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Notify the FDA Contest

chrisloldschrislolds Everyone, Registered Users Posts: 421
http://www.cigaraficionado.com/blogs/show/id/17611?utm_source=SilverpopMailing&utm_medium=email&utm_campaign=A%20Message%20from%20Marvin%20May%202%202014%20(3)

This is an article on the FDA wanting to define premium cigars as $10 or more. There is a link at the bottom of the article to comment to the FDA.

We have until July 1st to comment so the contest will end July 1st to give a chance for everyone to comment on it.

I'll update this post as time goes on with what you'll win, we'll have one randomly selected winner and I'll pledge 10 15 cigars(premium under $10) to start for the winner, and hopefully I'll be able to pledge more for the winner before July 1st.

To enter simply reply to this thread that you've commented and I will add your name to the list of entries.

FDA Comment Link here
and
Notify your local representative here.(link from jgiby!)

Contestants:
1. Rain
2. rsherman24
3. jgibv
4. cbuck
5. Bigshizza
6. wwhwang
7. Glock1975
8. honorknight7
9. pross
10. twistedstem
11. blutattoo
12. Gray4lines
13. Chemnitz
14. Puff_Dougie
15. ejgorman
16. matkn293
17. bearb
18. Beaker38
19. jsnake
20. Darktower007
21. ArmyS1Guy
22. MorganGeo
23. Brianak
24. FireRob
25. CharlieHeis
26. MESKC
27. perkinke
28. Jetmech_63
29. pelirrojo


«13

Comments

  • RainRain Everyone, Registered Users Posts: 8,761
  • rsherman24rsherman24 Everyone, Registered Users Posts: 2,711
    Good article and good points. I submitted a comment
  • jgibvjgibv Everyone, Registered Users Posts: 5,996
    Done.



    And you can also contact your local representatives using the CRA link below and urge them to support legislation H.R. 792 / S. 772 which would exempt premium cigars from FDA regulation.

    CRA link to contact your representative, CLICK HERE

  • chrisloldschrislolds Everyone, Registered Users Posts: 421
    jgibv:
    Done.



    And you can also contact your local representatives using the CRA link below and urge them to support legislation H.R. 792 / S. 772 which would exempt premium cigars from FDA regulation.

    CRA link to contact your representative, CLICK HERE

    Good call!
  • cbuckcbuck Everyone, Registered Users Posts: 421
    I just sent mine.
  • BigshizzaBigshizza Everyone, Registered Users Posts: 10,949
  • wwhwangwwhwang Everyone, Registered Users Posts: 2,863
  • Glock1975Glock1975 Everyone, Registered Users Posts: 4,372
  • honorknight7honorknight7 Everyone, Registered Users Posts: 525
    Both my wife and I submitted a letter.....

    The main topic of this is the guideline point #6
    (6) has a retail price (after any discounts or coupons) of no less than $10 per cigar
    (I agree with you all on this) But I also have a real concern on the guideline point #7
    (7) does not have a characterizing flavor other than tobacco
    Maybe I'm wrong on how it can be manipulated over time, but was surprised to not see anyone's complaint/comment on this point as well, Below is a copy of (my, not my wife's) comment, if it doesn't relay proper concerns please post and explain to me your thoughts on it Thanks :)

    ..............................................................................................................................................

    Regarding The FDA's Proposed Rule on tobacco products and the "Premium Cigar" Exemption...
    ***(FDA would propose to define a covered cigar to mean: any cigar as defined in this part, except a cigar that:
    (1) Is wrapped in whole tobacco leaf;
    (2) contains a 100 percent leaf tobacco binder;
    (3) contains primarily long filler tobacco;
    (4) is made by combining manually the wrapper, filler, and binder;
    (5) has no filter, tip, or non-tobacco mouthpiece and is capped by hand;
    (6) has a retail price (after any discounts or coupons) of no less than $10 per cigar (adjusted, as necessary, every 2 years, effective July 1st, to account for any increases in the price of tobacco products since the last price adjustment);
    (7) does not have a characterizing flavor other than tobacco; and
    (8) weighs more than 6 pounds per 1000 units.***

    I wanted to comment on the proposed regulation exemption regarding "Premium" cigars,
    Though I agree "mostly" on several points regarding the health issues and user age restrictions for this, I have concerns about two of the points..

