July 2016


The Child Nicotine Poisoning Prevention Act (CNPPA) of 2015 will take effect on July 26th, 2016. CASAA is recommending that members ask retailers if they know whether they will be carrying products that will be compliant with this new law. Details on this issue are below in our “legislative update” section.

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On May 10th, 2016, The Food and Drug Administration officially published their “deeming regulations” in the Federal Register. The official publication started the 90-day countdown to the effective date (August 8th, 2016) and various compliance deadlines. Despite the fact that CASAA has been sounding the alarm about this day since 2010, the advance awareness of the deeming regulations has not made their finalization any easier to digest by the community. The past month has been an emotional rollercoaster for our membership and the community at large. If left unchallenged, the impact of the FDA deeming regulations will be devastating to both the vapor industry and public health. It would be an understatement to say that CASAA is deeply concerned about, and critical of, the FDA’s decision to move forward with these regulations

In the past several weeks, efforts to push back against the regulations have started to take shape. But it should be made clear that the operative word here is “started.” CASAA acknowledges that developing useful regulation that will replace what the FDA is implementing requires a sustained effort over many years. The legal, political, and public awareness process is a long one, and our participation must be deliberate and thoughtful.
There are legislative strategies at work which we discuss later on in this newsletter.


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