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Owen Chaput practices in the area of food law, as well as tobacco and e-vapor regulation. He advises domestic and foreign clients on establishing clearances for food additives and food contact materials under FDA and comparable international regulations.  Mr. Chaput also counsels tobacco and e-vapor manufacturers and suppliers in matters of state and federal compliance.

Prior to joining the firm, Mr. Chaput held the position of Regulatory Counsel at FDA's Center for Tobacco Products (CTP), where he analyzed industry submissions for compliance with FDA advertising laws and worked on retailer compliance and enforcement matters with respect to sales of tobacco products.

While in law school, Mr. Chaput served as a law clerk in the Federal Trade Commission, Bureau of Consumer Protection.

 

On Friday July 28, 2017, the U.S. Food and Drug Administration (FDA) announced its new “comprehensive regulatory plan to shift trajectory of tobacco-related disease, death” that refocuses the Agency’s implementation of the Family Smoking Prevention and Tobacco Control Act (TCA) and the Deeming Rule. FDA’s new strategy appears to be moving away from its “one-size-fits-all”

Although we are still waiting for an official announcement, FDA’s Stakeholder Relations Office recently indicated that the Agency will be delaying enforcement of all future Deeming Regulation compliance deadlines set for May 10, 2017 or later, including those for manufacturer submission of cigar warning label plans, registration and listing, ingredient listing, health documents, substantial equivalence

UPDATE – FDA’s Ingredient Listing Deadline For Deemed Products Extended by Six Months

On December 28, 2016, FDA finalized its Guidance for Industry, “Listing of Ingredients in Tobacco Products” which is available here. In the new guidance FDA states that, “considering that some manufacturers of newly deemed products are not familiar with the forms

UPDATE: On December 9, 2016, FDA issued a revised guidance for industry, “Registration and Product Listing for Owners and Operators of Domestic Tobacco Product Establishments,” extending the December 31, 2016 deadline for registration and product listing for U.S. manufacturers by six months by June 30, 2017. According to FDA, the guidance has been