May 20 is the Deadline to Comply with the European Tobacco Products Directive (EU TPD)
by: Maria Verven
Any e-liquid manufacturer selling in Europe must know what these initials mean, because it’ll be the law on May 20 this year. The European Tobacco Products Directive (EU TPD) has set reporting, guidance and restrictions on cigarettes since 2001 and in May, the TPD’s Article 20 will regulate e-cigarettes as well.
“The TPD will affect every e-liquid or e-cigarette manufacturer selling in any one of the EU’s 28 countries,” said Dennis Moore, founder and CEO of Chemular, a full-service regulatory consulting firm that boasts the largest team of compliance, manufacturing software and engineering experts specializing in the U.S. vaping industry.
Moore and the Chemular team are currently helping e-liquid companies gain compliance with the TPD while lowering their liability risk by following best of-class quality practices. A former FDA investigator and regulatory expert, Moore is highly qualified to help companies negotiate the TPD’s quality standards as well as the labyrinth inside the FDA.
What does complying with the TPD mean, exactly? The TPD requires companies to submit a dossier including detailed toxicology and emissions data on every flavor I every nicotine level that flavor comes in. A technical file must also be submitted on any new product at least six months prior to launch.
While hiring an attorney isn’t necessary, most companies need the guidance of regulatory and quality professionals to help them prepare the technical file and registration dossier. The process can take several weeks, and if the deadline isn’t met, sales are banned for six months.
What’s Wrong with the TPD
The main issue with Article 20 of the TPD – like the FDA’s deeming regulations – is it fails to recognize where vaping products fall in the risk continuum, according to Robert Burton, Chemular’s chief scientific officer and former head of regulatory affairs for White Cloud. “Cigarettes are the most harmful things on the tobacco harm reduction risk continuum,” said Burton. “But the way the TPD is written, it doesn’t support that.” Burton first started working with the TPD on the tobacco side over nine years ago. “Like many of these regulations, they’re not appropriate for vaping products,” he said.
“E-cigarettes and vaping products have been inappropriately squeezed into these regulations.” Regardless, the TPD is a fact of life that e-liquid companies will have to live with. The only exception is zero nicotine e-liquids or e-cigarettes; if they don’t contain nicotine, they don’t fall under the TPD.
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A simple way to remember three key hallmarks of the TPD is 20-20-10. May 20 is the deadline. 20 mg is the maximum nicotine concentration. And 10 ml is the maximum bottle size.
With May 20, 2016, as the final compliance deadline, each of the 28 European member states may adopt some or all of the TPD guidelines – or come up with its own. So far, Denmark, Finland, Hungary, Italy, Latvia, Lithuania, Netherlands, Poland, Portugal, Slovakia, Spain and the U.K. have fully adopted the TPD’s guidelines, while the Czech Republic, Germany, Ireland have partially adopted them.
Austria, Belgium, Bulgaria, Croatia, Cyprus, Estonia, France, Greece, Luxembourg, Malta, Romania, Slovenia and Sweden have yet to adopt any guidelines, although Moore expects these countries to simply adopt the TPD rulebook, as it stands.
“When you’re dealing with 28 member states, it’s quite a complicated matrix,” Moore said. He explained that the format of the dossier varies from member state to member state, depending on their sophistication and ability to deal with proprietary information. For example, some countries require an electronic ingredient disclosure while others ask for password-protected CD-ROMs, he said.
In another example, member states can demand the full health warning on e-liquid and e-cigarette packaging: “This product contains nicotine which is a highly addictive substance. It is not recommended for use by non-smokers.” A simpler version is also allowed: “This product contains nicotine which is a highly addictive substance.”
The TPD also demands that companies include a leaflet with instructions for use and storage of the product, warnings against use by young people and non-smokers, and contra-indications for specif ic risk groups such as pregnant women. Information on the product’s addictiveness, toxicity, potential adverse effects as well as contact details for the manufacturer or importer is also necessary.
E-liquid bottles must list all ingredients in descending order as well as indicate the exact nicotine concentration. Nicotine levels are restricted to 2 percent or 20 milligrams per milliliter.
Bottles and containers containing nicotine e-liquids must be child- and tamper-proof.
Plus, the TPD restricts the size of e-liquid bottles and tanks; bottles may not be larger than 10 ml and the device chamber size, including coils, may not exceed 2 ml.
“This, again, is counterintuitive,” Burton said. “Vapers, and especially those who desire higher nicotine concentrations, will have to carry around more liquid with them.”
Gaining Favor with Flavor Companies
Perhaps the greatest burden on e-liquid manufacturers is that the TPD demands they provide detailed specifications on each flavor and flavor ingredient.
A technical file, which includes a list of all ingredients, is much like a medical device file, Moore explained. The final dossier would include a toxicology assessment and emissions test on each SKU and ingredient along with the artwork, instructions for use and disclosure requirements for each member state.
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Moore said they’re doing preliminary emissions testing to see which flavors may be of most interest to regulators. “Some flavors such as cinnamon and licorice contain aldehyde molecules have raised some concerns,” he said.
The biggest hurdle may not be the time or money to complete this dossier, Moore said. The main sticking point could be with flavor companies that may be reluctant to divulge their flavor ingredients because they’re literally their secret sauce.
Moore said Chemular is working with flavor shops to create a third-party repository process where flavor shops submit detailed flavor compounds under a very strict non-disclosure.
Since it’s likely that the FDA will be on the same regulatory trail, Chemular is working to gain the confidence of flavor manufacturers to give up this proprietary information. “If the flavor facilities won’t divulge molecular information on their flavor compounds, they’re simply not going to survive in the newly regulated environment,” Moore said.
Getting Ready for REACH
Finally, the TPD will also require e-liquid companies to use REACH-registered chemicals. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a program initiated by the European Chemicals Agency to ensure the safety of major ingredients used in consumer products.
