The Final Count Down -- Are You Ready?

[englishmick]

Just thinking about hardware. What would keep manufactures of mods and Rta/rda to market them as thc devices? Are those not already legal in some states?

I am really not familiar with the thc market and what gear is used.

Not legal in Illinois yet. It will be come January 2020.

 

[englishmick]

See, this is a good point. A lot of people here are commenting on "when will the price drop" kind of thing. Some won't drop at all. A lot of that will depend on many things: how fearful the vendor is, whether they have any future in business with other products after the hammer drops, where their orders come from, and as you pointed out - their overall business model.

I get my nic and flavoring mostly from Wizard Lab. Looks like they are exclusively catering to the vape market. I don't know what % of their sales are for nic. Maybe they could get by selling just flavorings and equipment. Same for NN.

TFA flavorings come from a large outfit that supplies flavoring to all sorts of customers. Guess they would be OK though they might have to stop putting their vape flavorings on a separate page.

I suspect that DIYers are more likely than most vapers to be aware of what's going on, and be well stocked up with nic. Many could go on mixing for years or decades. Would that be enough to keep a flavoring vendor in business without new customers? I don't know.

We would be able to buy flavorings from non-vape sources. But it would be harder, it would mean figuring out which ones are safe and so forth. And the names we are used to buying might go away. I know to order TFA Crème De Menthe. Will it still be available under that name?

 

[Rossum]

Generally, no. I agree with you. That said, I feel good anything that comes down the turnpike I will be among the very first to know it. Being a fixture on ECF allows that.

True, dat!

Plus (as I have learned with Carolina Xtracts), they have their own tobacco field they use to grow their own raw materials for nic extraction. It's not like they can call a vendor and cancel their raw material orders. They are vertically integrated and their pipeline is always full. Someone like them may be inclined to LOWER their prices to deplete their pipeline. Pricing/availability could go in the favorable direction too.

Yep, but it's still very hard to predict. The fact is prices will be where supply and demand meet. I will point to ammo prices at the end of 2008 and the first half of 2013 as an example.

 

[Rossum]

IMHO - Only those living in Hurricane/Tornado/Earth Quake areas would truly understand the absolute NEED to be prepared before the last minute "rush" . . . Just Sayin' . . .

Oh yeah. One Tuesday, just shy three years ago, my wife woke up and looked at the revised track for Matthew. She then woke me up and said, "We have to go -- today!" I looked at the track and said, "Why, it won't be here until Friday. We would leave tomorrow or even Thursday." Her retort was, "Do you have any idea what the traffic will be like then?"

We left that afternoon and convoyed both cars, filled to the gills with the stuff we most didn't wish to lose, to our cabin 600 miles north of here. The drive was uneventful, taking the normal nine hours.

I looked at Google Maps on Wednesday and Thursday, and the roads (I95 northbound and I26 westbound) were a sea of red.

Those who panic first, panic best.

 

[Brewdawg1181]

I get my nic and flavoring mostly from Wizard Lab. Looks like they are exclusively catering to the vape market. I don't know what % of their sales are for nic. Maybe they could get by selling just flavorings and equipment. Same for NN.

TFA flavorings come from a large outfit that supplies flavoring to all sorts of customers. Guess they would be OK though they might have to stop putting their vape flavorings on a separate page.

I suspect that DIYers are more likely than most vapers to be aware of what's going on, and be well stocked up with nic. Many could go on mixing for years or decades. Would that be enough to keep a flavoring vendor in business without new customers? I don't know.

We would be able to buy flavorings from non-vape sources. But it would be harder, it would mean figuring out which ones are safe and so forth. And the names we are used to buying might go away. I know to order TFA Crème De Menthe. Will it still be available under that name?

Got an email this am from NicRiver. Looks like they're expanding their business, to stay in business:

 

[Rossum]

Dangit Rossum now I have the incredible urge to listen to the unabridged audible book for Larry Niven's Ring World. Le sigh. Oh well I can do that while organizing my stuff.

