I have received a couple of emails and noticed that some Vapers want to know when they can expect formal guidance, final analysis, and a call to action from CASAA and SFATA. A few of them are screaming but to a certain extent, that is to be expected. The primary reasons for the delay is the complexity of the issue. These are very very complex regulations and are not limited to 241 pages. Briefly, the FDA wants to fold these regulations into the Federal Food, Drug, and Cosmetic Act, as Amended by the Family Smoking Prevention and Tobacco Control Act; Regulations on the Sale and Distribution of Tobacco Products and Required Warning Statements for Tobacco Products. Given this fact, we are talking about hundreds of pages of regulations, actions, and opinions for attorney review and guidance to each organization. You can read the references to these numerous documents in the basic 241 page “Deeming FDA Regulations” The other issue to consider is that both CASAA and SFATA strive to release accurate and helpful guidance. Neither organization can afford a “mistake” at release. I suggest patience. My best guess for release is a week or two.
CASAA Call to Action: Change the predicate date for vapor products newly deemed as tobacco by the FDA.