The Vapor Technology Association releases new guidance on regulations.
“There is something rotten in the State of Denmark (a/k/a the FDA) but things are not quite as bad as they
may have appeared to Hamlet when he gave his famous “to be or not to be” speech. Yes, there are many
questions about what the FDA will and will not permit. And, unfortunately, the FDA does not always provide
clear answers or, for that matter, any answers. Though what follows does not constitute legal advice, we
wanted to try to bring some clarity to some important and practical issues based on our cumulative decades
of FDA experience. Use this information as guideposts but, as always, please consult your own counsel to
determine what your corporate policies should be and how to legally comply with the Deeming Regulation.”