    Point #6...** Has a retail price (after any discounts or coupons) of no less than $10 per cigar **

    A premium cigar doesn't and shouldn't have to cost $10 or more to be considered "Premium". The government shouldn't force me to spend $10 or more on a good $3-$9 cigar that I enjoy that meets the other proposed conditions. This seems as strictly a ruling to disallow lower income individuals such as myself from being able to participate in the consumer aspect of the exemption process of cigars. I do understand arguments for the "Higher Price" I've seen regarding "Out pricing the Youth's ability to purchase" and though that may sound like a "Real" issue, or guideline to help curb minors from purchasing cigars, it is ludicrous, the only way to prevent underage usage of any product whether it be tobacco, alcohol, spray paint or any number of other items is to enforce age restrictions, and penalties to those that sell to, or supply them with such items.

    Point #7...** Does not have a characterizing flavor other than tobacco **

    This is a scary and potentially Very open ended future removal point (for removal of most if not all "premium labeled" cigars from being exempt from the ruling) guideline point, as there are so many cigars (including already "labeled" Premium pure hand made tobacco $10+ cigars) that have very distinctive flavor profiles of (coffee, cocoa, wood flavors, leathers, spice type flavors, & floral notes and a list of many other noticeable flavor profiles) that any given number of consumers could detect in the cigar while enjoying the product, and therefore allow "ALL" cigars Period, being dropped from any exemption because a "Flavor" was noticed by any given tester, regulator, or other person enjoying the cigar.

    Also there are several "Premium (Infused) Cigars" that meet all of the guideline points other then #7 "characterizing flavor" that Many Adult consumers enjoy,
    That are not like the standard cigarette type "cigarillos" or other misleading items labeled as "Cigars" that really are not "Premium Cigars" under the guidelines that have flavors of,
    Rum, Whiskey, Cognac, Coffee, Cocoa , And a multitude of other noticeable flavor profiles such as Vanilla, & Honey
    That are not marketed to minors but to those of legal age of consent that enjoy this type of "Premium Hand Rolled Cigar" on occasion.
    Thank you for your time

    ..............................................................................................................................................
  • chrisloldschrislolds Everyone, Registered Users Posts: 421
    honorknight7:
    Both my wife and I submitted a letter.....

    The main topic of this is the guideline point #6
    (6) has a retail price (after any discounts or coupons) of no less than $10 per cigar
    (I agree with you all on this) But I also have a real concern on the guideline point #7
    (7) does not have a characterizing flavor other than tobacco
    Maybe I'm wrong on how it can be manipulated over time, but was surprised to not see anyone's complaint/comment on this point as well, Below is a copy of (my, not my wife's) comment, if it doesn't relay proper concerns please post and explain to me your thoughts on it Thanks :)

    ..............................................................................................................................................

    Regarding The FDA's Proposed Rule on tobacco products and the "Premium Cigar" Exemption...
    ***(FDA would propose to define a covered cigar to mean: any cigar as defined in this part, except a cigar that:
    (1) Is wrapped in whole tobacco leaf;
    (2) contains a 100 percent leaf tobacco binder;
    (3) contains primarily long filler tobacco;
    (4) is made by combining manually the wrapper, filler, and binder;
    (5) has no filter, tip, or non-tobacco mouthpiece and is capped by hand;
    (6) has a retail price (after any discounts or coupons) of no less than $10 per cigar (adjusted, as necessary, every 2 years, effective July 1st, to account for any increases in the price of tobacco products since the last price adjustment);
    (7) does not have a characterizing flavor other than tobacco; and
    (8) weighs more than 6 pounds per 1000 units.***

    I wanted to comment on the proposed regulation exemption regarding "Premium" cigars,
    Though I agree "mostly" on several points regarding the health issues and user age restrictions for this, I have concerns about two of the points..

