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Oct 7, 2016
2,451
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Interesting that there are no entries for C&D, Lane, or Sutliff. What do you make of that?
The short answer is beats the hell out of me. The longer answer is that, other than filing for approval as a totally new product and starting from scratch, there are/were three pathways for keeping an existing product on the market:

(1) Grandfathering. There is a separate database for that, but it clearly does not include lots of things that “we all know” were on the market at whatever date in 2007 was relevant, haven’t changed manufacturer, nor recipes that anyone has been able to discern. I know others who have tried to search this database and come to the same “wtf’ conclusion. It MAY be that the database was a snapshot at a particular time and just isn’t up-to date. A lot of C& D and Pease blends are on this database If you search under Laudisi. I have not looked for Sutliff or Lane. And my understanding is that you can still submit an application for grandfathering. And Kretek got Bracken Flake grandfathered. Huh?

(2) Substantially Equivalent to something that has been, or I guess could be, grandfathered. Last I heard, the FDA hadn’t published a database for these applications, in part because the industry raised trade secret issues. There is a “batch application“ procedure the FDA has opened for this route, and that, combined with the (for now) confidentiality might be the preferred route for some companies who are paranoid about disclosure, but I don’t know.

(3) PMTA, which appears to be the route companies like D&R , Intercontinental and other players in the convenience store “pipe tobacco” market have followed.

From what I have heard, a lot of the paperwork the FDA wants to see is focused on how you market the product. They really want to corral vapes, alternative nicotine delivery products, and anything with youth oriented flavors, and I hear those products are getting the full proctologist examination, with less concern about chemistry than one might have thought early on. One Lane executive on this very forum a few years ago said products had to be “molecule for molecule“ the same, an interpretation that had already been superseded by informal guidance, but was still the prevailing view in the trenches of the trade.

So my best answer is, still, beats hell out of me. And nobody is paying me to come up with a better answer. Besides which, I am fully, completely and happily retired, and therefore I can’t legally take a fee anyway.

ETA: Several pages worth of blends by Lane , Sutliff, and Laudisi were submitted for grandfathering here.
 

macaroni

Lifer
Oct 28, 2020
1,007
3,116
Texas
. . . Several pages worth of blends by Lane , Sutliff, and Laudisi were submitted for grandfathering here.
Thank you for providing this information, I was unaware of it. I don't know what the category on the chart, "Determination," means. And I'm also ignorant what the status, "Established," means. I looked for Laudisi and happily scanned through several pages that included lots of blends I like.

Is it too much to expect this means that all these blends listed as, "Established," will continue being made after this fall?

And I wonder if a price increase (say 10 or 15%) can be expected after a company has gone to all this work to get through the process? Or does a doubling or tripling of prices sound more accurate?

Any guesses, crystal balls, gazing balls LOL
thnx again,
mike
 
Oct 7, 2016
2,451
5,196
Is it too much to expect this means that all these blends listed as, "Established," will continue being made after this fall?
Yes, subject to decisions made by the manufacturer for reasons having to do with demand, ingredient availability, etc.

Any thing is a good reason for a price increase, cost of compliance is just another one.
 
You're friends with Mark Ryan? He's the guy who really knows how to make the stuff, why not knock on his door? I expect he could whip some up in a jiffy even if it couldn't be tinned and labeled "Picayune"
I think I missed this one last night, and it makes all the sense in the world... which is probably why it didn’t occur to me right away... duh!
Ok, time to talk to the wizard!
 
Cosmic, give it a year and your homegrown picayune style twists will leave the actual product for dead.

On another note, I’m intrigued to see how blending some perique increases your nicotine absorption from 5bros.
Yes, I’ll take more of a C&D approach... “does it make you puke yet?”
add more burley!!! puffy

I still have some raw leaf burley and rustica from years past. I may just see what adding perique to rustica tastes like.
 

sablebrush52

The Bard Of Barlings
Jun 15, 2013
19,768
45,349
Southern Oregon
jrs457.wixsite.com
The short answer is beats the hell out of me. The longer answer is that, other than filing for approval as a totally new product and starting from scratch, there are/were three pathways for keeping an existing product on the market:

(1) Grandfathering. There is a separate database for that, but it clearly does not include lots of things that “we all know” were on the market at whatever date in 2007 was relevant, haven’t changed manufacturer, nor recipes that anyone has been able to discern. I know others who have tried to search this database and come to the same “wtf’ conclusion. It MAY be that the database was a snapshot at a particular time and just isn’t up-to date. A lot of C& D and Pease blends are on this database If you search under Laudisi. I have not looked for Sutliff or Lane. And my understanding is that you can still submit an application for grandfathering. And Kretek got Bracken Flake grandfathered. Huh?