I could used some boosterspice...

 

[Myrany]

I could used some boosterspice...

I think we all could at this point.

 

[Opinionated]

@Rossum

I just decanted my nicotine which is suspended in VG..

I didn't leave room for expansion, because I was thinking vg and nicotine won't expand..

My husband thinks I'm wrong so I want to ask to make sure.. I can fill these bottles all the way yes?

 

[fiddleshe]

@Rossum

I just decanted my nicotine which is suspended in VG..

I didn't leave room for expansion, because I was thinking vg and nicotine won't expand..

My husband thinks I'm wrong so I want to ask to make sure.. I can fill these bottles all the way yes?

Someone else posted that it contracts.

 

[Rossum]

Finally tracked it down. These statements by FDA say DIY is okay as long as you don't do it for others, but that any nicotine sold is a component part and subject to PMTA etc but that they currently will not enforce unless sold directly to customers.

FDA Center for Tobacco Products Commonly Asked Questions

"Can I mix or make my own e-liquids at home or do I need to register as a tobacco product manufacturer?

If you are mixing these components of a tobacco product and then selling them to other individuals or companies, you would be considered both a retailer and a manufacturer, and subject to all applicable requirements under the law."

"I'm a supplier who sells to a manufacturer. I don't sell directly to consumers. Do I need to register with the FDA and submit premarket applications?

If you are solely a supplier and your product is sold only to another company for further manufacture into a finished tobacco product, at this time, FDA does not intend to enforce certain provisions of the law with respect to your product. For example, FDA does not intend to enforce the requirements that you register your manufacturing establishment and list your products, submit premarket applications or submit ingredient listing or health documents with respect to deemed products that are sold or distributed solely for further manufacturing into finished tobacco products."

I remember reading this several years ago, noting with bemusement that the FDA implies (but never outright states) that:

• DIY for personal consumption is fine; they have no power to regulate that.
• If you sell an unfinished tobacco product like nic base to consumers, you do need to submit a PMTA for it.

 

[Rossum]

@Rossum

I just decanted my nicotine which is suspended in VG..

I didn't leave room for expansion, because I was thinking vg and nicotine won't expand..

My husband thinks I'm wrong so I want to ask to make sure.. I can fill these bottles all the way yes?

It expands with increasing temperature and contracts with decreasing temperature. If you're careful never to expose the bottles to higher temperatures than those at which you bottled them, you should be OK.

Contraction can create at most a ~14.7 PSI pressure difference. If you put totally full bottles in the freezer, they will develop some head-space there; it will be a vacuum. A decent glass bottle 500 ml or smaller in size should be able to handle that.

But expansion with increasing temperature can create an almost infinite rise in pressure in a bottle that has no head-space at all. So make sure you never let them get much warmer than the temperature you bottled them at.

I like to leave a bit of headroom, so I fill my bottles to the base of the neck. This bit of air goes a long way to mitigate pressure changes.

 

[Opinionated]

It expands with increasing temperature and contracts with decreasing temperature. If you're careful never to expose the bottles to higher temperatures than those at which you bottled them, you should be OK.

Contraction can create at most a ~14.7 PSI pressure difference. If you put totally full bottles in the freezer, they will develop some head-space there; it will be a vacuum. A decent glass bottle 500 ml or smaller in size should be able to handle that.

But expansion with increasing temperature can create an almost infinite rise in pressure in a bottle that has no head-space at all. So make sure you never let them get much warmer than the temperature you bottled them at.

I like to leave a bit of headroom, so I fill my bottles to the base of the neck. This bit of air goes a long way to mitigate pressure changes.

Okay well I've left that much room, but no more.. So it seems I'm good then.

My house I keep the temperature fairly regular, so it should come to room temp at about the same temp I bottled it at..

 

[englishmick]

I remember reading this several years ago, noting with bemusement that the FDA implies (but never outright states) that:

• DIY for personal consumption is fine; they have no power to regulate that.
• If you sell an unfinished tobacco product like nic base to consumers, you do need to submit a PMTA for it.

