Here's how pipe tobacco will be most greatly impacted under the proposed regulations- any blend that was on the market prior to 2/15/07 will be grandfathered in and will be allowed to continue to be sold. Anything after that date would have to be submitted for testing and approval. The problem with that is it will cost many thousands of dollars PER BLEND for testing, so the most logical thing to do would be to stop production on all the new blends that have come out in the last seven+ years, and there would be few, if any, new products coming out in the future, because it would be economically unfeasible.
If the FDA would follow the recommendation of the Pipe Tobacco Council and use the guidelines to determine what is pipe tobacco and what is not, it wouldn't be necessary to remove any real pipe tobacco from the market. Attrition will become an issue, because, as companies disappear, so will their blends, permanently.
There are a number of reasons that we expect this to be a protracted process, but your comments to the FDA are important if we are to get them to moderate their proposals. It only takes a couple of minutes.
Russ
If the FDA would follow the recommendation of the Pipe Tobacco Council and use the guidelines to determine what is pipe tobacco and what is not, it wouldn't be necessary to remove any real pipe tobacco from the market. Attrition will become an issue, because, as companies disappear, so will their blends, permanently.
There are a number of reasons that we expect this to be a protracted process, but your comments to the FDA are important if we are to get them to moderate their proposals. It only takes a couple of minutes.
Russ