Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

Distributors — Have Your Suppliers Complied with the FDA’s Registration and Filing Requirements?

By Troutman Pepper Locke Tobacco Practice on March 20, 2011
Email this postTweet this postLike this postShare this post on LinkedIn

Since the 2009 passage of the Tobacco Control Act, the Troutman Sanders Tobacco Practice has been helping our clients comply with the many new Food & Drug Administration requirements for tobacco companies.  These requirements include FDA registration and other filing requirements.

More recently, the Troutman Sanders Tobacco Practice has been working around the clock to help our clients file their “substantial equivalence” reports due on March 22nd.  This requires reports to the FDA regarding products that were first sold after February 2007, or products that have changed since then.

Compliance with these Tobacco Control Act requirements is important, as failure to comply can render a tobacco product “adulterated” or “misbranded,” which means the product could be banned from the market.  Although the Tobacco Control Act’s requirements are generally imposed on tobacco product manufacturers and importers, these requirements are also important for distributors, because if a product is deemed “adulterated” or “misbranded,” the product in your warehouse may be banned from sale.

It is not clear whether all manufacturers are complying with the FDA’s requirements, including the “substantial equivalence” reports due this week.  Foreign manufacturers in particular may be unaware of these requirements, or perhaps even unable or unwilling to comply.  It is also unclear whether importers are aware of these requirements.  Because failure to comply with these requirements could render products unsaleable, distributors should check with their suppliers to confirm whether they have satisfied their registration and filing requirements with the FDA.

For questions and/or comments, please contact Bryan Haynes, at 804.697.1420 or by email.

  • Posted in:
    Food, Drug & Agriculture
  • Blog:
    Tobacco Law Blog
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo