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Vapor Solutions and Labs, LLC manufactured and sold e-liquid tobacco products without obtaining required premarket authorization orders, violating the Family Smoking Prevention and Tobacco Control Act and the Federal Food, Drug, and Cosmetic Act. The FDA determined that the company's e-liquid products met the legal definition of tobacco products subject to FDA jurisdiction as electronic nicotine delivery systems (ENDS) under the August 8, 2016 deeming rule, and therefore required premarket approval before being marketed in the United States. The company failed to comply with FD&C Act requirements applicable to "new tobacco products" that were not commercially marketed in the U.S. as of February 15, 2007.