Posts by Marc Sanchez
SNAP Trafficking Charge Letter
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…
Read MoreFDA Form 483 Response Strategy – FY 2012 Inspectional Observation Summaries
FY 2012 Inspectional Observation Summaries FDA Form 483 response strategy – perhaps the best strategy to both prepare for a
Read MoreListing of Ingredients in Tobacco Products
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…
Read MoreTobacco Health Certificate (NCTTP)
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…
Read MoreWalmart 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.…
Read MoreAmazon FDA Registration Proof
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…
Read MoreFDA New Tobacco Deadlines
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…
Read MoreFDA Vaping
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…
Read MoreFDA Enforcement and Recall Report Week of July 18
FDA Recalls Each week the FDA reports on its enforcement activities as a guide to FDA compliance. To help capture and digest that information the FDA Atty blog will post FDA recalls and warning letters. This week continues the slow roll out of recalls. The biggest burst coming from the continued E. Coli concern with…
Read MoreFDA Enforcement and Recall Report Week of July 11
FDA Recalls Each week the FDA reports on its enforcement activities as a guide to FDA compliance. To help capture and digest that information the FDA Atty blog will post FDA recalls and warning letters. This week is both late and light due to the Independence Day holiday, but the FDA’s response to the General…
Read MoreFDA New Tobacco
FDA new tobacco regulation also known as the Deeming Regulation takes effect in 30-days (August 8, 2016). The regulations are broad, complex and impact every part of electronic nicotine delivery systems (such as e-cigarettes and vape pens), all cigars, hookah (waterpipe) tobacco, pipe tobacco and nicotine gels, among others. This has created a great deal…
Read MoreFDA Enforcement and Recall Report Week of July 4
FDA Recalls – General Mills and Raw Cookie Dough Each week the FDA reports on its enforcement activities as a guide to FDA compliance. To help capture and digest that information the FDA Atty blog will post FDA recalls and warning letters. This week is both late and light due to the Independence Day…
Read More