

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

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

CheapEcigs LLC (http://cheapecigs.com) formally requests that the FDA extend the comment period for its proposed rule referenced above and commonly know as “Tobacco Deeming.”

We are a small company of less than 10 employees and sell electronic cigarette products exclusively via online sales.  Starting with our predecessor company - New Day Online Inc, we have allocated substantial resources (for our size) to this process.  We have previously met with OIRA on Dec 19, 2013, spending over 60 hours researching and preparing for that meeting, not to mention financial and time investment in travel.  

We want to be part of this process, we feel we have an important perspective, and we want to get our comments “right.”  The proposed Regs are over 200 standard-pages long; intermix various issues between electronic cigarettes and cigars; and at times is quite confusing.  We have counted perhaps 140 questions for which FDA requests response.  All in, it is not an easy document to which a quick response can be written.  

Response is burdensome on a company of our size - and we believe we can prudently allocate no more than 1 business hour per workday responding to these proposed regulations (10% of our working time).  We have easily already spent over 50 hours on our response, but still, we expect to put well over an additional 50 hours into our comments - we have something important to say.  Allocating more time for us to prepare a comprehensive response would greatly relieve the burden to complete a thoughtful response, and we believe not overtly cause delay of significant magnitude.  At an additional 5 hours per week, that would be an additional 10 weeks to complete our submission.

As such, CheapEcigs LLC 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.
