By Norm Bour
If you are one of the 7,000 to 9,000 e-liquid manufacturers out there, then this one’s for you. You probably fall into one of three categories:
- You are a retail shop and you make your own liquid; hopefully not in your back room, but some of you know that you’re guilty of that. The bad news is that your days are numbered.
- You may be a brand manufacturer of any size. You probably have your own facility and you may also make juice for others. Your days may be numbered
as well unless you have studied the regulations and are planning on putting major dollars into your process.
- Or, you may be a contract manufacturer, making liquids for others and probably not selling your own branded products. If you plan to be here for the long term, then you have done your research and understand the rules of the game.
On the other side of the table we have the customers, the liquid sellers, that fall into one of several categories as well. If you have a substantial market share and are getting your juice manufactured by option number three above, then you need to know your risks and options going forward. You do not want to become an orphan.
New year, new game
Until recently, all “manufacturers” of vapor products were required to submit brand information, including names and labels to the Food and Drug Administration (FDA).
That target date was December 31, but the FDA was not prepared for the onslaught of submissions! They moved that date out six months to June 30, 2017. Ironically, the ingredients list for “large manufacturers” grossing more than $5 million annually comes before then, on Feb. 8, 2017, but by the time you read this that may be postponed, too.
The Product Composition Report is much more than an ingredient list—they must break down every ingredient and show the complete chemical composition. Small manufacturers have until August to supply the same.
Are you asking your e-liquid manufacturer the right questions?
Many contract manufacturers, along with most of the vape space, will be gone in the next 24 months. And many brands will go away as well because they don’t have a reputable manufacturer in place. A replacement alternative may not be available since they may be operating at capacity. Going forward you will see less businesses, doing more.
We spoke with James Arbaugh, one of the founders of the Vape Industry Business Exchange (VIBE), a newly formed trade group designed to support the industry through collaboration and teamwork. In addition to helping retail shops with mass buying power, they have also developed the “PMTA Exchange” which we will cover in more depth in our next issue.
For now, you need to ask tough questions of your manufacturer if you are using a third-party company. These are some guidelines that Arbaugh offered.
The three biggest lies told to vape industry businesses today
- “The check’s in the mail.”
- “I’m from the government and I’m here to help.” and…
- “Don’t worry, our e-liquid facility is completely prepared for the FDA and will be approved with flying colors!”
The first two lies apply to many life lessons, but if
you get bullshit answers to number three, then you should make a course correction quickly. Your livelihood is at stake and how you proceed will determine your longevity in the vape industry.
If you are getting your juice made by a third-party manufacturer, here are the Top Questions you must ask them.
1. What are you doing right now to prepare for FDA regulation of e-liquid manufacturers?
Their reply should have cGMP (current Good Manufacturing Practices*) at its core, since all manufacturers in all industries regulated by the FDA are required to adhere to industry-specific cGMP standards. Once cGMP’s are released for e-liquid manufacturing, they will be phased-in here, too. A serious and committed manufacturer should know about possible standards, which takes time and money to implement.
Acceptable responses might include: “We are substantially cGMP compliant” or, “We are making great strides in cGMP implementation.” Even, “We have hired (or retained) a firm that specializes in cGMP compliance and working frantically on it,” is passable.
Unacceptable answers include “We have an ISO-X clean room.” That lie has been revealed as unadulterated bullshit. Other unacceptable replies include: “Don’t worry about that, we’ve already registered!” Or, “We’re waiting to find out what the FDA requires because no one really knows yet until they release their requirements.” That means they haven’t taken the time to research and find out what they should be doing now.
True, while no one knows the specifics, there are many cGMP-related steps that can be taken now. Some should have been started last year and can save the company a lot of time without breaking the bank.
The absolute worst answer is, “We are already an FDA-approved e-liquid manufacturer.” There is no such thing and they are either lying to you intentionally or out of ignorance.
2. What are the qualifications of the person or firm that wrote your SOPs?
If they don’t have Standard Operating Procedures (SOPs), then they aren’t working on cGMP. If a PhD
…continued from above
chemist or a masters-level chemist with several years of cGMP implementation experience wrote them, that’s good. If they downloaded boilerplate information and a high school chemistry geek customized them, you might have a problem. If in doubt of their reply, get a copy of the chemist’s background and experience.
3. Can I tour your facility?
If they balk at this, it may be a bad sign. Most legitimate manufacturers are willing to show you around. If they claim “proprietary manufacturing secrets,” that also should set off your spider senses. They will probably ask you not to photograph or record anything, or maybe even sign a non-disclosure agreement, but those are within reason.
The “batch testing” question
The FDA will soon require batch testing of samples. Currently there are just a few liquid companies doing that, and the FDA will allow some time for implementation of this step.