Going beyond U.S. Pharmacopeia (USP) and European Pharmacopoeia (EP) standards, REACH will apply to nicotine, propylene glycol (PG), and vegetable glycerin (VG). As of this writing, only two nicotine manufacturers meet REACH standards – CNT and Nicobrand, Europe’s oldest producer of nicotine.
While not enforced until 2018, the TPD will require that these chemicals meet REACH standards. So every manufacturer not using REACH-approved nicotine, PG and VG will eventually have to reformulate their flavors and then resubmit files to the TPD.
The original “Vaping VampTM,” Maria Verven is a 35- year P.R. veteran and owner of Verve P.R, a marketing firm focused on the vape industry.
For a variety of reasons, vaping has a particularly negative image with the non-vaping public. Let’s examine the five main reasons why, and what we, as a community, can do to rehabilitate that image.
Negative Media Coverage
It isn’t surprising that the general public has such a negative perception of vaping, given the frequent media coverage devoted to only the most unfavorable news and shoddy journalism. Every day there are negative articles devoted to vaping with sensational or misleading titles. I saw this article today, titled “E-cigarette Use Increasing Among Teens”. Why title it that way? Wouldn’t something like “Cigarette Use Plummets Among Teens” have been more accurate, since that is the direct effect of teens using e-cigarettes? Another example from this week’s news is an article entitled “Parents Get the Low Down on Substance Abuse,” announcing an upcoming presentation titled “Not My Kid: What’s Really Happening with Marijuana, Binge Drinking and E-Cigarettes in Wilton.” Equating the use of e-cigarettes with binge drinking and marijuana, and classifying e-cigarette users as substance abusers is ridiculous. For crying out loud, cigarettes are NOT part of the topic, but e-cigarettes are? I call bullshit.
The media coverage of vaping is so toxic it was even noted in an article written by Sally Satel, M.D., a resident scholar at the American Enterprise Institute — who is completely independent from the e-cigarette industry. Her article, “What’s Driving the War on E-Cigarettes?,” concludes that the fault lies with the Center for Disease Control (CDC). She argues the CDC should be embracing vaping but instead are taking the so-called “precautionist” approach; giving disproportionate weight to speculative evidence and minimizing the potential benefits. The CDC’s position on vaping directly affects and encourages the rampant negative media attention. As Dr. Satel noted in her article, this position harms smokers who have been unable to quit by other means, it is bad for the integrity of the field of public health, and will ultimately harm the CDC’s credibility as it is a major violation of the public trust.
Association With Traditional Cigarettes
This reason irritates me, because it is the ultimate illustration of the old adage “don’t judge a book by its cover.” That is exactly what the public does when it comes to vaping: it looks like smoking, so they react accordingly. When someone is vaping, there are clouds of vapor expelled that resemble smoke. The nonsmoking public is so conditioned to hate cigarette smoking that the knee-jerk reaction is to hate vaping as well — often just as much as they hate smoking. When combined with the public’s lack of factual knowledge of vaping (thanks again, mainstream media,) the result is basically a presumption against vaping as a viable alternative to smoking. I like to call this the “mom factor” – your mom just doesn’t want
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to see anything that resembles a cloud of smoke, no matter what you kids are calling it these days!
The public sees vaping as far too similar to smoking, and media coverage is too often skewed to the most horrible things that ever happen in the vaping world. Exploding batteries are an ever-popular topic, because the idea of your face or genitals being blown off by a vape battery is disturbing. While extremely problematic, this issue is far more rare than the public would believe, is most often the result of improper use, and is no more prevalent than it is in other types of technology that use lithium-ion batteries — such as cell phones.
Outside of the immediate risk of a mod catching fire or being injured by explosion, there is no end to the news coverage of popcorn lung, diacetyl, anti-freeze, and random chemicals found in batches of e-juice. Another popular story angle is the one of children being poisoned from drinking liquid nicotine. There are concerns related to expelled vapor, even though studies have shown it is no more harmful than air. Then come the concerns related to whether there is formaldehyde in liquids. There is no end to the amount of health concerns people seem to have about e-cigarettes.
Common Industry Marketing Tactics can alienate average or new vapers
Sorry vape family, but some of the marketing tactics used in our arena are distasteful. If you have ever been to a vape convention, it is basically where Hooters waitresses go to die. Some strong connections have been made between vaping and a solely masculine subculture that is all about naked ladies and blowing sick clouds. This takes vaping firmly outside of what the mainstream is interested in. The second group the public associates with vaping are trendy “hipsters” — an association firmly rooted in images of people like Paris Hilton and Kylie Jenner vaping. One often hears the word “douchey” tossed around in description of the type of people who vape (don’t shoot the messenger, I’m just delivering the news). Outsiders who look at a vaping magazine or wander into a vape shop do not feel that they are part of the world that is being advertised; this is especially true for older females who may want to give vaping a try and are confronted with e-liquids with names like Monkey Jizz or Zombie Puss.
Lack of Support From Any Major Group in the Non- Vaping World
As already mentioned, the CDC is firmly against vaping as a means of quitting smoking. So is the American Lung Association, the American Cancer Society, and the majority of the public health field. Add the majority of Congress and legislators across the United States to the groups not on our side and we are left with a pretty sad little group of supporters, which basically consists of people who vape, Leonardo DiCaprio, those in the vaping business, Grover Norquist, and Representative Duncan Hunter from California. And don’t forget Kylie Jenner.
How Can We Rehabilitate the Public Vaping Image?
Lest you thought I was only here to point out how bad things are for vapers in the current climate, I do have a few ideas on how to fix our image. I have one quick idea for each of the five areas discussed above, which, if implemented, would go a long way towards giving our industry the public perception makeover it desperately needs.
First, respond to negative media coverage with positive media coverage. Vapers are always active in the comments section of anti-vaping articles, and should continue to be so, but in a respectful and informed way so that anyone reading it might actually learn something. The more of us that write positive articles about vaping, high-
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lighting positive research and the correlation between the rise in the use of e-cigarettes to the historical plummet in the use of traditional cigarettes, while al- ways emphasizing the scientific study which illustrates that vaping is 95 percent safer than smoking, the more the public is presented with alternate viewpoints. The public cannot understand the whole truth about vaping and have an informed opinion unless we do everything possible to share what we know.
