In a recent email update CASAA reminded all e-liquid manufacturers to ensure they were ready to comply with the CNPPA which is set to take effect on July 26th, if they weren’t already doing so. If you have no idea what the CNPPA is, stick around for a couple of minutes and we will explain it and give you details of exactly what is required.
What Is The CNPPA?
The CNPPA is the Child Nicotine Poisoning Prevention Act of 2015 which was signed into law by the President on January 28th 2016 and is entirely separate from the FDA’s deeming regulations. It basically states that any liquid containing nicotine must be sold in packaging approved by the Consumer Product Safety Commission (CPSC) and have passed certain tests to ensure that it is difficult for children under 5 to get into. The packaging must comply with standards set for “special packaging of household substance” under the Poison Prevention Act of 1970.
While many e-liquids are currently sold in child proof containers, there is a possibility they may not be up to the standards set in these bills. This act only seems to apply to open liquid systems and exempts closed systems where the user can not directly access any nicotine containing liquid ( even though they can).
“Liquid nicotine container” is defined to: (1) include a package from which nicotine in a solution or other form is accessible through normal and foreseeable use by a consumer and that is used to hold soluble nicotine in any concentration; and (2) exclude a sealed, pre-filled, and disposable container of nicotine in a solution or other form in which such container is inserted directly into an electronic cigarette, electronic nicotine delivery system, or other similar product, if the nicotine in the container is inaccessible through customary or reasonably foreseeable handling or use, including reasonably foreseeable ingestion or other contact by children.
There are specific guide lines that CASAA were kind enough to also put into the email and as well as ensuring that suppliers of bottles, caps etc are compliant with these regulations, manufacturers of e-liquid and consumers should also probably take note of the requirements involved. As a business owner, you may believe that your product is compliant yet under these rules it may fail. I will link directly to the Consumer Product Safety Commission document for you to read at your own leisure as well as the letter that they have been sending out to manufacturing facilities and store owners.
If you want to continue selling products after July 26th, you must make sure you meet these guidelines, plain and simple.
With the FDA dropping the deeming regulations on our heads, many people forgot that the Government had already passed a bill to make e-liquid for open systems child proof but the grace period is now over and if you aren’t compliant, prepare for the fall out.
As we pointed out, this information came directly from The Consumer Advocates for Smoke-free Alternatives Association news letter for this month and we could have cut out the middle man on this one if you just signed up with the organisation and received the same information we did.
If you are a consumer, make sure to pass this information on to your local shops and manufacturers, just to make sure that everybody has it and they don’t become a news story in a few weeks for attempting to kill children.