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  • Deanna Clark

Submit Your Comments On Our FDA Citizen Petition


On October 6, 2022 we submitted a Citizen Petition on behalf of our client, Vapor Vapes, Inc., to the U.S. Food and Drug Administration (FDA) to address a lack of appropriate guidance and agency regulation for tobacco and vapor companies who export products. In our petition we requested that FDA do the following:

  • Amend the regulation pertaining to the export of tobacco products, namely, 21 C.F.R. §1.101(b)

  • Issue a Guidance document for industry for Tobacco Product Inspections at manufacturing facilities that are engaged, in whole or in part, in the manufacture of tobacco products for export

  • Issue an update to FDA's Investigations Operation Manual (IOM) regarding inspections of manufacturers that export a tobacco product

If FDA does not take these actions the tobacco industry will continue to operate amid a lack of necessary guidance and regulation and will remain at risk of enforcement actions for products intended for export and exempt from domestic tobacco product regulation.


Our petition is now publicly available for comment on Regulations.gov. Click the button below to visit Regulations.gov where you can download and read our full petition.

Once on the page, click the “Comment” button shown in the graphic below to leave your comments on our petition. Please leave your comments within the next 30 calendar days.

Have questions about our Citizen Petition? Give our office a call today.


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