known regulations were coming...any day now. That day has arrived.

"Forced industry consolidation" seems like a genuine concern to me. I suggest, strongly, that you comment on that, among other things, and let the FDA know that you feel it would stifle competition and innovation.

But if point is 'any' (amount of) regulation will do this, then I hope you realized this before 4/24/14, and find peace with what's to come.

IMO, what's to come in say next 3 to 5 years, is triple the gross revenue within the vaping industry. While others seems to be okay posting commentary that in 2.5 years, it's all going to disappear. Yesterday, I was public about having a wager on that. I'm not backing away from that.

In my worldview, it's because of the fight and motivation the vaping community has amassed up to this point and what that likely will result in as to why things can plausibly get better in 3 to 5 years. I don't see regulation has helpful, but do see it as inevitable when you are in a business that is bringing in billions of dollars in revenue. Can you think of any other legal business with that much revenue that has magically avoided any sense of regulating?

 

[Gato del Jugo]

Thus commenting, in large numbers, that are to some degree organized, is best thing we can do right now, and for next 75 days.

Agreed..


Though there are other things we can continue to do...

- Like joining CASAA, for example.. I'm surprised they only have like 9K registered members... It would be that much more impressive in the eyes of others if that number were 3X, 5X, 10X that amount

- Like financially support entities such as CASAA, or ECF, or whatever

- Like getting as many smokers as possible to switch over to vaping over the next couple years.. Among other positive things, each & every smoker-turned-vaper not only takes them away from BT, but also adds them to our side -- with the net effect of 2, so to speak (minus one for them, plus one for us)... The extra money & voices come in handy... Because as much as these potential regulations could hurt BT in the short-term, I think they know that it actually helps them in the long-term... The weaker they are, and the stronger we are, the better prepared we are for this prolonged war...

 

[KODIAK (TM)]

IMO, vaping is clearly here to stay and FDA has given vaping community a golden opportunity to shape things.

These regulations merely serve as official validation to a non-vaping society that we are still smokers. Which is what they've been telling us we are all this time. How is taking one step "backwards" any kind of a golden opportunity?

 

[Gato del Jugo]

And the market, industry, and many consumers have known regulations were coming...any day now. That day has arrived.

"Forced industry consolidation" seems like a genuine concern to me. I suggest, strongly, that you comment on that, among other things, and let the FDA know that you feel it would stifle competition and innovation.

But if point is 'any' (amount of) regulation will do this, then I hope you realized this before 4/24/14, and find peace with what's to come.

As for peace, I knew this was coming... I'm down from 18mg to now 2mg liquid.. My goal is full-time zero-nic unflavored.. And some point after that, I'll probably quit vaping entirely..

But that doesn't mean that I'll stop fighting & supporting in any way I can.. I know what vaping has done for me, and I know what it can do for countless others...


As for my FDA comment, I've already been formulating my strategy.. And the competition & innovation part will definitely be in there..

I'm also looking forward to others' continuing input here at ECF, from CASAA, the hardware & juice manufacturers, the well-known YouTubers, etc.

 

[DC2]

As I read these, this is pretty much opposite of what I read here:

http://www.e-cigarette-forum.com/fo...rs-before-any-action-possible-under-regs.html

Considering who posted that, I'm not the least bit surprised.
That's all I have to say about that without getting another infraction.

EDIT......................................................................................................................................
When I say "who posted that" I am not attacking the poster in question.
I am responding based on his posting history, and the content of those posts in his posting history.

In other words, if this is considered an attack, then it is an attack on the historical content of his posts.

 

[RedNBlack]

Ok, time to step it up everyone,
Just got this from MOV....
Regulations.gov

Submitted mine, 75 days to input what we can, where we can...
Pass it on as you see fit....
The door is open, do not just sit watching, waiting,....

And if you are not a CASAA member,
go and join, donate or not, just join. This is just the first "shot", more is surre to follow.

CASAA - The Consumer Advocates for Smoke-free Alternatives Association
CASAA - The Consumer Advocates for Smoke-free Alternatives Association

 

[StormFinch]

Jman I saw somewhere where you were asking about the applications fees, but I can't find where that was so I'll just put it here.

This comes from a vendor who called the FDA to inquire on the process of getting his own e-liquids registered, and a trusted source. The way he explained it is;

A 2500.00 application fee for small businesses, 1500.00 per ingredient listed, and I'm not sure if this means just each flavoring plus PG, VG and nic or if each of the flavorings have to be broken down, waiting on confirmation for that. The hourly cost of a lawyer to file said application X 360 hours to prepare it per the FDA. I believe the average hourly for a standard lawyer is $284.00 per, but you would need one that's versed in FDA applications and I have no idea what they would charge. I believe the employee this vendor talked to also forgot to mention the testing that e-liquids will need to go through, and I won't even pretend to know what that would to cost. Someone else here might know.

So, for one single flavor liquid we have $2500 + $1500 X 4 (pg, vg, nic & flavor) if all the flavoring ingredients aren't required + $284 lawyer base cost X 360 hours = $110,740.00 plus the cost of chemical testing for 1 juice out of a line. And if any information is left off, the application is denied plus the fees are forfeited. Answer your question?

