

Comment Info: =================

General Comment:May 12, 2014

Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane
Room 1061
Rockville, MD  20852

Re: Request for Extension of Comment Period: Docket No. FDA-2014-N-0189

We at Cignot St. Louis have conducted preliminary review of your lengthy proposed regulations and respectfully request that the Food and Drug Administration (FDA) extend the comment period for the proposed rule entitled “Deeming Tobacco Products to be Subject to the Federal Food, Drug, and Cosmetic Act, as Amended by the Family Smoking Prevention and Tobacco Control Act; Regulations on the Sale and Distribution of Tobacco Products and Required Warning Statements for Tobacco Products.” 

We, Cignot St. Louis, are a small electronic cigarette retailer, employing fewer than 350 people.  We are family owned and operated, and carry higher end products including Joyetech, Kanger tech, Vision and much more.  As explained further below, the initial 75-day comment period does not provide enough time for companies like Cignot St. Louis to adequately analyze the entire proposal and provide substantive comments on the many questions posed by the agency. We need more time to address this 240-page document whose contents will deal a devastating economic blow to our business.

The preamble to the proposed rule identifies approximately 70 topics and issues the agency has requested comments on. Many of these issues are complex and difficult and relate to an extremely diverse array of products.  Clearly, the lengthy time period that the Agency required to propose these regulations is evidence that the issues addressed in the proposal are multi-faceted and challenging.  FDA cannot expect any interested party, and in particular, any manufacturer, to conduct a meaningful review and analysis of these issues and provide detailed and thoughtful comment in a 75-day period. 

Therefore, Cignot St. Louis again respectfully requests that FDA extend the comment period to 180 days as this will help ensure that the final rule is based on an adequate and meaningful administrative record.  Thank you in advance for your consideration of this request.

Sincerely,


Ryan Cunningham

