CNPPA GCC Compliance

Posted by Mister E Liquid on 14th Jul 2016

To our valued wholesale customers,

As many of you may know, the Child Nicotine Poisoning Prevention Act of 2015 (CNPPA) was enacted by congress on January 28th, 2016. This act requires that all E-Liquid manufacturers comply with the child resistance requirements set forth in CFR 1700.15 and 1700.20. On July 26th 2016, all products shipped to our wholesale customers will require a General Certificate of Compliance (GCC). We suggest that you retain your documentation from these orders to prove that they were obtained before this date.

On or after July 26th, 2016, any e-liquid you purchase from outside manufacturers, including Mister-E-Liquid, should come with a GCC that states the products covered under the certificate (plastic or glass bottle, volume, composition, and dropper enclosure), applicable requirements (16 C.F.R. 1700 15, 16 C.F.R. 1700 20), Manufacturer/Importer of Record (Mister-E-Liquid), Custodian of Records, Date/Place of Manufacture, Date/Place of Testing, and Laboratory.

Mister-E-Liquid will be fully compliant and intends to begin providing these documents to you with all orders beginning July 25th, 2016. We assure you that the Mister-E-Liquid products you have purchased before July 26th are compliant with the CNPPA and are not subject to GCC inspection. We encourage you to maintain data on any orders you may have obtained before July 26th in case of inspection to prove that it was manufactured before this date.On or after July 26th, any manufacturer that supplies you with e-liquid should provide you with GCCs that are manufacturer and bottle type specific. We recommend that you maintain these records at least until you have sold through/no longer have the product on your shelf that was related to this order. It is imperative that you maintain accurate records as an inspector can and will request these records.

This letter is not intended as legal advice, but merely suggestive as to how to handle compliance with the CNPPA and how to manage GCCs. Again, we would like to remind you that GCCs are not required for any product manufactured before July 26th, and Mister-E-Liquid fully intends to comply with the CNPPA and will furnish GCCs with all orders by July 25th, 2016.

Thank you,

Mister-E-Liquid Customer Support