Placement:

The Tobacco Control Legal Consortium (TCLC) is urging the public to write to the FDA and encourage the agency to strengthen the proposed deeming regulations on electronic cigarettes. In a set of provided by the TCLC, the Consortium attacks the 24-month grace period for the submission of substantial equivalence or new product applications by electronic cigarette products, calling for the removal of this grace period:

Under this provision, an electronic cigarette company cannot even inform consumers that the product does not produce smoke because such a claim would be considered a "reduced exposure" claim under the Tobacco Act.

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