Second, stop blowing your huge vape clouds everywhere. As much as I love vaping and want to protect my right to vape, I want to protect the rights of the rest of the world to quit smoking through vaping as well. To do this, it is helpful to try not to be an asshole. And people just don’t want to see you blowing huge clouds out of your 200 watt mech mod in the middle of a restaurant while they are eating lunch. Or on an airplane. Or in the mall, at movie theaters, in line at Target, or anywhere else they are indoors. It is very easy to adjust your vaping habits to not annoy the whole world. Discretion is a virtue; try it out.
Third, the vaping community must continue to put forth a harm reduction philosophy to compete against the “precautionist” model which currently governs. Our stance must be firm that vaping should be embraced as the premier means of smoking cessation, and anyone concerned about possible health ramifications should be devoted to minimizing those harms, instead of exaggerating them. Since we all know vaping is 95 percent safer than smoking, all health concerns must be reviewed in that context. What do I mean by that? If you are addressing people worried about the diacetyl in e-cigarettes and its potential to cause “popcorn lung”, after making sure the person or group you are engaging is aware there is 750% more diacetyl in a cigarette than in an e-cigarette according to a Harvard study, change the focus to the vast number of diacetyl-free liquids available. You don’t fix a sprained ankle by cutting off the head of the injured patient; we should respond to the actual nature of the “threat,” and encourage others to do the same.
Fourth, we need to change our marketing tactics. The data shows that women are more likely to try e-cigarettes than men are in an attempt to quit smoking. If anything, get Channing Tatum and his group from Magic Mike on some advertisements! I’m kidding, and actually we must entirely reframe the lens through which e-cigarettes are viewed publicly. Of course they are used recreationally, but they are the most successful smoking cessation device known to mankind; THAT is how they should be advertised and marketed. No deaths have been attributed to vaping, something that cannot be said of other FDA approved forms of nicotine replacement therapy, like Chantix. These are the truths we need to hammer home, and change the view of vaping from nothing more than a recreational drug to a serious and safe means of smoking cessation.
Finally, we must find support outside the vaping community. As compelling as Leonardo DiCaprio and Julia Louis-Dreyfus may be, we need more people like them. We need disinterested (non-vaping) members of the public health community, the government, and the media to help change the image of vaping, and give it the legitimacy it deserves. We need smart, disinterested people like Dr. Satel to tell it like it is, and present the entire truth about vaping, and its usefulness in the fight against smoking. We need members of the general public to embrace vaping the same way they embrace lozenges, patches and pills as useful tools that help people quit smoking. Until then, Keep Calm and Vape On.
Most state legislatures have been in session for over a month now. In that short period of time, CASAA has identified multiple legislative threats to vaping and issued over 30 calls to action. Typically, the response rate to our calls to action is noticeably higher than some organizations see with other issues. Certainly this speaks to the passion that consumers have for vapor products and the level to which we are willing to be engaged. However, despite all of the opportunities that consumers have to be involved, some people are still hungry for more ways to participate.
CASAA has attended several events already in 2016, and at each one, we were approached by people that want to know what more they can do; they simply aren’t satisfied with firing off an email or making a phone call to a lawmaker. The good news is there are absolutely more ways to get involved.
First, Register To Vote! There are an estimated ten million vapor consumers in the United States (at the time of this writing, CASAA is close to counting 134,000 of them as members). Although most of the vapor consumers in the US are people that purchase or have purchased the cig-a-like or basic “ego” style devices from a C-store or gas station, there are still millions of consumers that purchase and use advanced devices from small specialty shops. Just imagine the voting power we would have if just that group of advanced users were registered to vote and actually voted. Yes, we are talking about determining the outcome of a federal election. Moreover, when you communicate with lawmakers, it is vitally important that you mention that you are a voter in their district. While it’s true that good ideas and passionate policy discussion come from nonvoters to a lawmaker, the prospects of losing or gaining a vote in the next election carries more weight.
Second, when you make a call or send written communications to lawmakers, it is a great idea to take that opportunity to request an in-person meeting. It may take a while to set up the meeting and you may only end up speaking with a staff member, but any inperson meeting with a lawmaker or their staff sends a powerful message that you are serious about this issue. Once you’ve scheduled your meeting, take a moment to reach out to any of the organizations that have been doing this for a while. Someone there will be more than happy to share their experience and help prepare you for your meeting.
Third, the aforementioned 10 million vapor consumers in the US need to know how to get involved. Maybe more importantly, they need to know that they should get involved. There are still hundreds of vapor retailers that don’t know about the regulatory threats to their businesses. Unfortunately, their customers are likely in the dark as well. As consumers, you have the power to influence retailers with your spending habits. Shop in stores that promote awareness and advocacy. If you are limited to just one or a few shops and they seem unaware of the issues, take a moment to recommend some materials they can post in their store. CASAA has things that can be downloaded and printed out for free (bit.ly/casaamaterials). You can also find flyers that are tailored to specific states or issues here: bit.ly/casaaflyers.
Finally, sharing calls to action and other bits of information is vitally important to getting the word out and are often overlooked as ways to get more involved. Some may naturally assume that information coming from a large organization is seen by many more people\ than one person can hope to reach. Unfortunately, this is not the case. I’ll refer back to the 9.8 million vapor consumers in the US that are seemingly unaware of the threats to their access to vapor products. The reality is that you have social and business networks that advocacy organizations are unable to reach on their own. Manufacturers and online retailers, especially, have large email lists that consist of vendors and consumers alike. While CASAA can send out one alert here and there to specific audiences, our message tends to get buried in all of the other exciting stuff happening in the vapor universe. It is vital that everyone who interacts with these products sees multiple reminders to take action or to generally be aware of the issues.