Don't know if it makes a difference, but nic has been sold for a long time. Maybe it could get through on the substantial equivalence route. I've heard that is easier than full PMTA, but I don't know how much easier. Would they still have to prove it was beneficial to the public health and all that?

 

[DaveP]

Unflavored nic could simply fall under the "only tobacco flavors" rule.... because it is not tobacco flavored it would be banned.... besides, Romney's bill that he has on the floor wants to ban refillables, which would probably include unflavored nic.

100mg Nic is a tobacco product since it's produced from the leaf. I guess it's all in the interpretation of what a tobacco product actually is. I wouldn't consider 10% Nic (100mg/ml) to be a flavor, although for many of us it's our daily vape at whatever percentage we mix with PG and VG.

 

[Rossum]

Don't know if it makes a difference, but nic has been sold for a long time.

100 mg solution in PG or VG?

Yes, if someone could prove that this was marketed prior to 2/15/2007, it would be grandfathered, or at least be eligible for an SE application, which is (in principle) much easier than a PMTA.

 

[fiddleshe]

Bottling up my nic tomorrow or Monday when my bottles get here tomorrow. Depends how late and how lazy I feel.

 

[Brewdawg1181]

Don't know if it makes a difference, but nic has been sold for a long time. Maybe it could get through on the substantial equivalence route. I've heard that is easier than full PMTA, but I don't know how much easier. Would they still have to prove it was beneficial to the public health and all that?

I dont' think the substantial equivalence means to something that's just already on the market. My interpretation was equivalent to a product that already passed, and it leaves the submittor to prove that the minor change wouldn't cause a significant and possibly negative effect. IIRC (but very possbly don't), they mentioned in the FDA comments/responses something along the lines of varying nic content, or possibly a variation in pg/vg ratio. But the burden of proof to claim the substantial equivalence would still be on the submittor. And just because nic's been sold a long time wouldn't really mean anything. They'd likely have to get PMTA approval for several versions to begin claiming that.

I do wonder why none of the nic mfgs. have submitted for approval, though, now that we're talking about it.

 

[Brewdawg1181]

100 mg solution in PG or VG?

Yes, if someone could prove that this was marketed prior to 2/15/2007, it would be grandfathered, or at least be eligible for an SE application, which is (in principle) much easier than a PMTA.

Well, then. Disregard my previous post.

 

[*RJ*]

Bottling up my nic tomorrow or Monday when my bottles get here tomorrow. Depends how late and how lazy I feel.

I just washed all my bottles. I’ll be bottling tomorrow. I realized the box the bottles came in will be perfect for storage in the freezer. I need to make room in the freezer. My mom offered to keep it in her freezer but I don’t like that idea. 1/3 of my freezer will be nicotine.

 

[Eskie]

100 mg solution in PG or VG?

Yes, if someone could prove that this was marketed prior to 2/15/2007, it would be grandfathered, or at least be eligible for an SE application, which is (in principle) much easier than a PMTA.

Well, patches, gums, and nasal nicotine sprays have been around since well before 2007. The pharma companies had to get it from somewhere. It's not like they grew their own tobacco. So I would imagine a case could be made that if you were in the nicotine business back then you would be in under the grandfather clause and not have to file anything other than a registration. If what you made was substantially equivalent to what was available pre-2007, a SE application should theoretically be possible. And as they've already stated that they would accept differing nicotine concentrations on one application for retail juice, then a company that made 100 mg or 200 mg or 300 mg nic solutions could simply have one filing for a nicotine solution. Well, two, one for PG base and one VG.

Heartland already identifies themselves as a wholesaler. They offer industrial size products in 55 gallon drums ($7,999 if you want to really stock up and have a walk in freezer in your basement). No idea how long they've been around for, but I expect they are looking at remaining in the business even if only as wholesalers after the storm passes. Although I'm not sure Juul/Altria will rely on them as a primary supplier, but you never know.