Again, not true.
As outlined in the my post you just replied to....
They suggest eliminating nearly all of the paperwork by:
1. Changing the date from 2007 to the date of final regs
(meaning every vapor product currently on the market would be legal, a predicate and free from Pre market authorization)
2. Not requiring a new Pre market authorization for minor changes/differences to the products.
(This is huge and would eliminate a large portion of the paperwork and fees that would cripple small business)
3. Basing regulation on vapor produced, not device producing it.
(This is an amazing concept, I doubt it has any chance of happening, but this would further reduce paperwork drastically by sensibly focusing on actual differences in product function)
These changes if implemented would mean NO overly burdensome or costly paperwork for existing small businesses to stay in business and minimal filing for new products developed unless there is substantial change to the vapor output.
I'm beginning to think you're reading a different document than the one you linked to... Because to me it is quite clear that lorilard's public comments to the FDA are much more in line with the vaping community than I ever would have dreamed.
They even go so far as to distinguish that smokers and vapers are not the same thing.
On top of that they go further than most comments I've read and not only explain why the proposed regulations are wrong, but also suggest solutions that are not only, logical and reasonable but also that would benefit vapor product manufacturers large and small, at the expense of traditional tobacco.
I must agree. It's a well written and persuasive comment. Very focused and lawyer-like.