Special Report｜CrossBar's High-Puff Vapes Draw Attention on Pennsylvania's 163-Product Directory as Link Between Earlier 1.3mL PMTA Filings and New 13mL Products Remains Unclear

Key Points

Pennsylvania's October 18 ENDS directory contained 163 entries, including 15 disposables. CrossBar's four 13mL devices were distinctive for their advertised 20,000-puff capacity and contemporary high-capacity design.

Historical CrossBar records show 1.3mL devices, compared with newer 13mL products appearing in state directories from 2025 onward.

PMTA compliance expert Mr. K identified application amendments and ownership transfers as possible explanations for product and corporate changes, while FDA rules require new PMTAs for additional products.

Reynolds acquired 16 PACHA products and related assets for $7.5 million in 2025. Seller Charlie's Holdings reported retaining 678 PMTA-submitted products as of June 2026.

2Firsts

October 22, 2026

Pennsylvania began enforcing restrictions on electronic nicotine delivery system (ENDS) sales on October 19, 2026. According to a 2Firsts analysis of the October 18 directory, 163 product entries from seven manufacturers included British American Tobacco's Vuse, Altria Group's NJOY, JUUL and Japan Tobacco's Logic.

Four CrossBar disposable vapes stood out for their 13mL e-liquid capacity, advertised 20,000-puff rating and broad, flattened design, markedly different from the conventional closed-pod systems and compact disposable devices that account for much of the directory.

A Pennsylvania vape distributor told 2Firsts that CrossBar had become a sought-after product among local retailers. The distributor said his company was one of three businesses with distribution authorization for the products and described CrossBar as one of the few directory-listed options resembling contemporary high-puff disposable vapes.

The listing raises a regulatory question. Pennsylvania's certification framework includes an eligibility pathway linked to qualifying premarket tobacco product applications (PMTAs) submitted to the U.S. Food and Drug Administration (FDA) by September 9, 2020. Yet CrossBar 20K's capacity and appearance resemble high-puff disposable formats that became popular several years later.

CrossBar Stands Apart From Conventional Vapes on Pennsylvania's Directory

Pennsylvania Attorney General Dave Sunday announced on October 8 that enforcement under Act 57 of 2025 could begin on October 19.

The October 18 directory contained 163 entries from seven manufacturers. BAT, Altria, Japan Tobacco and JUUL accounted for a combined 112 entries, or approximately 68.7% of the total.

By product type, the directory comprised 68 pod entries, 40 bottled e-liquids, 24 kits, 16 devices and 15 disposable vapes.

The 15 disposable entries covered three product series: NJOY DAILY and DAILY EXTRA, e Cig 4 Inmate, and CrossBar.

Altria-owned NJOY DAILY products feature a traditional compact disposable format. Official packaging images of e Cig 4 Inmate show a narrow, transparent tubular device.

CrossBar was the only series among the 15 disposable entries with the broad, flattened design and advertised high-puff capacity associated with recent mainstream disposable vapes.

Naked 100, another independent brand represented on the directory, accounted for 40 bottled e-liquid entries rather than complete disposable devices.

E-liquid capacity further differentiates CrossBar from the traditional disposable and closed-pod products listed in Pennsylvania.

Note: The comparison covers relevant product families represented on Pennsylvania's directory. Capacity figures refer to a complete disposable device or a single prefilled pod or cartridge and are based on corresponding U.S. product documentation, FDA records or published research. Unverified capacities are not estimated. A directory listing does not establish unrestricted commercial availability: NJOY ACE is separately subject to U.S. International Trade Commission restrictions affecting its sale and distribution.

CrossBar 20K's 13mL capacity is approximately 14.4 times that of a single NJOY DAILY disposable (0.9mL), 7.2 times that of a Vuse Alto pod (1.8mL), and 18.6 times that of a JUUL pod (0.7mL).

Capacity alone does not determine total puff count or nicotine delivery, but the figures illustrate the substantial difference between CrossBar and conventional closed-system vaping products.

Pennsylvania's four listed CrossBar products are Butterscotch Tobacco, Raspberry Wafer Tobacco, Blue Razz Ice Menthol and Miami Mint Menthol. Official packaging records identify 13mL capacity, 50mg/mL nicotine concentration and an advertised maximum of 20,000 puffs.

Brands prominent in the more recent U.S. disposable vape market, including Geek Bar, RAZ, Lost Mary and Elf Bar, were absent from the October 18 directory.

The Attorney General's Office said 22 additional manufacturer certifications were under review and that the directory would continue to be updated.

