Beyond product applications, there are other deadlines (some that already have passed) that are part of the deeming rule. Those deadlines include:

—Registration of establishments engaged in the manufacture, preparation, compounding or processing of a tobacco product and product listings:
     -Oct. 12, 2017.
     -Immediately upon first engaging in the manufacturing of a tobacco product for products released after Oct. 12, 2017.
—Ingredient listing
     -May 8, 2018.
     -Nov. 8, 2018, for small-scale tobacco product manufacturers.
     -90 days prior to marketing for new products released after Aug. 8, 2016.
—Harmful and potentially harmful constituents:
     -Nov. 8, 2019.
     -90 days prior to marketing for products entering the market after Nov. 8, 2019.
—Prohibition on the introduction into interstate commerce of products that contain “light,” “low,” “mild” or other similar descriptors in the label, labeling or advertising of such products without a modified-risk tobacco product order in effect:
     -Stop manufacturing: Nov. 8, 2017.
     -Stop distribution into interstate commerce: Dec. 8, 2017.

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