FDA has published its new compliance deadline chart, which sets forth the various new deadlines and to which entities such deadlines apply. The chart can be found here: FDA New Compliance Deadline Chart

It further notes a clarification that:

• Retailers that mix and prepare e-liquids or create or modify vaporizers will be regulated as both retailers and manufacturers.
• Importers of tobacco products must ensure that the tobacco products they import are in compliance with the law.

“[F]ailure to comply with these requirements may render a tobacco product adulterated, misbranded, or both, and it is unlawful for any entity to sell or distribute an adulterated and/or misbranded product in interstate commerce.”

For more details contact Thomas Norby or Lindsey Streicher.