It may seem like “doing more” requires some kind of heroic effort. However, it’s the little things that add up and can have a significant impact. Rather than strive for grand gestures intended to jump start a revolution, consistent and simple actions are what sustain a movement.
Until now, many vapers have been happily vaping away, without much concern over the contents of their E-Liquids. After all, E-Liquid is made from simple, safe, household ingredients — it’s gotta be better than the 7,000+ chemicals in cigarettes, right? As long as the juice is made in a clean fashion — there isn’t much to worry about.
But then diacetyl reared its ugly head. Although knowledge of the chemical is not new in vaping circles, after all, informed vapers know that electronic cigarette researcher Dr. Konstantinos Farsalinos warned us about the chemical back in 2014, with a study published in the journal Nicotine and Tobacco Research. The study recommended then that diacetyl and acetyl propionyl (AP) be removed from E-Liquids, as they are an avoidable risk. The diacetyl story broke to the public in December 2015 when a study was published in Environmental Health Perspectives, by researchers from the Harvard T.H. Chan School of Public Health that revealed the chemical’s presence was in up to 75 percent of vapor liquids.
But, why the concern? What potential harm can diacetyl cause? Diacetyl, when inhaled, can cause bronchiolitis obliterans, popularly known as popcorn lung. Inhalations of high concentrations of diacetyl can cause obstructive lung disease, which can be very severe. With popcorn lung, the bronchioles of the lung become scarred and constricted, blocking the movement of air.
This was bad news for vapers who were turning to e-cigarettes as a way to reduce harm from cigarette smoking. If vapor liquids contained ingredients that would damage the lungs as well, then why not just smoke?
A Daily Caller article then responded, pointing out important facts that had not been discussed by the Harvard report, and charging the study with selectively revealing information about diacetyl content in other substances — namely, tobacco cigarettes. Dr. Farsalinos has argued that cigarette tobacco also contains high levels of diacetyl — even higher than those found in most vapor liquids. He presented data showing tobacco to have much higher levels of diacetyl — on average 110 times higher compared to the E-Liquid samples he tested. Additionally, he observed that the threshold for the diacetyl content in the Harvard study was very low — inhaling levels of diacetyl this low were unlikely to contribute to popcorn lung. Cigarettes have not been linked to the disease, and if cigarettes contain higher levels of diacetyl than e-cigs, than how can we reasonably conclude that E-Liquids cause the disease?
Even so, the vape industry had to respond. If harm reduction is truly the game here, when faced with this news, manufacturers had to act. E-Liquid producers then turned to their flavoring suppliers with questions. Some suppliers claim directly on their website that diacetyl is not added to any of their flavorings. Others have gone even farther to remove other questionable chemicals AP and acetoin from their formulations.
How can E-Liquid companies handle the diacetyl question? Some companies try their best to have no trace of diacetyl or other known harmful chemicals in the juices. Their juices are tested by third-party laboratories and the test results are often proudly posted on the company website. Other companies
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have chosen to be transparent — acknowledging that the liquids may have some concentrations of diacetyl, AP, or acetoin — and that there is some risk taken by the consumer. Those warnings acknowledge the link between diacetyl and lung disease, while also noting that no adequate testing has been done on diacetyl in electronic cigarettes. After all, it has been pointed out that the workers who developed popcorn lung were breathing in high concentrations of pure flavorings at extremely high temps, and also that the levels of diacetyl in electronic cigarettes were less than diacetyl levels in tobacco cigarettes. Other companies have not said much either way — and still others have been accused of misleading their customers.
What is the best policy for E-Liquid manufacturers? As Dr. Farsalinos has argued, transparency by the juice companies and removal of the chemicals are the only two viable ways to move forward. When companies hedge or refuse to answer tough questions about their E-Liquids, they seem uninformed at best and deceptive at worst. And of course, falsifying test results or making false claims is a completely unacceptable practice.
How do vapers move on from diacetyl? Vapers should ask for test results as well as informing themselves of the risks associated with the product. But since vapers are moving away from the clearly toxic habit of smoking to a clearly less harmful habit of vaping — which no one has claimed to be totally safe, the risks associated with diacetyl seem minimal. Especially since an informed vaper can easily avoid it by choosing diacetyl free liquids. In the future, more extensive testing of E-Liquids and flavorings will be the norm. As electronic cigarettes continue to be studied, we hope that they will be studied in a way that is fair and balanced, not in a way that aims to stifle the technology.
By and large, vapers are health conscious individuals. Many of them chose vaping in the first place as a way to move towards a healthy lifestyle. As research identifies the E-Liquid flavors that have the least health risks, and companies adapt to the changes, vaping will continue to be a good choice from smokers looking to quit combustible tobacco.
From its humble beginnings in 2009 to today, ProVape and its ProVari line of products have come a long way, baby. Manufactured in the U.S. and sold in over 68 countries, ProVari has grown into a top-rated personal vaporizer thanks to its dependability, durability, safety and performance – not to mention thousands of raving fans.
“ProVari has a huge fan base,” said Phil Busardo, a popular reviewer. “If you were to post something negative, fans sense something negative and will come and vigorously defend it.”
In other words, ProVari is blowing away the competition.
David Flagg, ProVape CEO and a full-time vaper who hasn’t had a cigarette since he switched to vaping in 2009, said he and his business partner Phillip Schuessler weren’t happy with most Chinese devices due to their poor performance, lack of quality control and safety.
“When we first got into the market, we saw a lot of poorly designed products,” Flagg said. “So we set out to improve on those designs. We didn’t just want to make a premium device; we also wanted to keep manufacturing here in the U.S. to support American workers.”
Flagg said everything – from engineering designs to circuit boards to the metal work on all ProVari products – is made in Monroe, Wash., a small town about 45 minutes east of Seattle. Since the release of the ProVari 1 in 2010, ProV ape has released several different models, including the ProVari 2, 2.5 and 3, the ProVari Classic and the ergonomically designed ProVari Radius, launched last October.
