Yes, you're basically correct (including what I presume is your satirical final comment).
Once the comment period ends, the FDA has to send the final proposed rule (which may differ) to OMB for another look. If OMB signs off on it, then Congress gets a crack at it. But Congress doesn't hav eto do anything, it just gets to look it. Under the Congressinal Review Act, congress could theoretically stop it (subject to a potential veto). Not too much chance of it being stopped there.
The good news is that Bill G. thinks it might take up to two years for the FDA to send the final proposed rule to congress. I think congress has 30 days to act (? anybody know). Something like that anyway.
That's it, the rule's final then. And then - depending on what time of year it is - registrations have to occur no later than 6 months after that or thereabouts (p.116). I'm fairlly sure that registration includes the ingredients/manufacturering process declaration. Like you, I'm very concerned that many small manufacturers will not register. Some of these Chinese companies might just say "why bother?" and pull out of the US market.
The good news is that if the FDA doesn't get the final proposed rule submitted to congress by the time of the presidential changeover, then it's probably dead. So at some point, I suspect that CASAA will be asking us to put pressure on congresspeople to start peppering the FDA with letters, queries, etc. Anything to slow them down.
Under the current proposed rule, of course, any manufacturer who does register can keep the product on the market for two years after the rule becomes final. However FDA may change that 2-year window in the final version. Although it does mirror a very similar provision in the original tobacco act, and it may be that OMB forced them to put it in.
Hope that helps.