    Point #6...** Has a retail price (after any discounts or coupons) of no less than $10 per cigar **

    A premium cigar doesn't and shouldn't have to cost $10 or more to be considered "Premium". The government shouldn't force me to spend $10 or more on a good $3-$9 cigar that I enjoy that meets the other proposed conditions. This seems as strictly a ruling to disallow lower income individuals such as myself from being able to participate in the consumer aspect of the exemption process of cigars. I do understand arguments for the "Higher Price" I've seen regarding "Out pricing the Youth's ability to purchase" and though that may sound like a "Real" issue, or guideline to help curb minors from purchasing cigars, it is ludicrous, the only way to prevent underage usage of any product whether it be tobacco, alcohol, spray paint or any number of other items is to enforce age restrictions, and penalties to those that sell to, or supply them with such items.

    Point #7...** Does not have a characterizing flavor other than tobacco **

    This is a scary and potentially Very open ended future removal point (for removal of most if not all "premium labeled" cigars from being exempt from the ruling) guideline point, as there are so many cigars (including already "labeled" Premium pure hand made tobacco $10+ cigars) that have very distinctive flavor profiles of (coffee, cocoa, wood flavors, leathers, spice type flavors, & floral notes and a list of many other noticeable flavor profiles) that any given number of consumers could detect in the cigar while enjoying the product, and therefore allow "ALL" cigars Period, being dropped from any exemption because a "Flavor" was noticed by any given tester, regulator, or other person enjoying the cigar.

    Also there are several "Premium (Infused) Cigars" that meet all of the guideline points other then #7 "characterizing flavor" that Many Adult consumers enjoy,
    That are not like the standard cigarette type "cigarillos" or other misleading items labeled as "Cigars" that really are not "Premium Cigars" under the guidelines that have flavors of,
    Rum, Whiskey, Cognac, Coffee, Cocoa , And a multitude of other noticeable flavor profiles such as Vanilla, & Honey
    That are not marketed to minors but to those of legal age of consent that enjoy this type of "Premium Hand Rolled Cigar" on occasion.
    Thank you for your time

    ..............................................................................................................................................
    GREAT points!
  • prosspross Everyone, Registered Users Posts: 739
    Done, and cc'd state rep and state senator.
  • twistedstemtwistedstem Everyone, Registered Users Posts: 2,691
    Done thank you for the links!!
  • blutattooblutattoo Everyone, Registered Users Posts: 1,100
    Thanks to all of those that took time to comment. I went to my local B&M today and they are just as concerned as us if not more so. If you haven't commented already please do so. Here are my comments -

    These comments are meant to address specific issues for the proposed rule-making of Docket No. FDA-2014-N-0189, and RIN 0910-AG38.

    Under section IV subsection C. - Options for Premium Cigars and Request for Comments Regarding Scope.

    I propose changes in the definition used to quantify what a premium cigar is. Under option 2 there is a ten dollar threshold in order for a cigar to meet the definition of a premium cigar. By this definition very few cigars would meet this requirement without dramatically raising their prices. When sold in bulk, by the box, or as a part of a inventory reduction sale it is very common that premium hand rolled cigars sell for three dollars per unit or less. These constitute the bulk of cigar purchases according to the boutique cigar manufacturers association. To force manufacturers and retailers into an arbitrary price point, it would not change the content of the product but only price out consumers. This would result in a loss of jobs involved in the cigar industry. This loss of jobs would be disproportionally born by small businesses. The larger companies may be able to stay in business, but the loss of tax revenue would be tangible due to pricing out most consumers. For those that continue to enjoy the pastime the burden to do so would disproportionally affect those in lower income brackets without benefiting public health.

    My proposal would be that the dollar amount threshold be removed from consideration altogether. In the other criteria used to determine the definition of a premium cigar it goes far enough by removing those cigars not considered premium by not allowing machine made cigars into the category. By making machine made cigars not a part of the category you are effectively killing the industry most associated with flavored cigars, cigars smoked more frequently, cigars smoked by younger adults and cigars most likely to not fully contain premium aged tobacco made primarily of long filler. The financial incentive to make cheap cigars will be removed by not allowing machine made cigars. This will allow variation of blends offered by manufacturers to continue without compromising what is constituted as a premium cigar for the industry and consumers, while still positively affecting public health.

