FDA's Regulations on E-cigarette Industry: Chinese Company's Response

Aug.08.2022
FDA's Regulations on E-cigarette Industry: Chinese Company's Response
The FDA has issued over 263 marketing denial orders (MDO) to e-cigarette companies, prompting appeals and legal battles.

Editor's note: As of July 2022, the FDA has issued marketing denial orders (MDOs) to 263 electronic cigarette companies, prohibiting the sale of their products in the United States, and has rejected over a million PMTA applications. This has led to over 40 e-cigarette companies appealing to the FDA to suspend or revoke the MDOs, with the appeal review scheduled for 2025. Huang Zhuohao, a senior consultant at the Shanghai office of the law firm Two Supreme Invited Fangda, has proposed solutions to address the US electronic cigarette regulatory policy.


Author's Bio:


Huáng Zhuōhào, a senior advisor at the Shanghai office of Fangda Law Firm and a licensed lawyer in the state of New York, USA.


The following is the original text, with added subheadings by the editor:


The FDA and E-cigarette Enterprises in Tobacco Control Act.


On July 26, 2022, the United States Court of Appeals for the District of Columbia denied a rehearing request from four electronic cigarette manufacturers: Jucice Co., Cool Breeze Vapor, Ecig Charleston, and Jay Shore Liquids.


Four companies had submitted a Premarket Tobacco Application (PMTA) to the United States Food and Drug Administration (FDA) in 2020, but all received a Market Denied Order (MDO) from the FDA in 2021. The court acknowledged the FDA's decision that there was no evidence to prove that the electronic cigarette products of these four manufacturers met the requirements of the federal Family Smoking Prevention and Tobacco Control Act, which stipulates that they must be "appropriate for the protection of public health.


In 2009, US President Obama signed the Tobacco Control Act, which authorized the FDA to regulate tobacco products. All tobacco products sold in the US are required to submit a premarket tobacco product application (PMTA), evaluated by the FDA based on toxicology, packaging, advertising, and other sales strategies to determine if the product is "appropriate for public health protection." Products that meet the criteria are granted a Market Granted Order (MGO), while those that don't receive a Market Denied Order (MDO). In 2016, e-cigarettes were included in the category of tobacco products and must now also submit PMTA and receive approval. Products that fail to submit PMTA or receive a MDO will be prohibited from importation and sale in the US market, with violators facing warnings or fines.


According to official data released by the FDA, as of July 6, 2022, the FDA has only approved PMTA and granted MGO for a total of 23 e-cigarette products from three companies: U.S.-based R.J. Reynolds Vapor Company (9), Japan-based Logic Technology Development LLC (8), and China-based NJOY LLC (6). At the same time, MDOs have been issued to 263 e-cigarette manufacturers and sellers. Over 40 e-cigarette companies have appealed against the FDA's MDO, which the courts usually suspend pending a full review. While most of these appeals are still in the court or FDA's supplementary review stage, they have put considerable pressure on the FDA, and even resulted in the voluntary suspension of some MDOs. It is foreseeable that in the near future there will be instances of the courts rejecting FDA's MDO.


Lessons from Chinese business practices


What are the implications of this series of lawsuits for Chinese companies?


Currently, a substantial number of Chinese e-cigarette products have not yet applied for PMTA or have applied but received MDO. As a result, the import and sale of these products in the United States have lost their legal basis. While the FDA's enforcement of these products is currently limited to warnings and fines, strict measures are likely to be implemented in the future. Recent reactions from various American e-cigarette companies suggest that the cessation of imports and sales is only a matter of time. This will have a significant impact on the entire Chinese e-cigarette industry.


Chinese e-cigarette companies should consider taking action as soon as possible before strong law enforcement arrives, using the rules of America's game to leverage a larger living space for themselves. Currently, the FDA's enforcement of e-cigarettes in the United States appears to be a legal issue, but behind it is America's policy orientation toward the entire industry. The core issue is how much range is allowed for the e-cigarette industry to survive in the United States. Therefore, companies need to actively respond in both the legal and policy domains.


From a legal standpoint, businesses need to actively sue the FDA for any improper administrative actions and use litigation as a means to pressure the FDA into reaching a settlement with the company. Litigation has long been the primary weapon used by American companies to combat excessive governmental abuse of power. In fact, e-cigarette giant Juul used litigation last month to force the FDA to suspend its marketing denial order and continue legally selling products in the US. Through litigation, Juul also opened up negotiations with the FDA and provided a path for potential settlements in the future.