CrossBar Appears on Multiple State Directories as 13mL Products Emerge in 2025

CrossBar's directory presence extends beyond Pennsylvania.

A 2Firsts review of publicly available state records identified entries for the four newer CrossBar products in Pennsylvania, North Carolina, Virginia, Nebraska, Tennessee and Mississippi.

The records name entities including Blue Nine LLC and VR Products I LLC and share four UPC identifiers:

North Carolina added four CrossBar products registered by Blue Nine LLC on May 1, 2025. Nebraska's directory explicitly identifies the newer products as 13mL devices.

Earlier 1.3mL CrossBar products also appeared in Louisiana and Arkansas. Wisconsin listed four newer products in May 2025 but removed those entries in February 2026.

CrossBar therefore appeared in product directory records from at least nine states during the periods examined. Six states listed newer products, two had historical 1.3mL entries, and Wisconsin had previously listed and then removed the newer products.

Directory eligibility, filing dates and product status vary among states. State listing does not constitute FDA marketing authorization.

CrossBar has also promoted its presence on multiple state directories in commercial materials, using eligibility as part of its distribution messaging.

From 1.3mL to 13mL: CrossBar's Product and Registration History

Historical CrossBar products differed substantially from the 13mL CrossBar 20K devices listed in Pennsylvania.

An FDA PMTA review document identified Romo LLC dba CrossBar. Louisiana's historical records listed CrossBar Tobacco 24mg and Menthol 24mg products associated with Romo LLC, each containing 1.3mL of e-liquid and linked to a September 9, 2020 PMTA filing date with an under-review status.

The newer CrossBar 20K products contain 13mL of e-liquid, ten times the capacity of the historical 1.3mL devices, and feature a substantially different body design and advertised puff count.

Table 2. Historical CrossBar Products and the Newer 20K Series

Note: Historical 18mg and 24mg product labels are not expressed in the same units as 50mg/mL and should not be used for a direct concentration comparison. The records do not establish that both generations are covered by the same PMTA.

A tobacco product listing export obtained by 2Firsts from FDA's registration system contained 12 CrossBar-related historical product records, including eight e-cigarette entries and four bulk e-liquid entries. The e-cigarette records included Tobacco and Menthol variants labeled 18mg and 24mg.

An FDA establishment registration export dated October 22, 2026 also identified a Romo LLC facility in London, Kentucky. Its declared operations included manufacturing, labeling, packaging and storing, under facility identifier 3014467785.

That record establishes a U.S. manufacturing-related establishment registration for Romo LLC but does not identify the manufacturing location of the current 13mL devices.

Corporate and trademark records point to developments in the first half of 2025.

Romo LLC filed CrossBar-related trademark paperwork in March 2025, around the time Blue Nine LLC was formed. Four newer CrossBar products registered by Blue Nine entered North Carolina's directory on May 1.

By 2026, Blue Nine was also the registering entity for four 13mL CrossBar products on Pennsylvania's directory.

Public documents reviewed by 2Firsts do not establish whether brand assets or PMTA application rights were transferred from Romo to Blue Nine, or whether the newer products were covered by the historical applications.

PMTA Compliance Expert Cites Possible Amendments and Ownership Transfers

Mr. K, a PMTA compliance expert, identified amendments to pending FDA applications and changes in application ownership as possible explanations for CrossBar's changing product specifications and registration entities.

FDA allows applicants to submit amendments while their PMTAs are under review, including updated scientific information, responses to agency requests and certain changes to previously submitted product details.

Form FDA 4057a includes an Update Product Properties section that allows applicants to identify previously submitted properties and revised target values.

The form also states that amendments cannot be used to add new products to an existing application. Additional products require a new PMTA.

Whether changing a product's e-liquid capacity from 1.3mL to 13mL could qualify as an amendment to an existing submission depends on the original application's scope, the changes involved and FDA's handling of the application.

Form 4057a also provides a Change in Ownership process, requiring documentation from the previous and new applicants and identification of the relevant applications, product names and submission tracking numbers.

No public materials reviewed by 2Firsts establish that CrossBar introduced its 13mL products through those procedures or that Romo LLC transferred the relevant applications to Blue Nine LLC.

Pennsylvania's directory framework includes an eligibility route for qualifying products with timely filed PMTAs. That route involves products already marketed in the United States by August 8, 2016, with applications submitted by September 9, 2020, alongside other legal requirements. The law also establishes other specified certification circumstances.