Starting with only four staffers in a 6,000 square foot facility, ProVape has grown to over 40 employees working out of a 24,000 square foot facility. “It’s nice having all the extra space,” Flagg said. “Having departments instead of everyone crammed into a small area really helps us be more organized.”
From Word of Mouth to Top Google Ranking
In the early days, there was very little marketing to speak of; word of mouth from customers was their only advertising. Even so, thanks to great reviews, sales were going well.
In 2013, they hired Eventige, a full-service marketing agency, to update the website. “Our focus had to be on building and testing products and shipping orders,” Flagg said. “We looked around at several agencies, but connected with the Eventige team and their vision.”
Eventige lists dozens of clients, including Blue Cross Blue Shield, the Ford Foundation, Habitat for Humanity, Hilton Worldwide, Marriott, Microsoft, Skype, Uber and The Wall Street Journal. Their client list also includes Logic and Ecig Caddy. Alexei Alankin, CEO and founder, is a vaper and passionate about the industry. Eventige was a key sponsor at SFATA’s annual meeting last year.
Alankin and the Eventige team came up with several suggestions and marketing ideas, eventually honing their strategy and focusing on new product launches. They started by creating a unique look and feel for every ProVape product page on the website. As the relationship with ProVape grew, so did their engagement until eventually Eventige assumed responsibility for all of ProVape’s social media, website and marketing.
Eventige created and implemented a global brand strategy that aligned all brand marketing activities into a cohesive and milestone driven roadmap. The goal was to increase brand awareness and global sales to smokers as well as current vapers.
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and then created the materials needed to reach the mass market,” Alankin said. “Our experience in e-commerce and online positioning helped us navigate this difficult terrain and find unique ways to propel the ProVape message forward.”
Alankin said they boosted online sales by focusing on inbound lead strategies that elevated ProVape’s organic ranking in Google searches. After implementing both on- and off-page proven SEO (search engine optimization) strategies, they then improved the website load speeds and user interface design and optimized the website conversion rate, turning more visitors into buyers and eventually fans.
Thanks to these efforts, ProVape increased its search traffic by a whopping 1,600 percent. ProVape.com continues to hold the number one position on Google and other search engines for several important keyword searches used by people seeking high quality vaping devices. This is a critical strategy, since any business selling vape products cannot use Google AdWords or paid acquisition strategies to generate website traffic.
Quadrupling the Fan Base
Eventige also developed loyalty programs, online contests and social media aggregate platforms to strengthen public opinion, increase sharing and optimize opportunities for the ProVari brand to build a following in the vape community.
On the #VapeProVari fan board, they delivered a daily influx of user-generated content that continues to drive engagement and attraction. This helped quadruple the number of social media fans in a very short period of time. For example, in one campaign, they sent ‘Zombies’ roaming the virtual streets via digital media to promote the Zombie version of the ProVari. This unique design of the classic unit features a coating that looks like blood spatter, and the design was a hit with fans all around the world.
When ProVape got ready to roll out its new ProVari 3, Eventige created custom packaging that emulated the brand’s sleek, elegant, modern look. They also created a campaign to promote the lighter, titanium version of the P3, which weighs 2.1 oz. vs. the 3.8 oz. stainless steel version. Advertisements promoting the Titanium P3’s unique selling features show the ProVari 3 balancing on a fulcrum with a feather.
Retail distribution hit over 900 dealers worldwide with USB keys and loyalty cards included in their point of display promotional packages. Articles have also appeared in major print media such as Reuters, Forbes, and the Daily Caller as well as vape publications VAPE News and Vapor Voice.
Today, ProVape continues to experience aggressive growth rates; even celebrities like Katherine Heigl are using a ProVari device. The partnership between ProVape and Eventige is also as strong as ever.
“Four years ago when I started vaping, I was looking for that perfect product,” Alankin said. “Ever since I met David (Flagg), the ProVari was it for me. Over the years, I upgraded whenever a new model came out. I’ve also helped many friends and family make the switch.”
Meanwhile, Alankin is always experimenting with ways to drive new customers to the ProVari brand. “It’s very much a rotating platter when it comes to what to try next,” he said. “We’re always trying to see what gets the most attention.”
The original “Vaping VampTM,” Maria Verven is a 35-year P.R. veteran and owner of Verve P.R, a marketing firm focused on the vape industry.
Where do we stand at federal level with vaping products regulation? As of the end of February, the proposed Food and Drug Administration (FDA) deeming vaping products (and other products) tobacco products appears to still be with the Office of Management and Budget of the White House. In fact, as late as mid-February, the Office of Management and Budget took additional meetings with interested parties, specifically with senators, on the so-called deeming rule.
However, in response to general concerns regarding accessibility of nicotine-containing liquids by unintended individuals, on Jan. 13, Congress passed the Child Nicotine Poisoning Prevention Act of 2015, which was then sent to the President of the United States and was signed into law on January 28, 2016.
The Child Nicotine Poisoning Prevention Act gives the Consumer Product Safety Commission (CPSC) jurisdiction over anyone selling a “liquid nicotine container” in or into the U.S. and controls the packaging of such containers under the Poison Prevention Packaging Act. The act requires any nicotine, which is offered for sale in liquid nicotine containers, to be packaged in accordance with the CPSC’s standards and to pass testing in accordance with the method described below.
Liquid nicotine container is defined as “a package […] (i) from which nicotine in a solution or other form is accessible through normal and foreseeable use by a consumer; and (ii) that is used to hold soluble nicotine in any concentration, but it does not include 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.“ In lay terms, cigalikes and sealed refill cartridges need not meet the child-safe packaging requirement.
The Child Nicotine Poisoning Prevention Act does not preempt the Food and Drug Administration’s future authority over vaping products or other nicotine containing products packaging. The act, however, mandates that the Food and Drug Administration consult with the CPSC if the FDA “adopts, maintains, enforces, or imposes or continues in effect any packaging requirement for liquid nicotine containers, including a child-resistant packaging requirement […] taking into consideration the expertise of the Commission in implementing and enforcing this Act and the Poison Prevention Packaging Act of 1970 (15 U.S.C. 1471 et seq.).” One could wonder – is this recent law
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in fact contemplating an erosion of the Food and Drug Administration’s authority over the packaging of vaping products?
