Is Vape Doomed?

As state bans begin to join major city bans and the FDA announcement of a new crackdown the question many people are asking is vape doomed? There’s no question vape (e-cigarette, e-liquids, ENDS hardware, etc.) faces an uphill battle at both the state and federal level here are some reasons it may continue albeit in…

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Emerging Growth Companies

Our firm offers works with companies of all sizes and at all different stages of growth. Emerging growth companies in regulated industry can need special guidance on corporate matters. Issues ranging from formation, questions about investing regulations, distribution agreements and agreements with contract manufacturers. We can discuss a broad range of corporate issues and develop…

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SNAP Trafficking Charge Letter

FDA SNAP Trafficking Attorney

Overview of USDA/FNS Charge Letter Response and Appeal SNAP Trafficking charge letter act as the official notification from the USDA FNS (United States Department of Agriculture Food and Nutrition Service) to a SNAP retailer. It will indicate the nature of the trafficking violations, the time-frame to respond, which is incredibly short, and the type of…

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Listing of Ingredients in Tobacco Products

Vape Registration

Listing of ingredients in tobacco products will be one of two submissions for newly regulated tobacco companies (vape, e-cig, e-liquid, cigar, hookah, etc.). The listing of ingredients must be submitted using the FDA’s Electronic Submission Gateway (ESG). The ingredient listings are due on one of two deadlines depending on the scale of operations. Those are…

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Tobacco Health Certificate (NCTTP)

Vape Registration

The tobacco health certificate will be one of two submissions for newly regulated tobacco companies (vape, e-cig, e-liquid, cigar, hookah, etc.). These certificates must be submitted using the FDA’s Electronic Submission Gateway (ESG). Health certificates are due on one of two deadlines depending on the scale of operations. These are February 8, 2017, or August…

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Walmart VTA Supplier Requirements

Selling with a major retailer is a dream for many companies. When selling with any major retailer it is important to understand the retailer’s regulatory requirements. Walmart VTA supplier requirements (vendor tagged advertisement) is one example. This process is sued by Walmart to approve or reject any radio or TV advertisements for its vendor’s products.…

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Amazon FDA Registration Proof

Amazon FDA Approved

Amazon FDA registration proof can be a moving target. Is it a certificate, a screenshot, or something else!? The answer varies from week to week and from seller support agent to seller support agent. Amazon FDA registration proof is something this blog has tackled on numerous occasions. Over the past six months, I’ve been working…

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FDA New Tobacco Deadlines

Vape Registration

As is well known by now the FDA Deeming Regulation is effective as of August 8, 2016. What is less well understood are the various new tobacco deadlines from the regulation. As a reminder the new tobacco deadlines apply to any new tobacco product (electronic nicotine delivery systems (such as e-cigarettes and vape pens), all…

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FDA Vaping

FDA Vape Ban

The FDA vaping regulation (a/k/a Deeming Regulation) currently requires companies to register and list their products. Previous posts discussed the FDA vaping regulation and provided updates on the registration process. After two weeks interacting with the FDA’s Center for Tobacco Products registration system it appears there is a design flaw. The system is formally known…

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