The California Department of Resources Recycling and Recovery (CalRecycle) is currently working on a rulemaking to implement SB 1215, which revised the state’s Covered Electronic Waste Recycling Program (E-Waste Recycling Program) to include covered battery-embedded products. These are generally products containing batteries that are “not designed to be easily removed from the product by

Azim Chowdhury
Azim Chowdhury is a regulatory and public policy attorney with a focus on vapor, nicotine and tobacco product regulation. He is a Partner in Keller and Heckman’s nationally-ranked food and drug law practice.
Mr. Chowdhury advises domestic and foreign corporations in matters of Food and Drug Administration (FDA) and international regulatory compliance. In particular, he has developed expertise in tobacco and vapor product regulation relating to the implementation of the Family Smoking Prevention and Tobacco Control Act, and spearheaded the Tobacco and E-Vapor practice at Keller and Heckman. Specifically, Mr. Chowdhury has experience representing tobacco, e-cigarette and e-liquid manufacturers, distributors, retailers, suppliers and trade associations in matters of FDA, state and global regulatory compliance. He also assists corporations in establishing clearances for food and drug additives in the U.S., Canada, and European Union, with an emphasis on indirect additives used in food-contact materials.
Mr. Chowdhury has authored and edited numerous articles and publications, including Tobacco Regulation and Compliance: An Essential Resource, FDA Regulation of Tobacco: A Comprehensive Guide – An FDLI Primer and Tobacco and Nicotine Delivery: Regulation and Compliance, 2nd Edition. He is a frequent contributor to the Food and Drug Law Institute's (FDLI) Update Magazine and has served on the Editorial Advisory Board of the Food and Drug Law Journal. In addition, he has been interviewed in the U.S. News and World Reports Best Lawyers Edition (2016) and was named one of “10 Names to Know in the Vape World” in the October 2015 issue of Vape Magazine. Mr. Chowdhury received the 2018 National Law Review Go-To Thought Leadership Award for his consistent coverage of the emerging issues surrounding vaping and e-cigarettes on Keller and Heckman’s law blog, The Continuum of Risk. As an industry leader, Mr. Chowdhury frequently speaks at industry conferences and events.
Mr. Chowdhury also has an active pro bono practice through Keller and Heckman’s Pro Bono Program, and has been featured in the Baltimore Sun for successfully obtaining asylum in the United States for a family who fled their home country of El Salvador because of violence they faced from an international gang.
Prior to entering private practice, he served as a judicial law clerk on the Court of Special Appeals of Maryland. Mr. Chowdhury received a B.A. and B.S. from Johns Hopkins University, a MBA from the University of Maryland Robert H. Smith School of Business, and a JD, cum laude, from the University of Maryland School of Law.
Education: Johns Hopkins University (B.A., B.S., 2003); University of Maryland Robert H. Smith School of Business (M.B.A., 2006); University of Maryland School of Law (J.D., 2006, cum laude).
Admissions: District of Columbia; Maryland
FDA Scores Win in Wages, but Industry Eyes Fifth Circuit Remand in Flavored Vape PMTA Denial Challenge

On April 2, 2025, the U.S. Supreme Court issued its decision in the Wages and White Lion Investments d/b/a Triton Distribution (hereafter “Triton”) Premarket Tobacco Product Application (PMTA) Marketing Denial Order (MDO) challenge. In a 9-0 unanimous ruling, the Supreme Court held that FDA did not act arbitrarily and capriciously when it denied the…
Webinar: Update on EU Regulations of E-Vapor and Nicotine Pouches

Update on EU Regulations of E-Vapor and Nicotine Pouches
Date: Thursday, 08 May 2025
Time: 4:30 PM – 5:30 PM CET | 10:30 AM – 11:30 AM EDT
Duration: 60 minutes
Cost: Complimentary
Registration: Click Here
Keller and Heckman LLP is pleased to announce a complimentary webinar, Update on EU Regulations of E-Vapor and Nicotine …
FDA Issues First Marketing Authorization for Oral Nicotine Pouches
In a groundbreaking move, FDA has kicked off the year with its very first marketing authorization for an oral nicotine pouch product. On January 16, 2025, FDA authorized twenty ZYN nicotine pouch products, marketed by Swedish Match (a subsidiary of Philip Morris International), in two nicotine strengths, 3 mg and 6 mg. The newly authorized…
CTP Advances Proposal to Set Maximum Nicotine Level in Cigarettes

On December 10, 2024, the U.S. Food and Drug Administration (FDA or the Agency) Center for Tobacco Products (CTP) advanced a proposal to set a maximum nicotine level in cigarettes and certain other combusted tobacco products. The Agency requested the White House Office of Management and Budget (OMB) expedite a proposed tobacco product standard in…
California Bans Online Sales of Flavored Tobacco Products Effective January 1, 2025
On August 28, 2024, the California legislature passed two laws – Assembly Bill 3218 (“AB 3218”) and Senate Bill 1230 (“SB 1230”) – that expand the scope of the state’s enforcement powers against flavored tobacco products. These laws, which have been signed by the Governor and are set to go into effect on January 1…
Oregon Court Strikes Down Vape Packaging Law as Unconstitutional Violation of Free Speech
On October 16, 2024, the Oregon Court of Appeals in Bates v. Oregon Health Authority made a significant ruling by overturning a law restricting the packaging of e-cigarette and cannabis products on the grounds that the law is an unconstitutional restriction on free speech.
The law in question, ORS. 431A.175(2)(f), prohibited an “inhalant…
U.S. Youth Vaping Rates Continue to Show Dramatic Decline
On September 5, 2024, the U.S Food and Drug Administration (“FDA”) and Centers for Diseases Control and Prevention (“CDC”) released data from the 2024 National Youth Tobacco Survey (“NYTS”), which shows the most remarkable decline in youth vaping to date. Specifically, the most recent NYTS, an annual, cross-sectional, web-based survey of U.S. middle school (grades…
FDA Authorizes First Menthol-Flavored Vapor Products
On June 21, 2024, FDA issued marketing granted orders (MGOs) to NJOY LLC for two non-tobacco flavored electronic nicotine delivery system (ENDS) products, the DAILY 4.5% and DAILY EXTRA 6% disposable devices, along with two ACE 2.4% and 5% pre-filled pods. All four of these NJOY ENDS products are menthol flavored. This FDA action, the…
The Menthol Cigarette Ban Saga: Biden Administration Delays Long-Anticipated Ban Indefinitely
On May 4, 2022, the U.S. Food and Drug Administration (FDA) initiated a notice and comment rulemaking process to ban menthol-flavored cigarettes and all characterizing flavors in cigars and cigarillos.[1] Recently, Health and Human Secretary Xavier Becerra announced the ban on menthol-flavored cigarettes will be delayed indefinitely. This article explores the long history of…