An important consequence of this lawpre-empting requirements in place by state and local authorities. The Child Nicotine Poisoning Prevention Act does not specifically address the preemption issue, however it is well established that CPSC regulation will preempt state and local requirements applicable to the same product. Thus, the Poison Prevention Packaging Act specifically preempts state and local standards on child resistant packaging that are not identical to the Consumer Product Safety Commission standard. The broader issue of state and local preemption with respect to vaping products is addressed in the Family Smoking Prevention and Tobacco Control Act of 2009. Certain state laws adopted to date with respect to vaping products manufacturing or specifications will become inapplicable if vaping products are deemed tobacco products. One could argue that states had affirmative knowledge of such future FDA regulation since the 2010 Sottera decision and should not have gone through the trouble of regulating the manufacture or labeling of vaping products, among other things, as this will fall under the FDA’s jurisdiction.
In conclusion, the Child Nicotine Poisoning Prevention Act is now the governing federal statute with respect to child resistant packaging for vaping products as defined and limited in the act itself. Manufacturers have 180 days to comply with the act, meaning until July 25, 2016. Since compliance may require the replacement of some existing containers that do not meet the CPSC’s standards, manufacturers should take steps to meet these requirements soon.
Child Nicotine Poisoning Prevention Act of 2015 full text: https://www.govtrack.us/congress/bills/114/s142/text
To say I solved vaping might be a tiny-bit of an exaggeration. In a perfect world, where vaping is embraced as the premier method of smoking cessation, and the mutual societal goal is to make it even better and even safer than it already is, there are very few federal rules and regulations that would be necessary to properly regulate the industry. Understanding vaping is 95% safer than smoking and is the cause of the unprecedented decline in the smoking rate occurring in the United States and worldwide, the following regulations would be more than sufficient to help people who want to quit smoking by vaping.
Some restrictive regulations are inevitable, and I am one of the vapers who would be ok with moderate regulations aimed at avoiding or limiting the most dangerous vapingrelated situations. This includes:
Requiring the caps on e-liquid bottles to be childproof. This is a no-brainer and I cannot fathom any argument against it.
Require e-liquid bottles to display the ingredients and carry a nicotine warning label. It is dangerous to ingest liquid nicotine, and people should know that, especially so they keep their e-liquids away from children and pets. People should also have access to the ingredient list for any e-juice they are thinking of purchasing, so an informed decision can be made of what products to purchase.
Ban the use of Diacetyl in e-liquids. Do I think anyone is going to vape enough diacetyl containing e-liquid to contract “popcorn lung”? No, I don’t. However, diacetyl is a carcinogen, and there is absolutely no need to ingest it. I know this might upset some vapers, but there are so many choices; why vape something that could lead to a deadly disease when it’s not necessary. I feel the same about formaldehyde and any other carcinogens or additives that cause additional health risks.
Do something to regulate the batteries used in mechanical mods, box mods, and electronic cigarettes to minimize explosions. We cannot regulate away user error, but we can implement some reasonable standards that will ensure only high quality batteries that have been quality checked are used in devices sold to the vaping public.
Establish a reasonable review process for new products. Perhaps the federal government could work with an organization like AEMSA to help all of the current e-liquid makers and future e-liquid manufacturers adhere to a set of standards and obtain certification. This should be done with an eye to preserving small business and helping those whose products do not meet the standards get into compliance.
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I also believe there should be positive, pro-vaping regulation. Given the research to date both on the comparative safety of e-cigarettes to traditional cigarettes, and the unprecedented success people have seen by using vaping as a smoking cessation device, it might be appropriate to include federal legislation such as:
Taking the regulation of e-cigarettes out of the tobacco realm and into the same regulatory realm as other smoking cessation devices. This is something the pharmaceutical lobby will resist, a lobby that is hostile to the e-cigarette industry as a whole. The New York times reported last year that the makers of Nicorette gum, GlaxoSmithKline, and the manufacturers of nicotine patches, Johnson & Johnson, lead the strong opposition against e-cigarettes. The evidence, however, supports this, and the public health community and our elected officials need to be on the side of the people, not the side of the lobbyists.
Set a federal safety standard that, if met, allows insurance coverage for e-cigarettes to assist those who wish to quit smoking. This is the law in Great Britain as of January 2016, and it is the strongest way government can help people who have been unsuccessful in the past to quit smoking.
Fund a system devoted to the funding of research to increase vaping safety, instead of funding studies looking for ghosts to debunk it as a means of smoking cessation. Imagine what we could do if we actually had grants available to make e-liquids and hardware safer.
There You Have It
That’s it. Leave other rules to the states, who should be instructed (and have federal funding tied to) legislating e-cigarettes in a manner consistent with what they actually are: a legitimate nicotine replacement therapy option and the preferred method of smoking cessation for people who have failed in the past.
Yes, it will be annoying if your state or municipality rules that you cannot vape inside of your favorite restaurant, but once there is a federal regulation declaring vapor products separate from tobacco, restaurants will have a strong argument that they should have the option of including a vaping section if they wish. More importantly, if federal health policy on vaping is made around the concept that vaping is the most effective technology yet introduced in the war against smoking, instead of treating it like a tobacco product, then the states will take the cue and make regulations accordingly.
Before any of these common sense rules and regulations can come to fruition, the conversation needs a fundamental change. Instead of electronic cigarettes being considered counter-culture addictions like regular cigarettes, vaping advocacy must focus on changing the public perception of vaping. The public has to be made to understand how much safer vaping is than smoking, and how much more effective it is in helping potential quitters than any other smoking cessation device available to the smoking population. When we get there, we can easily solve the issues surrounding vaping regulation, and make everybody happy. Until that day comes, Keep Calm and Vape On.
