2Firsts Compliance Brief|Issue #1 Thresholds & Shakeups: Inside the New Wave of U.S. Compliance Consolidation

Jul.17.2025
2Firsts Compliance Brief|Issue #1 Thresholds & Shakeups: Inside the New Wave of U.S. Compliance Consolidation

Top News Analysis

 

BAT Acquires Three Pacha Brands from Charlie’s Holdings

2FIRSTS | BAT Subsidiary Acquires Three More CHUC E-Cigarette Products in $1.5 Million Deal

 

British American Tobacco (BAT), through its U.S. subsidiary R.J. Reynolds, has acquired three e-cigarette brands — PachaSyn, PachaMama, and Pacha Disposable — from Charlie’s Holdings. This move not only expands BAT’s presence in the U.S. but also reflects increased investor confidence in the PMTA pathway.

 

2Firsts observes that these acquired products are already progressing through different stages of the PMTA process. As enforcement tightens and unapproved products exit the market, regulatory certainty is beginning to encourage bold investment. Major tobacco firms appear to be entering a new confidence cycle — one where acquiring approved or PMTA-pending assets is seen as a viable growth strategy amid increasing barriers to market access.

 

 

North Carolina Enforces New Directory Rule for ENDS Sales

2FIRSTS | North Carolina Enforces Comprehensive E-Cigarette Regulations: Unlisted Products Banned Starting July

 

Starting July 1, North Carolina officially implemented HB900, requiring all vapor and consumable nicotine products to be listed in the state’s public directory to remain on sale. Manufacturers of non-listed products face fines of $10,000 per SKU, while retailers face escalating penalties for noncompliance.

 

According to 2Firsts analysis of the June 30 directory update:

 

● Total products listed: 876

● Brands: 28 manufacturers, mostly U.S.-based

● Product types: Disposables, cartridges, e-liquids, and refillables

● Flavor profile:

·Tobacco & menthol variants: 495 products

·Other flavors: 381 products (~43.5%), across 104 unique flavor descriptions

·Examples: Raspberry & Dragon Fruit, Orange Fantasie, Pineapple Ice

 

Most flavored entries are from U.S. brands like Vapetasia, Twist, and Cold Fusion — suggesting that flavor itself is not banned, but requires formal PMTA compliance to remain viable. Notably, there are no Chinese brands listed in the current North Carolina directory.

 

PMI Ties Compliance to Local Manufacturing with $600M U.S. Investment

2FIRSTS | PMI Launches "Invest in America" Campaign as ZYN Factory Set for Full Operation in 2026

 

Philip Morris International’s U.S. affiliate announced a $600 million investment into a nicotine pouch facility in Arizona, alongside a national campaign titled “Invested in America.” This move responds directly to Trump-era policies and Republican narratives pushing for U.S.-based manufacturing and tougher import enforcement.

 

2Firsts views this as a powerful signal of how political alignment, regulatory pressure, and trade protectionism are reshaping industry strategy. For PMI, aligning manufacturing location with regulatory credibility has become part of the playbook.

 

2Firsts View

 

China’s Manufacturers Diverge: Compliance vs. Illicit Strategy

 

As U.S. enforcement intensifies — particularly at customs and state-level — many Chinese manufacturers are adopting starkly different paths. Some, including companies with prior success in Europe or other regulated markets, see this as a historic opportunity to enter the U.S. via compliance. Others, especially those that previously relied on “gray clearance” methods, are pivoting toward more aggressive black-market strategies as traditional loopholes close.

 

This divide reflects a growing consensus: compliance is no longer optional. The FDA’s actions are forcing strategic repositioning, separating long-term players from short-term opportunists.

 

Acceptance Letters: The New Minimum Threshold for U.S. Market Entry

 

With illegal products being cleared from shelves and state directories tightening PMTA-based eligibility, one baseline standard is emerging — the FDA Acceptance Letter.

 

While the letter itself does not guarantee final approval, it proves a product’s PMTA is officially filed and under review. Increasingly, this is becoming the minimum regulatory threshold to access the U.S. market. Customs enforcement and state-level compliance systems — including directory rules like North Carolina’s — all acknowledge the Acceptance Letter as valid interim proof of compliance.

