FDA FDA deeming regulation proposals

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aikanae1

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All things I disagree with, especially the ban against minors. Contrary to most, or many, I don't care to disassociate with BT, until such a time that it is proven BT = ANTZ.

Let us agree to disagree on this last point.

I can accept that BT played a part in shaping regulations, but also see most big vaping vendors doing the same, and telling their customers that they did so.

When we respond in comment, we too will be shaping regulations. All you who want a ban against minors and note this in your comments will be on record for a) agreeing with FDA on regulations and 2) seeking a ban. Guess how well that sits with me?

Cigalikes are here to stay, just as vaping is here to stay. I reckon cigalikes will be regulated, at a superficial level, differently than other hardware. My cigalike product, which I've used 99% of time I've been vaping in 2+ years is not owned by BT, but the smokes that I still choose to smoke are. When I went cold turkey, I didn't hate on BT. Not a game I'm all that interested in.

I don't expect BT, or corporate style vaping vendors, to fight the fights we fight and thus to shape policy like a consumer approaches this. I hope we are all on the same side, but even us consumers can't say as much. I principally oppose bans to minors and advocate vaping everywhere. From my perspective, that makes me very concerned about consumer vaping rights. From another consumer's perspective, I'm misguided. So, if some of us are saying BT is misguided, I take that with a grain of salt. Always up for having this discussion/debate, but hard to get around certain things when a mind is made up and won't budge.

I'm seeing that some tune our statements out because they assume we are big tobacco. In every interview I hear "taking a play from big tobacco by aiming flavors at kids" ... and that's all they hear. We need to disarm that comment. Going into a lengthy explaination that can't be proven to a non-vapor won't do it.

I was serious when I mentioned to someone about having truck drivers, bikers and the other "sterotypes" stand up for bubble gum, cotton candy, gummy bear flavors. I think that could be done in a fun way. I also don't want mech mods and tanks thrown under the bus for cigalikes.

I've spent a lot of time convincing someone to give ecigs another chance because they AREN'T like Blu.

The reason I don't want BT in this comes from the Surgeon's General's Report; "Although the prevalence of smoking has declined significantly over the past half-century, the risks for smoking-related disease and mortality have not. In fact, today's cigarette smokers - both men and women - have a much higher risk for lung cancer and chronic obstructive pulmonary disease (COPD) than smokers in 1964, despite smoking fewer cigarettes."

Cigarettes have become more harmful in the hands of BT. I don't want that to happen to eliquids and it will. I can go back and quote Dr. F on that one.
 
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Sirius

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I'm seeing that some tune our statements out because they assume we are big tobacco. In every interview I hear "taking a play from big tobacco by aiming flavors at kids" ... and that's all they hear. We need to disarm that comment. Going into a lengthy explaination that can't be proven to a non-vapor won't do it.

I was serious when I mentioned to someone about having truck drivers, bikers and the other "sterotypes" stand up for bubble gum, cotton candy, gummy bear flavors. I think that could be done in a fun way. I also don't want mech mods and tanks thrown under the bus for cigalikes.

I've spent a lot of time convincing someone to give ecigs another chance because they AREN'T like Blu.

The reason I don't want BT in this comes from the Surgeon's General's Report; "Although the prevalence of smoking has declined significantly over the past half-century, the risks for smoking-related disease and mortality have not. In fact, today's cigarette smokers - both men and women - have a much higher risk for lung cancer and chronic obstructive pulmonary disease (COPD) than smokers in 1964, despite smoking fewer cigarettes."

Cigarettes have become more harmful in the hands of BT. I don't want that to happen to eliquids and it will. I can go back and quote Dr. F on that one.

Well, I was a truck driver for many years. And a motorcycle rider. I really love cotton candy vapes. I just polished off one from TVR.
 

Sirius

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Then start a video response to that comment. It's the number one thing ANTZ points to proving vaping is the same as bt and they are marketing to kids. Repeat that enough without countering it and it will be the same as fact.

Well there's an idea. I wonder if Busardo or Rip has done that?
 

