This doesn't make much sense. It is still called McCranie's Red Ribbon, and it still contains the same type of tobacco ingredients, just a different crop. This is no different than any other blend that uses different crops to achieve roughly the same product.
Sorry - lost track of this thread for a day. You're right. It makes no sense. But if you read all of the FDA's guidance, each year of Christmas Cheer is a new product needing new approval. Or at a minimum submitting an application to determine "substantial equivalence." But reading their guidance, even different tin art has made products NOT substantially equivalent and require full testing as a new product. And it's ridiculous. It's like saying a 2015 Mondavi Cabernet is different from a 2016 Mondavi Cabernet. Of course they're different. It's a product made from a crop, and each year a new crop grows. Duh. Or like sweet corn. I love sweet corn, but there's definitely a difference from field to field. Occasionally you find that sweet corn that's just perfect this year. What McCranies/McClelland do is basically say each year "of all the fields worth of virginia tobacco - this was the best of the best this year." Just like finding good corn or good wine. But in the FDA's wisdom, that is now all regulated and impermissible without a process that will cost more than the total sales volume of the product each year.