Why Black Note Discontinued Three N.E.T Vape Blends
As many of our fans and loyal customers know, Black Note has had to discontinue three of their vaping liquids. As of Oct. 25, the three blends of Adagio, Bravura and Cadenza shall be gone with the wind – no longer available on our website and no longer in production.
The reason behind the discontinuation was not because we were bored with the names or tired of the flavors. It was because we simply can’t continue to produce the full lineup of products we had been producing under the new FDA deeming regulations. It’s just too costly, too arduous, and too much of a total nightmare.
The new FDA deeming regulations, which were published in May and took effect in August, dictate all vaping liquids on the market adhere to strict guidelines. And we mean strict. The European Union pulled a similar stunt, passing rigorous vaping industry guidelines under its Tobacco Product Directive (TPD).
While existing products that are already on the market do have a grace period, giving manufacturers time to fill out and submit the tons of paperwork and fees that go with each application, we made the difficult decision to take these three blends off the market before the deadline.
The new regulations have the potential power to decimate the vaping industry as we know it, and we’ve already personally felt the impact with the discontinuation of Adagio, Bravura and Cadenza.
The cost of submitting a vaping liquid application to the FDA with all the required bells, whistles and studies is estimated at $300,000 to $1,300,000. Yikes is right. And an application has to be submitted for each and every vaping liquid flavor and nicotine level manufacturers intend to sell. That means the same flavor sold in two different nicotine levels would require two different applications, as each is considered a different product.
Fees and research costs are likewise associated with applications required to sell vaping liquid under the TPD, although a total overall cost estimate was not readily available.
If the application’s cost alone doesn’t make vaping liquid manufacturers faint, the other application requirements just might. You can check out the gritty details of what the regulations demand in our FDA infographic and TPD infographic. As a brief example, FDA regulations demand each application include things like:
Reports on the health risks
Full ingredient listings
Description of how the product works
Descriptions of the manufacturing process and facilities
Evidence the product meets tobacco standards
As noted, the list goes on. And on. Then goes on some more.
Combine the massive cost with the massive application process for each product on the market, and you already have a nightmare in the works. But that’s not all. Additional requirements include things like:
Showing “permitting this product to be marketed would be appropriate for the protection of the public health”
Submitting reports that touch on health issues such as toxicology as well as the behavioral and physiological effects of the products and their ingredients
Undergoing annual registration with the FDA
Sending the FDA a product listing and samples
Complying with new labeling standards that require specific health warnings and other precise information
The Bottom Line
While Black Note will comply with regulations to continue to keep our other blends on the market, we did have to pare down our offerings out of sheer necessity. We needed to keep our sanity. The more products we have, the more applications we have to submit, the larger fees we have to pay and the bigger headaches we have to endure.
So it is with sadness we bid adieu to the three blends of Adagio, Bravura and Cadenza. We do hope you enjoyed them while they lasted. And we do hope we don’t eventually have to say the same about the entire vaping industry.
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