 

[DC2]

And the market, industry, and many consumers have known regulations were coming...any day now. That day has arrived.

"Forced industry consolidation" seems like a genuine concern to me. I suggest, strongly, that you comment on that, among other things, and let the FDA know that you feel it would stifle competition and innovation.

But if point is 'any' (amount of) regulation will do this, then I hope you realized this before 4/24/14, and find peace with what's to come.

IMO, what's to come in say next 3 to 5 years, is triple the gross revenue within the vaping industry. While others seems to be okay posting commentary that in 2.5 years, it's all going to disappear. Yesterday, I was public about having a wager on that. I'm not backing away from that.

In my worldview, it's because of the fight and motivation the vaping community has amassed up to this point and what that likely will result in as to why things can plausibly get better in 3 to 5 years. I don't see regulation has helpful, but do see it as inevitable when you are in a business that is bringing in billions of dollars in revenue. Can you think of any other legal business with that much revenue that has magically avoided any sense of regulating?

I'll tell you what, I'll make you a bet.

I'll bet you $1000 that when these regulations are eventually put in place, we'll be left with nothing but cig-a-likes.
Most of which, if not all, will be made by Big Tobacco.

All you have to do is figure out who is going to hold the money.

And if I lose this bet, I'll be the happier than a pig in...

 

[DC2]

These regulations merely serve as official validation to a non-vaping society that we are still smokers. Which is what they've been telling us we are all this time. How is taking one step "backwards" any kind of a golden opportunity?

And they also show that the FDA is "doing something" about this electronic cigarettes scourge that is sweeping the nation.

 

[StormFinch]

I'll tell you what, I'll make you a bet.

I'll bet you $1000 that when these regulations are eventually put in place, we'll be left with nothing but cig-a-likes.
Most of which, if not all, will be made by Big Tobacco.

All you have to do is figure out who is going to hold the money.

And if I lose this bet, I'll be the happier than a pig in...

Might want to add the quantifier nothing "legal" DC2.

 

[thanswr]

I'll tell you what, I'll make you a bet.

I'll bet you $1000 that when these regulations are eventually put in place, we'll be left with nothing but cig-a-likes.
Most of which, if not all, will be made by Big Tobacco.

And if I lose this bet, I'll be the happier than a pig in...

Pay up, please.

There's always diy from readily available ingredients. With a mech mod, batteries that the FDA won't outlaw since they're used for purposes other than vaping, an rba, diy liquid, and you're on your way.

I'll take my $1000 as a Macy's gift certificate.

 

[Katya]

historical content

 

[DC2]

There's always diy from readily available ingredients.

How do you define "readily available" when it comes to nicotine?

 

[Hulamoon]

Between a rock and a hard place - by claiming it is harm reduction, that leaves us exposed to BP nanny pfizer and their paid politicians to claim it is a "medication" in line with their own useless products. Claim it's "tobacco" and BT will put a lock on it by sticking to their 2007 cigalike sticks.

The only rule I saw that didn't seem quite fair was the banning of advertising "harm reduction". I don't own a business, but as someone who smoked for 40 years and am now smoke-free, everything I have read says that vaping is less harmful than smoking. It will be interesting to see how the businesses who want to advertise feel about this.

The rule that requires a list of ingredients is a good one, IMHO.

 

[Hulamoon]

May have been mentioned before (sorry, I'm at work) but is this worth bannering on ECF? I know it's like spitting in the wind, but it shows that vapors are watching?

https://petitions.whitehouse.gov/petition/veto-fda-restrictions-e-cigarettes/kdKtpFH4

 

[thanswr]

How do you define "readily available" when it comes to nicotine?

If the nicotine is that important, get creative. Grow a plant. Figure out how to extract the liquid into a usable form.

The point here is that there will be other options other than analogs manufactured by BT.

Btw, I have a nicotiana plant. Aka: Flowering tobacco.

 

[Katya]

If the nicotine is that important, get creative. Grow a plant. Figure out how to extract the liquid into a usable form.

The point here is that there will be other options other than analogs manufactured by BT.

Btw, I have a nicotiana plant. Aka: Flowering tobacco.

I really hope you're joking.

If not, well...

 

[DC2]

If the nicotine is that important, get creative. Grow a plant. Figure out how to extract the liquid into a usable form.

The point here is that there will be other options other than analogs manufactured by BT.

Btw, I have a nicotiana plant. Aka: Flowering tobacco.

I'm not finding a nice way to respond to this, so I'll just remain silent.
I think your post speaks for itself.

 

[thanswr]

I'm not finding a nice way to respond to this, so I'll just remain silent.
I think your post speaks for itself.

It sure does because this entire "the sky is falling" and "we'll have nothing but BT analogs in 2 years" discussion is ridiculous. If someone feels strongly that the sky will indeed fall, well become a "Doomsday Vape Prepper" and order a few dozen gallons of liquid nicotine. Stored correctly, it will last you a lifetime. There's no expiration date on liquid nicotine. Combined with a mech mod, a battery, and readily available diy ingredients, and you'll be all set.

Better get moving though: There might be a run on liquid nicotine in 23 months.