    I'm sure there is more to say, but feel free to use any of these data points when sending your comments. Oh, and I'm in for the contest!
  • Gray4linesGray4lines Everyone, Registered Users Posts: 3,439
    Commented regarding price stipulation and weight although I am unsure about typical cigar weights. But certainly premium companies offer cigarillos that are nothing like black and milds.
  • ChemnitzChemnitz Everyone, Registered Users Posts: 1,070
  • Puff_DougiePuff_Dougie Everyone, Registered Users Posts: 3,182
    Comment submitted. Thanks for the heads up!
  • ejgormanejgorman Everyone, Registered Users Posts: 891
  • chrisloldschrislolds Everyone, Registered Users Posts: 421
  • webmostwebmost Everyone, Registered Users Posts: 3,131
    I don't agree with any of this. None. In a free society, a man ought to own his own body period hands down front and center clear title. My letter to these nitwits would say keep your effin nose outta my business and go get a life of your own. Alas, these nitwits would toss my letter in the box that gets toted to IRS at the end of every day.

    All you guys are doing with this approach is negotiating whether your slave collars will be forged of iron, bronze, or steel.

    What's the answer I don't know. This is not it.

  • chrisloldschrislolds Everyone, Registered Users Posts: 421
    webmost:
    I don't agree with any of this. None. In a free society, a man ought to own his own body period hands down front and center clear title. My letter to these nitwits would say keep your effin nose outta my business and go get a life of your own. Alas, these nitwits would toss my letter in the box that gets toted to IRS at the end of every day.

    All you guys are doing with this approach is negotiating whether your slave collars will be forged of iron, bronze, or steel.

    What's the answer I don't know. This is not it.

    So you don't want in the contest? ;) haha
  • wwhwangwwhwang Everyone, Registered Users Posts: 2,863
  • matkn293matkn293 Everyone, Registered Users Posts: 1,277
    I have not notified the FDA but I did go through the process to send my legislators letters regarding this subject and the bill H.R. 792, The Traditional Cigar Manufacturing and Small Business Jobs Preservation act of 2013 that is making its way through committee to protect us. I did get a response from Blaine Luetkemeyer (HOR-MO) saying that he is endorsing this bill. Kudos to all that have stepped up for our hobby / obsession.
  • bearbbearb Everyone, Registered Users Posts: 1,044
    Comments entered. Mostly on the premium concept, difference between figs and cigars and the natural components.
  • bearbbearb Everyone, Registered Users Posts: 1,044
    By the way, this was one of the topics Alex chatted with us at cfest. Giving us some relevant background and other pertinent information.
  • chrisloldschrislolds Everyone, Registered Users Posts: 421
    matkn293:
    I have not notified the FDA but I did go through the process to send my legislators letters regarding this subject and the bill H.R. 792, The Traditional Cigar Manufacturing and Small Business Jobs Preservation act of 2013 that is making its way through committee to protect us. I did get a response from Blaine Luetkemeyer (HOR-MO) saying that he is endorsing this bill. Kudos to all that have stepped up for our hobby / obsession.
    Your in, thats enough for the contest.... I also received a reply back yesterday on my letter to my congresswoman.
  • jgibvjgibv Everyone, Registered Users Posts: 5,996
    Bump
    (hope that's ok with you, Chris)

    Just got a "reply" from one of my representatives ... figured I'd bump this thread for anyone who hasn't seen it yet.
  • Beaker38Beaker38 Everyone, Registered Users Posts: 184
    i replied to http://www.regulations.gov/ on how this bill is what i call a joke. It just makes me shake my head reading the bill.
  • chrisloldschrislolds Everyone, Registered Users Posts: 421
    jgibv:
    Bump
    (hope that's ok with you, Chris)

    Just got a "reply" from one of my representatives ... figured I'd bump this thread for anyone who hasn't seen it yet.
    Definitely ok!

    BUMP
    Was gone for a few weeks but I updated the first post, I'm going to bump up the prize to 15 premium cigars (under $10 each).

    I think we've gotten most people who wanted to enter, but I'll let this run its course.... slow contest but we'll let everyone who wants get in.
  • wwhwangwwhwang Everyone, Registered Users Posts: 2,863
    Bump. If you haven't already, please sent your thoughts to the FDA.
  • jsnakejsnake Everyone, Registered Users Posts: 5,037
    Thanks for the bump. I did my part a couple weeks ago so I am in.
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