In 1982, first-time-writer John Naisbitt penned the book “Megatrends.” Little did he know, it paints a microcosm of the vape industry’s deep roots in Florida.
Megatrends discusses societal changes within the country and said that “The most reliable way to anticipate the future is by understanding the present.” He called himself a “social forecaster.” Fifteen years earlier, Naisbitt worked at the White House under President Lyndon Johnson and was tasked with gathering similar intelligence for the staffers.
He and his team of two dozen analysts dissected 200 daily newspapers from all over the United States and looked for signs or indicators of what was to come. This was the core of Megatrends. Today, there are online tools that do the same thing, but 35 years ago this was innovative and tedious work.
His studies revealed that many new trends in the US comes from just a few states which he called “bellwether states.” Among those were California and Florida. When it comes to innovation and leadership in the vape space these two states stand out more than most others. California, which is considered “Ground Zero” for vaping and where many things start, is an obvious choice. But “Why Florida?”
The Significance of Florida
Florida pulls lots of money and talent from the colder Northeast area which accounts for lots of demographic immigration. The huge influx of senior citizens, retirees and snowbirds that escape the colder climes do the same. Since Megatrends came out there has also been a big increase in South American and Hispanic influence, especially in Miami and the surrounding Dade and Broward counties. Also since that time, the election debacle of 2000 has made Florida and Floridians noteworthy for the wrong reasons. For those that may not remember, the presidential election of 2000 was a virtual tie until the “chad” hit the fan in Florida. Were it not for a few winds blowing the other direction, we may have had President Al Gore instead of President George W. Bush in office. I recently spoke with Rich Peirce, Digital Marketing manager and T.D. Bowen,
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owner, from Moon Mountain Vapor, in Tampa, and asked the pivotal question: why Florida?
“Florida is prevalent in retail, e-liquid companies and corporate locations because of the diverse culture of people from all over the country,” they replied. “Florida is a melting pot with fewmulti-generational natives here. Most are first generation born Americans or Floridians.
“They all seem to bring ideas and ways of thinking from other areas. Since there are no state income taxes in Florida, it also appeals to those that want to avoid that expense.”
As in California, there are a select few significant areas of actively: Broward and Dade counties, which cover Miami and the surrounding areas; Hillsborough and Pinellas counties, which surround Tampa to the north, and Orange county, which is dead center and includes Orlando.
The Tampa area appeals to many displaced middle class Americans, whereas Miami and the southern cities have a huge percentage of South Americans, Cubans, and immigrants from Puerto Rico, the Dominican Republic and Haiti. According the Moon Mountain, “Florida is the largest vaping state in the eastern United States.” As a consultant, I echo that opinion as Florida is the number one state for VapeMentors clients, surpassing even California. Many recognizable name brands originate in Florida, including Halo, V2, South Beach Smoke, VaporFi, and Vapor Shark.
I caught up with Brandon Leidel, CEO of Miami based Vapor Shark, and one of the bigger players in the business and asked his thoughts. Since starting in 2010, Vapor Shark has grown to 37 locations, including one in Shanghai and Guatemala. They include both corporate shops as well as franchises, but have the largest retail presence of anyone in the state.
Leidel brought up an interesting statistic about Florida. Florida has a very high number of alcohol treatment centers and former alcoholics. Many of them are also reformed smokers and have become vapers.
Florida is a leader in advocacy, with their own state association, the Florida Smoke Free Association, FSFA, which was established in 2014. Bowen was one of the founders and continues to be actively involved.
Norm Bour is the founder of VapeMentors, which offers online educational programs, services & resources for anyone in the vape space, including vape shops, online stores and e-liquid brands. He’s also host of Vape Radio, a podcast series that interviews the masters of vape and thought leaders in the vape space. Contact him at norm@VapeMentors.com.
Do you enjoy selecting e-liquid at a fair price from your local vape shop? Do you like supporting your neighborhood brick and mortar by rewarding their convenience with your money? Is there a favorite employee who has walked you through tough vaping issues or made an effort to understand your personal story? If you happen to be one of Chicago’s 2.7 million residents, then that’s too bad.
As Clayton Guse so eloquently put it in his article for Time Out Chicago, “This isn’t the first time [Chicago] has cracked down on vaping. In April 2014, e-cigarettes were officially banned in most public places in Chicago, much to the chagrin of the jerks who vaped inside bars and restaurants. The city forced them to go outside with the rest of the smokers, and the new tax will force them to pay up just like cigarette smokers.” I am still a big advocate for respectful vaping in public, but since my devices have been able to produce large visible clouds I have seriously reconsidered my definition of respectful. I still think the message can be spread anywhere smoking is acceptable, even in some instances where the law is broken, but no one is harmed.
I vape while waiting on the L (Chicago’s elevated transit system, operated under Chicago Transit Authority, or CTA), as long as no one else is near enough to be bothered. I actually didn’t do that when I first moved to the area in January 2015, because I was accustomed to the subway system in Manhattan (where they don’t screw around). That changed recently when a few friendly CTA employees let me know that they
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didn’t mind at all. They even assured me that no one would bother to give me a citation as long as I wasn’t disturbing others. So far this has proven true, but I remain cautious and careful.
Honestly, as much as they’d like to point fingers at indiscriminate cloud chuckers, I think the answer may end in zeros. “(…) the tax is expected to bring in some sweet, sweet cash to help plug the city’s colossal pension deficit (Chicago’s on the hook for $672 million payment to the police and fire pension funds next year),” Clayton continued in his Dec 2015 article for the Time Out Chicago (just before the tax law was made official).
Establishments outside the city of Chicago are off the hook for the tax, and some wording of the law does allow
for completely legal loopholes. According to cityofchicago.org “This is a tax on the retail sale of Liquid Nicotine Product in the City. The rate is $.80 per liquid nicotine product unit plus an additional $0.55 per fluid milliliter of consumable liquid, gel, or other solution contained in the product. Some taxable examples are “E-liquids, e-juice, and smoke juice containing nicotine”.