(2) Substantially Equivalent to something that has been, or I guess could be, grandfathered. Last I heard, the FDA hadn’t published a database for these applications, in part because the industry raised trade secret issues. There is a “batch application“ procedure the FDA has opened for this route, and that, combined with the (for now) confidentiality might be the preferred route for some companies who are paranoid about disclosure, but I don’t know.

(3) PMTA, which appears to be the route companies like D&R , Intercontinental and other players in the convenience store “pipe tobacco” market have followed.

From what I have heard, a lot of the paperwork the FDA wants to see is focused on how you market the product. They really want to corral vapes, alternative nicotine delivery products, and anything with youth oriented flavors, and I hear those products are getting the full proctologist examination, with less concern about chemistry than one might have thought early on. One Lane executive on this very forum a few years ago said products had to be “molecule for molecule“ the same, an interpretation that had already been superseded by informal guidance, but was still the prevailing view in the trenches of the trade.

So my best answer is, still, beats hell out of me. And nobody is paying me to come up with a better answer. Besides which, I am fully, completely and happily retired, and therefore I can’t legally take a fee anyway.

ETA: Several pages worth of blends by Lane , Sutliff, and Laudisi were submitted for grandfathering here.
Thanks for providing the link. All of the D&R that's still in production were on that list as well, and no Picayune. Interesting that they're listed as RYO tobaccos on the Grandfathered list and listed as Pipe Tobacco on the PAL list. Seems they've got these redefined, or are trying to. I'm guessing for tax purposes.
More better, and surprising, a lot of Watch City blends are grandfathered in as well.
There were a few other "interesting" surprises as well.
 
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brew

Lurker
Feb 18, 2016
4
3
I went to every pipe forum in existence in 2013, and promoted saving EGR. I discussed what the blend was (posted my review), what the history of the blend was that I knew at the time, and the importance of keeping a historical blend in production. I encouraged everybody to e-mail the company, and respectfully tell them why they wanted to blend to continue production. I also suggested that people ask Sutliff to produce it in tins, and not just tubs for those who, like me, couldn't afford or didn't want to spend $38. for a tub when they didn't know whether or not they would like it. I responded to every question on every thread in every forum. I contacted every e-tailer, and personally spoke to them on the phone about ordering EGR. Then, I sent links to every thread to Sutliff so they could see how many people were interested. Between that, e-tailers calling to order it, and the avalanche of e-mails (which crashed their server for three days), Sutliff decided in our favor.
I own 14 large tins of LLRR. It has become my go to blend. Thank you.
 
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Dec 6, 2019
4,296
19,375
33
AL/GA
Man.. I had high hopes when I started reading this thread. I sent my email. Great plan.. talk to the legend himself. Tell him I'm down to only a few pounds, and this makes me more depressed with every bowl I smoke.
 
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Man.. I had high hopes when I started reading this thread. I sent my email. Great plan.. talk to the legend himself. Tell him I'm down to only a few pounds, and this makes me more depressed with every bowl I smoke.
I haven't gotten a reply from Mark yet, but I was mostly asking him for help recreating it. I figured that if he no longer was active with blending that he wouldn't be able to make up a batch. But, maybe I should have been more vague, so that the thought would cross his mind. I will send him another email. I just don't want to come across as a crazy Picayune fan, wanting to toss my panties at him on stage, ha ha.
 
Dec 6, 2019
4,296
19,375
33
AL/GA
I haven't gotten a reply from Mark yet, but I was mostly asking him for help recreating it. I figured that if he no longer was active with blending that he wouldn't be able to make up a batch. But, maybe I should have been more vague, so that the thought would cross his mind. I will send him another email. I just don't want to come across as a crazy Picayune fan, wanting to toss my panties at him on stage, ha ha.

Yep. That's what I'd look like. Haha The struggle is real.. Man I barely want to smoke anything else, and I still haven't found a replacement.
 
Yep. That's what I'd look like. Haha The struggle is real.. Man I barely want to smoke anything else, and I still haven't found a replacement.
There really isn't anything close to it, but I think you might like C&D Burley Flake #1. It's worth a try, but like I said, it isn't close in the flavor at all.
 
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