Since Congress is likely to enact the PACT Act (as the Senate approved Kohl's PACT bill several years ago, but it didn't get approved by the House), I suggest that it would be best to urge members of Congress to exempt smokeless tobacco products from the legislation.
Unlike the massive and growing problem of cigarette tax evasion, there is very little if any tax evasion or smuggling of smokeless tobacco products.
And since cigarettes are 100 times deadlier than smokeless tobacco products, there is no public health need to apply the PACT Act to smokeless tobacco products.
Although the FDA doesn't now classify e-cigarettes as tobacco products, if they do (as I've been urging the agency to), e-cigarettes would probably be considered a smokeless tobacco product (not a cigarette or cigar).
Ironically, there is far more tax evasion for cigars than for smokeless tobacco products. But cigars are exempt from the PACT Act.
Why are you urging the FDA to classify juice as a tobacco product?? This is what none of us want them to do..