Sirius

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You can bet my comment won't be about flavors though. I had to quit smoking because I had a heart attack. I tried all the FDA approved methods to quit but they didn't work. Not until I tried vaping was I able to stop smoking. That's the truth and for all it's worth, I sure feel a lot better now that I'm vaping and not smoking cigarettes.
 

aikanae1

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Well there's an idea. I wonder if Busardo or Rip has done that?

I've seen that video. It's good and went up on my FB page (I'm surprised my friends still pay attention anymore, but they are probably the most informed non-smokers on ecigs found).

This might add some fuel http://www.e-cigarette-forum.com/fo...b1500-assigned-committee-18.html#post13010730

The whole thing about the calif online ban was about .... flavors. Again. I haven't finished reading it. To my knowledge no bt cigalike is produced in flavors (beyond menthol).

It's the flavors that attracted me to ecigs.

FYI - I tend to consider NJoy one of the better ones since they have been very politically active in AZ which I'm sure has kept bans away from the the state.
 
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Sirius

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I've seen that video. It's good and went up on my FB page (I'm surprised my friends still pay attention anymore, but they are probably the most informed non-smokers on ecigs found).

This might add some fuel http://www.e-cigarette-forum.com/fo...b1500-assigned-committee-18.html#post13010730

The whole thing about the calif online ban was about .... flavors. Again. I haven't finished reading it. To my knowledge no bt cigalike is produced in flavors (beyond menthol).

It's the flavors that attracted me to ecigs.
I didn't think they ( state governments) could ban online sales? I smell law suits.
 

aikanae1

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I didn't think they ( state governments) could ban online sales? I smell law suits.

Oh yes they can!!!! This isn't the first threat. The act gives states permission to do whatever they want, so it's not going to go away, year after year.

Here's the extended version; Stefan Didak

It's all about the flavors right now :facepalm:
 

Kent C

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Cigarettes have become more harmful in the hands of BT.

And BT has been in the hands of the FDA - reducing both tar and nicotine causes people to smoke more. If you reduce tar and leave nicotine at levels the consumer needs, then there wouldn't be the effect that the Surgeon General describes: basically that FDA regulations didn't work.
 

Sirius

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Oh yes they can!!!! This isn't the first threat. The act gives states permission to do whatever they want, so it's not going to go away, year after year.

Here's the extended version; Stefan Didak

It's all about the flavors right now :facepalm:

OMG! What a bunch of...........
Elffy_36.gif
 

Lessifer

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I didn't think they ( state governments) could ban online sales? I smell law suits.

They've amended it, it's now a requirement for age verification at time of purchase(through access to a consumer database) AND at time of delivery(by requiring an adult signature). The flavor thing was a comment by the bill's author, but one I think it's important to fight in the realm of public opinion.

Currently vaping Jelly Beans #adultslikeflavors


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salemgold

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An update from CASAA

CASAA is shooting for releasing the Call to Action within a week.

In addition to working on the Call to Action, CASAA is also working on other related and important activities:

1) We are filing for an extention to the comment period, increasing it to 180 days.
2) We are putting together a new e-cigarette user survey to provide statistical data for the official CASAA public comment, which requires a review of all of the requests for information made by the FDA in the proposed rules.
3) We are compiling a list of potential "asks" to petition Congress regarding the FDA's actions.
4) We are still working out facts of the rules vs. rumors/opinions (ex. definition of "finished product," actual costs of filing applications, number of comments allowed, etc)
5) We are still collecting information for the Call to Action, which will include instructions for submitting comments so they show up publicly, a summary of the rules and our objections and talking points for members to pick and chose from when submitting their story. (Note: the CTA will be written for individual comments, so it won't be asking members to submit comments with all of the technical and science facts like the CASAA comment will have.)

We know people are chomping at the bit, however, we cannot take the risk of "shoot first, ask questions later." CASAA has been gearing up for this for 5 years now and we aren't going to risk dropping the ball now. We continue to ask members to be patient and let us do this the right way. We are not leaving this to the last moment, so there is no need to worry that you will be under the gun time-wise after we release the Call to Action. Once we release the CTA, members will still have over 60 days to submit their own comments.
 

