"In its current form, however, the Deeming Rule appears to propose a regulatory approval process for e-cigarettes that closely mirrors that applied to traditional combustible products. This is the case despite the fact that products such as those we sell present a materially distinguishable health, safety, and efficacy profile from that of combustible products. If finalized in its draft form, the proposed Deeming Rule would pose an unbearable economic burden on our company and virtually the entirety of the electronic cigarette industry, leading to a high likelihood of substantial industry consolidation, dominance of the electronic cigarette market by a small handful of existing large tobacco companies, reduced consumer choice, fewer and slower advances in technology, and fewer existing users of combustible tobacco products switching to safer alternative products like the e-cigarettes and e-liquids that we offer. We encourage FDA to pursue less burdensome means that may be equally effective in protecting the health and safety of the public, such as a more streamlined and less expensive pre-market tobacco application (“PMTA”) and approval process."
Well written and thoughtful response. The full letter is here: http://www.totallywicked-eliquid.com/news/2014/august/twel-comments-to-fda-on-proposed.html
Well written and thoughtful response. The full letter is here: http://www.totallywicked-eliquid.com/news/2014/august/twel-comments-to-fda-on-proposed.html