 

For brands planning serious entry into the U.S., having at least an accepted PMTA on file is no longer a nice-to-have — it’s essential.

 

2Firsts Compliance Solutions

 

Accelerating Access with 2Firsts Compliance Platform

 

To help manufacturers and brands respond to this changing landscape, 2Firsts has launched the Compliance Solutions platform — connecting Chinese and global manufacturers with scientists, labs, and regulatory experts.

 

This initiative lowers the cost and complexity of compliance while offering customized strategies for navigating PMTA and state regulations.

 

Acceptance Pro Solution

Your First Step Toward U.S. Market Access

 

2Firsts offers the Acceptance Pro Solution — a rapid, science-based service designed to help you secure the FDA’s Acceptance Letter.

 

What’s Included:

● Submission-ready PMTA documents tailored to your ENDS or Nicotine Pouch product

● Expert support for FDA eSubmitter and correspondence

● Scientifically optimized documents for acceptance-stage review

● Reference price: $20,000 USD (covers up to 10 SKUs)

 

Whether you’re entering the U.S. for the first time or relaunching through compliance, this is your regulatory starting point.

 

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Oral Thin-Film Technology Firm CTT Pharma Eyes U.S. Nicotine Product Trials
Oral Thin-Film Technology Firm CTT Pharma Eyes U.S. Nicotine Product Trials
CTT Pharmaceutical Holdings said it has signed a letter of intent with a U.S. company to conduct clinical trials and testing for several potential nicotine products using its patented oral thin-film technology.
Jun.18
FDA Commissioner Marty Makary Resigns After Opposing Trump Administration’s Flavored Vape Push
FDA Commissioner Marty Makary Resigns After Opposing Trump Administration’s Flavored Vape Push
FDA Commissioner Marty Makary resigned on May 12 after opposing the Trump administration’s push to authorize fruit-flavored vaping products, according to reporting by The New York Times. Makary reportedly objected over concerns that flavored vapes could attract young people and refused to support broader approvals.
News
May.13
Reuters: Big Tobacco Emerges as Winner After FDA Regulatory Shift
Reuters: Big Tobacco Emerges as Winner After FDA Regulatory Shift
According to Reuters, major tobacco companies may emerge as key beneficiaries after the U.S. FDA loosened regulations on vaping and nicotine pouch products, a shift that has sparked debate over public health risks.
Industry Insight
May.26
Why Many E-Liquids Today Are "Not Bad, but Not Memorable" – Mylor’s Approach to Experience Design
Why Many E-Liquids Today Are "Not Bad, but Not Memorable" – Mylor’s Approach to Experience Design
From May 8 to 10, 2026, Mylor (Booth E70) will exhibit at The Vaper Expo UK, where it will showcase its systematic experience design solutions for e-liquids. At present, the e-liquid market commonly faces a challenge: many products have “no obvious shortcomings, but lack memorable features.” In response, Mylor has proposed refined solutions across multiple dimensions, including device-adaptive sweetness, progressive cooling sensation, fruit-oriented sourness, and segmented nicotine experience.
May.08
KT&G Overseas Tobacco Revenue Jumps 24.6%, Attracting Global Capital
KT&G Overseas Tobacco Revenue Jumps 24.6%, Attracting Global Capital
South Korean tobacco company KT&G is drawing growing global investor attention after reporting record overseas tobacco sales, with international institutions including Capital Group and BlackRock increasing their stakes.
Business
May.19
Cambodia Moves to Draft New Tobacco Control Strategy Targeting Illicit Products and E-Cigarette Spread
Cambodia Moves to Draft New Tobacco Control Strategy Targeting Illicit Products and E-Cigarette Spread
Cambodian Health Minister Cheang Ra has called for the development of a tobacco control strategy for 2027–2031, with the goal of reducing tobacco use by 30% by 2030. The directive was issued during a Tobacco Product Control Committee meeting in Phnom Penh. Priority areas include reducing tobacco use, protecting the public from secondhand smoke, tackling illegal and counterfeit tobacco products, and preventing the spread of e-cigarettes.
Apr.29 by 2FIRSTS.ai