EddardinWinter

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It costs me >5¢/ml to DIY. I guarantee they get it cheaper, 1000% (50¢/ml after markup at my cost) is actually pretty low ball.

Even if you include a glass bottle and childproof cap at minimal bulk prices (my cost) you end up with >$2 for a 30ml bottle, x10 = $20. Yes 1000% is a pretty good guess even when including marking up the bottle.
Note that I am saying markup and not profit margin (in case you want to start claiming overhead like RebelGolfer72 does).

How about paying mixers who produced the juice? How about material handling and cleaning? You work for free when you DIY, but liquid manufacturers must pay their employees. There is also the fact that your flavors may be cheaper than MOV or HHV.

While pure overhead can be left out of costs of production in your scenario (example: rent), all direct costs into the liquid production process are part of production cost. This cost of production deducted from sale price would determine "markup" as you define it.

I think your number is off by a bit, Myk.



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DC2

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hi all,
i've read all the posts so far.there are a lot of angles being presented to all
aspects of the proposed regs from the FDA.
the topic that concerns me the most is the so called registration process.
i haven't made up my mind on the hardware side yet but,as e-juice with nicotine
will most certainly have to be registered here are my thoughts on that.
first a lot has been discussion on the cost.i have heard numbers from hundreds of dollars
to 10 million dollars for each and every item.i think in a month or two some realistic numbers
should be coming forth.
now research.it seems to me that we know whats in juice,propylene glycol,vegetable glycerin,
nicotine,and food flavoring and coloring.
individually and in some cases used together these have all been approved as safe by the FDA.the FDA must have on file all
the applications they passed for these.so just pull these applications,take all the studies
that were used to prove this,and resubmit those with each and every product.
along with all the studies cassa has listed on there web site this would be quite formidable.
the FDA would be hard pressed to come up with a reason to say juice was not a safer
alternative than smoking.in no way they could compare it to smoking.
they would have to contradict a lot of already approved products to do so.
we could sort of hoist them on there own petard.
i know it doesn't quite literally work that way.i'm just thinking that something along
these lines for our individual responses to the FDA and our elected officials.

running this up the flag pole to see if any one salutes regards,
mike
You may want to read this...
http://www.fda.gov/downloads/TobaccoProducts/GuidanceComplianceRegulatoryInformation/UCM273425.pdf
 

Myk

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How about paying mixers who produced the juice? How about material handling and cleaning? You work for free when you DIY, but liquid manufacturers must pay their employees. There is also the fact that your flavors may be cheaper than MOV or HHV.

While pure overhead can be left out of costs of production in your scenario (example: rent), all direct costs into the liquid production process are part of production cost. This cost of production deducted from sale price would determine "markup" as you define it.

I think your number is off by a bit, Myk.



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Profit margin does not equal markup. I already told you that so why did you go into profit margins trying to claim them to be part of markup? You're a bit backwards.
Markup is I buy this item for $100 and I sell it for $200. Out of that $100 profit I pay for the rent, electricity, wages and all my other overhead. What's left in the bank when it's all said and done is profit margin. I SAID NOTHING ABOUT PROFIT MARGINS.

You're right, my number is off. IT'S LOW. It's probably more like 10,000% for some of the larger mixers.

There's the fact that my flavors are extremely costly because I buy them in tiny little bottles not gallon jugs. My 5¢/ml is from smart shopping but it's not from bulk pricing and wholesale deals.

Most of the rest of the retail world manages with markups of 100% - 300% (some only get markups in the single digit percents). You will never convince me eliquid is super special and needs to make 10x more than anyone else, which just magically comes out to be slightly undercutting cigarette costs. They make what they do because they can and to prepare for regulations (build a lab, set back a nest egg to pay for approval, etc.).

If they actually have to make that markup to pay their present overhead we're all screwed because they'll never even afford the application fees let alone the lawyers they'll need. But I know that's not the case because I've seen how liquid makers can take off and grow without taking on investors.
 

Sirius

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