From a policy perspective, businesses can increase their negotiation leverage by adopting practices that align with American culture and gradually shifting the policy direction. Legitimate channels, such as collaborating with American stakeholders, engaging with the media, government officials and lawmakers, and connecting with independent research organizations can be used to legitimately voice out opinions and influence e-cigarette policies in the United States. Additionally, measures aimed at improving company governance and reputation overseas can strengthen the e-cigarette industry's policy bargaining power.


Currently, the United States is enforcing laws targeting the entire electronic cigarette industry, with intertwined economic interests at play. Chinese companies will only be able to fundamentally change the policy direction of the electronic cigarette industry in the United States by joining forces, coordinating resources, and collaborating effectively.


To learn more about the legal disputes between the FDA and e-cigarette companies, click on the "FDA and E-Cigarette Company Legal Dispute Summary" topic, which is being continually updated by 2FIRSTS.


Risk Alert and Disclaimer:


This article is authorized by the author for first publication on "2FIRSTS". The views expressed in the article solely represent the author's personal opinion. The title and editorial modifications are made by the editors at "2FIRSTS". Please refer to the original text from the author for the content of the article.


This article pertains to e-cigarette policies, and readers are advised to consult official documents released by the governments of China and relevant countries for accurate information. The data and policies presented by the author in this article cannot be verified by 2FIRSTS, so caution is advised when reading.


This article is intended for industry researchers only. Please refrain from forwarding it to individuals outside of the industry or to minors.



Disclaimer

This article is provided solely for professional research, industry discussion, and informational purposes. Any references to brands, companies, products, technologies, or policies are made for factual reporting and analytical purposes only, and do not constitute endorsement, recommendation, promotion, or advertising by 2Firsts.

Nicotine-containing products, including but not limited to cigarettes, e-cigarettes, heated tobacco products, and nicotine pouches, carry significant health risks. Readers are responsible for complying with all applicable laws and regulations in their respective jurisdictions, including age restrictions and access limitations.

The information contained in this article should not be regarded as investment, legal, medical, regulatory, or commercial advice. While 2Firsts strives to ensure the accuracy and reliability of its content, it does not assume liability for any direct or indirect loss arising from errors, omissions, inaccuracies, or reliance on the information contained herein.

This article is not intended for individuals below the legal age for accessing tobacco or nicotine-related information in their jurisdiction.

 

Copyright Notice

This article is either original content produced by 2Firsts or content reproduced, translated, summarized, or adapted from third-party sources with attribution where applicable. The intellectual property rights of the original content remain with 2Firsts or the respective original rights holders.

No individual or organization may copy, reproduce, distribute, republish, modify, translate, or otherwise use this content without prior authorization. Any unauthorized use may result in legal action.

For copyright-related inquiries, corrections, or removal requests, please contact: info@2firsts.com.

 

AI-Assisted Translation and Editing Notice

Portions of this article may have been translated, edited, or reviewed with the assistance of artificial intelligence tools to improve efficiency and readability. Due to the limitations of AI-assisted translation and editing, discrepancies, omissions, or inaccuracies may exist when compared with the original source.

Where applicable, readers are advised to refer to the original source for the most complete and accurate information. If you identify any errors or believe that any content infringes upon your rights, please contact us at info@2firsts.com, and we will review and address the matter promptly.