The precise certification basis for the four CrossBar 20K products has not been established from the public product records reviewed.

Reynolds' $7.5 Million PACHA Deal Highlights the Commercial Value of PMTA-Related Assets

Around the time newer CrossBar products began appearing in multiple state directories, a separate transaction provided a documented example of the commercial value of products associated with historical PMTA submissions.

On April 16, 2025, Charlie's Holdings signed an asset purchase agreement with R.J. Reynolds Vapor Company, part of British American Tobacco's U.S. operations. Reynolds agreed to acquire 12 PACHA synthetic nicotine products and related assets for $5 million.

According to filings with the U.S. Securities and Exchange Commission (SEC), the associated PMTAs were originally submitted in 2022.

A May 29 amendment added three products for $1.5 million. Another transaction on August 8 added one product for $1 million.

The transactions ultimately covered 16 PACHA products and related assets for $7.5 million in fixed cash consideration. The original agreement also included a contingent payment of up to $4.2 million, tied to commercial performance.

The asset purchase agreement filed with the SEC identified three PMTA submission tracking numbers: PM0005632, PM0005565 and PM0005433.

The contract included regulatory submission materials and related rights among the acquired assets and required documentation concerning the transfer of applications to FDA.

The $7.5 million represented consideration for a portfolio of products and related assets, not a stand-alone valuation of PMTA applications.

In its quarterly report for June 30, 2026, Charlie's disclosed that it still held 678 products for which PMTAs had been submitted following the transactions.

The company said its remaining PMTA portfolio could have significant monetary value and outlined plans to strengthen applications with additional scientific data, update selected products with age-verification technology and explore further strategic partnerships.

The company also said it intended to pursue amendments to relevant existing PMTAs as part of those plans.

SEC filings establish the PACHA transaction and associated regulatory asset provisions. No evidence reviewed by 2Firsts establishes that CrossBar underwent a comparable ownership transfer.

The two developments occurred within a similar period. Reynolds completed its first two PACHA acquisitions in April and May 2025. Four newer CrossBar products entered North Carolina's directory that May.

By October 2026, Pennsylvania had begun enforcing its directory-based sales restrictions, making state eligibility more consequential for wholesale sourcing and retail product availability.

The PACHA deal offers a documented transaction value for assets linked to historic PMTAs. CrossBar's Pennsylvania position illustrates how directory eligibility can affect distribution opportunities for products with a different format from most other listed devices.

As more states impose product directory requirements, historical PMTA submissions, product-specific eligibility and the ability to transfer related assets are becoming increasingly relevant to corporate strategy and market access in the U.S. vaping industry.

Follow 2Firsts for timely updates on global tobacco and nicotine industry developments, corporate strategy and market trends.

Cover Image: Left, AP Photo/Tony Dejak, 2015; right, CrossBar promotional materials.

2FIRSTS | Pennsylvania Lists 163 Vape Products Eligible for Sale, Including Vuse and JUUL; Previously Pending Chinese Brands Such as OXBAR Remain Absent, While Unlisted Products Including Geek Bar Face Enforcement From October 19

Pennsylvania begins enforcing its electronic nicotine delivery system (ENDS) directory restrictions on October 19, 2026. The October 18 directory contained 163 product records from seven manufacturers, including Vuse, JUUL, NJOY, Logic and Naked 100. Geek Bar, RAZ and Lost Mary were absent. BAT, Altria, Japan Tobacco and JUUL collectively accounted for 112 records, or 68.7%, while Imperial Brands' blu had no listings. The directory included 15 disposable vape records, 40 bottled e-liquids and 10 products labeled 0mg, but no open-system refillable devices. Twenty-two manufacturer certifications remained under review. Four Logic models corresponding to Smoore's pending records were listed under the brand owner, while LYCO, OXBAR and Boulder/Rock had no approved directory entries.

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Reference

1. Pennsylvania — ENDS Directory
2. Pennsylvania — Act 57 Enforcement Announcement
3. 2Firsts — Pennsylvania 163-Product Directory
4. Pennsylvania — CrossBar 20K Official Packaging
5. Pennsylvania — e Cig 4 Inmate Official Packaging
6. FDA — Authorized ENDS Products
7. FDA — NJOY DAILY Technical Review
8. FDA — NJOY ACE Marketing Order
9. Published Study — Vuse Vibe and Ciro Product Specifications
10. FDA — PMTA Guidance
11. SEC — PACHA Asset Purchase Agreement
12. SEC — Charlie's Holdings, June 2026 Quarterly Report

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