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HPHC testing is just the first of the expensive tests that e-liquid manufacturers will have to complete if they want their PMTAs to receive serious consideration. Those with no plan for completing that work are unlikely to survive (legally) beyond Sept. 9—and some observers don’t think any company that hasn’t done testing will make it past that deadline. But some vape industry insiders believe the FDA will grant case-by-case exceptions to small manufacturers that communicate with the agency and show a concrete plan for finishing the remaining tasks. Amanda Wheeler is in the second camp. She believes the FDA will be lenient toward manufacturers that have been forthright explaining their progress to the federal regulators. And she and Char Owen are constantly seeking solutions that will put all of those processes within reach of small manufacturers.

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