

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

General Comment:June 25, 2014
Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane
Room 1061
Rockville, MD 20852

Re: Food & Drug Administration, Docket No. FDA-2014-N-0189, RIN 0910-AG38 “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.”

Subject: Request for Further Extension of Comment Period
We at Cherry Vape have conducted preliminary review of your lengthy proposed regulations and respectfully request that the Food and Drug Administration (FDA) FURTHER 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 andTobacco Control Act; Regulations on the Sale and Distribution of Tobacco Products and Required Warning Statements for Tobacco Products.”

Cherry Vape, LLC is small e-cigarette components and e-liquid US manufacturer/distributor and retail shop owner, employing fewer than 350 people. 

The initial 75-day comment period does not provide enough time for companies like Cherry Vape 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. The components we produce vary by design and color -- more than 70 currently -- and we have hundreds of variations of e-liquid, as well. 

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 such a short time period.

Therefore, Cherry Vape again respectfully requests that FDA extend the comment period by 105 days and agree to accept comments filed to the docket on or before October 22, 2014. 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,
Cheryl L Richter
Co-Owner
Cherry Vape LLC
634 Webster Avenue
New Rochelle NY 10801
cheryl@cherryvape.com
224-377-9827