Not only did city shops in Chicago have to start charging an additional $.80 cents per bottle, they are now forced to add $.50 cents to every milliliter in that bottle that has any amount of nicotine in it. So, you end up paying an additional $15.80 in taxes per bottle of your favorite smoke juice.
Fortunately many establishments have been able to remain fair to their customers. At Cloud Vapor Lounge (a Chicago Gem off the Western Blue Line stop), Tom Fisher explained how he’s dealing with the crackdown. “If customers want to add nicotine to one of the hundreds of nicotine free e-liquids we carry, they can simply purchase that separately. We sell 1 milliliter nicotine solution packages and send them home with you in a child safe container, or you can take advantage of our ultrasonic mixer. The 1 mil will cost around four dollars, including the price of the nicotine pouch and the city taxes.”
The city of Chicago isn’t just spending all that tax money on worthy items like retirement funds for it’s loyal employees. An anti-vaping campaign, replete with billboards and buses to reduce the traffic to business like Fisher’s. Warnings in bold colors proclaim “Vaping: Why Risk It?” and “Vaping, liquid poison!” from nearly every corner of the city.
While discussing the city’s appropriation of funds toward this massive campaign at Cloud Vapor Lounge, Donna, a regular there, offered her opinion. “I think vaping is glamorous. Look I’ll show you” she said as she removed her phone and started scrolling through pictures. “I was married just last week”, a pause for congratulations, “and I insisted the photographer took this picture.” Donna hands me her phone and this beautiful image appears:
“Some of my family members thought I was a little crazy for wanting this picture, but the photographer totally got it.” she said. “Local businesses make the city of Chicago a home. It’s a place that people from all over the world travel to see what separates Chicago from the rest. Local business tax money supports all of Chicago’s functions from snow plowing to street paving to building parks like the 606 that draws people to want to make a home here. This is what separates us from the suburbs. Suburbs have chains in every strip mall. In Chicago, local businesses know their customers and form relationships and makes people want to stay in Chicago and spend their money, which in turn, supports our municipality.”
While many people aren’t rattled by the city’s scare tactics, some will fall prey to it’s baseless propaganda. Those people will most likely stick to what they know, cigarettes. And what does Chicago gain from this? Will the city find it’s missing $627 million by taxing the life out of local business and keeping smokers out in the cold?
I have the FUhattan mod and I was wondering what mod is better. I’m kind of new to this whole thing, but I’m just not satisfied with the performance of this. Any suggestions?
Hey There! I’ve never liked the term “better” or “best”. It’s kind of like asking “Hey, I have a Toyota Prius… what’s better?” I guess that depends what you want. For some people, a Toyota Prius is the “Best” and for others, not so much. No matter, without having to get a whole new mod, there are some things you can do to get the most out of the setup you currently have.
First things first, take your mod apart and clean EVERYTHING! Mech mods need some TLC from time to time to keep things working at optimum levels. Clean and polish the contacts. Clean the tube and clean the 510 connection. The next thing you can do is get high quality batteries. Higher quality batteries will have a higher amp limit, which will allow you to build lower resistance coils safely and get maximum performance from your coils. There are LOADS of brands out there making sometimes misleading claims on their amp limit and mAh. Track down some Samsung 25r batteries. They
are a very tried and true battery in the vape world.
The last thing is to build some good coils in that atomizer. The Samsung 25r battery has a pulse amp limit of 35A and a continuous amp limit of 20A, which means if you build a nice 0.2ohm coil in there. You will be good to go. Building coils just takes practice. When it all comes together you should have a nice, warm, flavorful and, above all, safe vape.
You guys know your stuff. I’m new to cloud chasing and still new to all the juices, etc. I’m running a KBOX, an Aspire Atlantis Mega along with a Cherry Bomber and drip tip, but I’m hunting for a good juice to vape with something fruit. Any pointers? Please guys.
Hey Jon! I absolutely agree with you. A good juice to vape is what makes the vaping experience so enjoyable. Because taste is so subjective it’s really hard to recommend a brand or flavor of juice. Some people want a bakery type flavor, others like fruity stuff, others like minty menthol juices. The absolute best advice I can give you is to visit a vape shop, and try the juice lines that they sell. Vape shops generally have an area set up for trying out new flavors and seeing what you like to vape.
If you don’t have access to a vape shop for the actual tasting of juices, then check on YouTube or different forums for people who have tried the juices you are interested in. Eliquid.com is a great site for checking out juices. You can find some you might be interested in, then search Google and YouTube for reviews of those juices.
Hope that helps out!
Natalie Norris Miles Help! I am a newby. Long story short, I went from a vape pen to an Eleaf 30w and Kangertech subtank, which sucked, then to the Aspire Triton subohm tank. I have been told I need 18-22 mg nicotine e-juice, then told 3mg, then 6, now 12. I was just informed my istick 30w is not suitable for the triton. My local shop did not say a word about the Triton not being a good match for the 30w iStick, but another shop did and said it could overheat. I feel like everyone just wants to sell me new gear. I am getting pissed off and ready to abandon the whole idea. Help me understand. I am, or was, a pack-a-day smoker. I am running the 25w-30w coil on the Triton rated at 0.4 ohms
Hey Natalie! Don’t lose hope. There seems to be a bit of confusion these days between store employees on what exactly they are telling the customers. As far as the juices goes, you should vape whatever satisfies you. The reason people drop their nicotine level when using tanks like the Triton is that most people find the higher nicotine juices irritating to their throat. The Triton is a “Sub-OHM” tank. Meaning the resistance is generally very low and will need a higher wattage in order to reach peak performance. In your situation running a 0.4ohm coil in the Triton, on the iStick 30w is a perfectly fine vape. If it’s working for you, then keep using it! Pick a nicotine level that satisfies you, and you are good to go.
In the future a good thing to remember is that lower resistance (OHMS) coils will need more wattage, and higher resistance coils will need lower wattage.