Germany's Four-Year Tobacco Tax Plan Heads to Parliament as BAT, JTI and PMI Push for Changes
Germany's Four-Year Tobacco Tax Plan Heads to Parliament as BAT, JTI and PMI Push for Changes
Germany's parliament is scheduled to hold a first reading of amendments to the Tobacco Tax Act on September 24. The government plans annual tax increases from 2027 through 2030 covering cigarettes, heated tobacco, vaping liquids and other categories. It expects the reform to generate €756 million in additional revenue in 2027, rising to €3.589 billion in additional annual revenue by 2030. Ahead of the parliamentary debate, the German Association of the Tobacco Industry and Novel Products, or BVTE, launched the "Tabaksteuer mit Augenmaß" campaign backed by BAT, JTI, Philip Morris, Reemtsma and wholesale and retail groups.
Sep.23
JUUL2 Sued Within a Week of FDA Authorization as AJ Marketing Alleges Infringement of Programmable Vape Patent
JUUL2 Sued Within a Week of FDA Authorization as AJ Marketing Alleges Infringement of Programmable Vape Patent
Less than a week after JUUL2 received U.S. FDA marketing authorization on August 28, 2026, JUUL Labs was sued for patent infringement in federal court in Delaware. AJ Marketing LLC filed the complaint on September 3, alleging that both JUUL 1 and JUUL2 infringe U.S. Patent No. 8,851,068 B2. The patent covers aspects of programmable electronic vaporization devices, including controls over dose delivery, usage frequency and operating parameters. The plaintiff is seeking reasonable royalties and ongoing royalties tied to the remaining life of the patent. JUUL has not yet publicly responded to the case.
Sep.10
German Bundestag Passes Tobacco Tax Hikes: Vape Liquid Duty to Reach €0.44/ml, Heated Tobacco Taxes to Rise and Cigarettes Seen Near €12 a Pack
German Bundestag Passes Tobacco Tax Hikes: Vape Liquid Duty to Reach €0.44/ml, Heated Tobacco Taxes to Rise and Cigarettes Seen Near €12 a Pack
Germany's Bundestag passed amendments to the Tobacco Tax Act on October 15, 2026, setting out annual excise tax increases from 2027 through 2030 for e-cigarette liquids, heated tobacco, cigarettes and other tobacco products. Under the Finance Committee's amended bill, duty on qualifying e-liquids will rise from €0.32/ml in 2026 to €0.44/ml in 2030, an increase of 37.5%. Heated tobacco will retain its tax calculation based on 80% of the corresponding cigarette excise duty. The average price of a 20-cigarette pack is projected to approach €12 by 2030, with some brands potentially reaching €14. The legislation is projected to generate approximately €11.8 billion in additional tax revenue over four years and remains subject to further legislative procedures.
Regulations
Oct.19
PMI Expands Its Second Global and First Asian Business Services Hub in the Philippines, Serving 160 Markets and Scaling Up AI Capabilities
PMI Expands Its Second Global and First Asian Business Services Hub in the Philippines, Serving 160 Markets and Scaling Up AI Capabilities
Philip Morris International's PMI Business Solutions Philippines has expanded its global business services hub in Makati and plans to add more than 80 positions. Established in 2021 primarily to provide finance and IT support to about 20 markets, the center now employs 519 professionals delivering roughly 600 services across 160 markets. Its functions now span finance, human resources, IT, commercial operations, data analytics, supply chain and project management. PMI says the hub's next phase will focus on AI-enabled and higher-value work. The company did not disclose the size or investment cost of the expansion.
Sep.24
Smoore Seeks to Toss CCELL Price-Fixing Claim as Court Weighs Vertical Distribution Versus Horizontal Conspiracy
Smoore Seeks to Toss CCELL Price-Fixing Claim as Court Weighs Vertical Distribution Versus Horizontal Conspiracy
Smoore and four authorized U.S. CCELL distributors are asking a California federal court to permanently dismiss a core antitrust claim brought by direct purchasers. Plaintiffs allege that Smoore coordinated minimum wholesale prices, customer allocation and limits on price competition among distributors, amounting to a per se unlawful horizontal conspiracy. The defendants say the alleged conduct reflects ordinary vertical relationships between a manufacturer and its distributors. The court previously dismissed a similar claim, and the latest dispute centers on whether the second amended complaint adds sufficient facts to establish a horizontal agreement.
Sep.14
South Korea Imports 12,126 Kg of Nicotine Analogues From April to August After Bringing Synthetic Nicotine Under Tobacco Law
South Korea Imports 12,126 Kg of Nicotine Analogues From April to August After Bringing Synthetic Nicotine Under Tobacco Law
South Korea's liquid-vape market is showing changes across raw-material imports, product types and sales channels after synthetic nicotine came under the Tobacco Business Act on April 24. Customs data show nicotine-analogue imports totaled 12,126 kilograms from April through August, while synthetic-nicotine imports over the same five months totaled 231,663 kilograms, just 39.3% of the amount imported in March alone. Physical liquid-vape stores tracked in Seoul and Gyeonggi Province fell 9.9%, unmanned outlets edged higher and online sales listings increased from 27,774 to 42,437. Government testing of 105 liquid inhalation products promoted as nicotine-free separately found nicotine in 13 and 6-methylnicotine in 12.
Sep.22