In the next year, the FDA will require all manufacturers to test each batch after mixing to validate that the active ingredient falls within +/- 10 percent of the label claim. If they use the acid based titration method to test finished product, most experts will tell you that’s inaccurate when mixed with other ingredients. That method is effective for nicotine purity before it’s mixed with flavorings, but not after.
The only way to accurately test the nicotine strength of finished e-liquid is with a specialized chromatograph. These fall into one of two categories, and are either a Gas Chromatograph (“GC”) or a High Performance Liquid Chromatograph (“HPLC”).
They should also staff a trained technician to keep the equipment calibrated and to read and record the results. If your manufacturer is doing batch release testing using GC or HPLC, then you did a good job at picking a winning company.
The future’s so bright you gotta wear shades!
The days of the Wild, Wild West aren’t so wild any more. The Feds are in town and are kicking ass and taking names. If your company is targeted for investigation, then you had better be prepared!
If your e-liquid manufacturer is keeping you in the dark and covering you with BS, you could find your brands on the trash heap of history. Don’t take that chance—know the right questions to ask, and understand the right answers!
The Vape Industry Business Exchange will be sponsoring manufacturing symposiums in 2017, hosted by VapeMentors and taught by industry leaders, Keller and Heckman, LLC law firm. Their first workshop of the new year will be held in Washington, D.C. on Feb. 2-3. Contact email@example.com for information about attending.
*current Good Manufacturing Practices starts with a set of Standard Operating Procedures, or “SOPs” that prescribe exactly how every step in the manufacturing process is to be conducted and documented to ensure every single bottle of e-liquid is exactly like the others.
Norm Bour is the founder of VapeMentors and creator of the VAPE U online programs. They offer services and resources for anyone in the vape space, including vape shops, online stores and e-liquid brands. He’s also the host of Vape Radio, the largest vaping radio show in the world with more than 1.3 M downloads. Norm interviews the masters of vape and thought leaders in the vape space. Contact him at norm@VapeMentors.com.
Letter From the Editor
Welcome back to another special edition of VAPE Magazine. The subject — all things e-liquid.
When we began planning this issue, we decided it should be a book that vapers and store owners alike would use as a reference for the year to come. Are you or your customers looking for a new pistachio tobacco? You’ll find it here. How about a rice krispy treat? An awesome milkshake? A line of nothing but milk flavors?
This reference guide lists hundreds of brands, what they offer and how to reach them in an easy to navigate system that will help put vapers in touch with new brands they may have otherwise never come in contact with.
We worked to put together a variety of content focused solely on e-liquid and the business to compliment the guide.
I hope you’ll find it to be useful!
From the entire team here at VAPE Magazine, I wish you all an awesome 2017! We’ll see you out on the show circuit!
Thanks for reading,
Editor in Chief
Standing Out in a Saturated Market
By Cory Noles
The struggles of the modern e-liquid manufacturer are real. Quite real.
In any time, to take a product from a simple concept to being successful is difficult — far more than the average vaper understands. Today, the climb is astronomical.
The days of perfect timing are over. Even “unique” flavors are becoming a thing of the past as there are few things that have yet to be done in the field.
Instead of having the right flavor, today’s market is about being “more clean” and having more hype. What makes your brand stand out beyond those that have been dominating the space for years?
Brace yourself for this.
What has happened is that as the e-liquid manufacturing industry has grown from a couple dozen big manufacturers to several thousand small to moderately sized manufacturers, it has begun to mature.
This isn’t a bad thing, unless your product depended entirely on good timing.
What this means for us, is that the vaping industry is taking on the basic business hallmarks that apply to every industry.
Today’s market demands a quality product
There are literally thousands of e-liquid companies across the nation and guess what — many of them make a good product. Adversely, many of them make lousy ones as well. What this means is that simply having a solid line is no longer enough to get your business where you want it to be.
Marketing is necessary
There was a time in the vape space when a good product could outshine its crappy label and cheap bottle. That time has passed. Sadly, it’s no longer “all about the juice.” People need a reason to want to try your product aside from word of mouth. That means they need to see it everywhere — on social media, in magazines and in the hands of the industry’s influencers.
A long-taught marketing principle says that a person has to see an ad or a logo an average of eight times before they will take action. Are people seeing your branding regularly?
People don’t buy e-liquid with your name on it
Locally, Bob’s Coil Suds might do well. If that’s all you want, go for it. However, in the grand scheme of things, your branding should reflect your audience. For example, Boosted is extra attractive to the car crowd. What started as a niche grew into a massive international brand. Bob is not a niche. Bob is a dude who, while probably a great dude, most of us don’t know.
So don’t do it.
Keep the number of flavors you release under control
While in theory, having a line made up of 20-30 flavors seems like it would have something for everyone, it’s a hard if not impossible sell to shop owners and especially distributors.
When your line crosses three flavors, expect it to be about 50 percent more difficult to sell with each you add. The fact is most shop owners aren’t rich and can’t afford to take a $1,500-$3,000 gamble on your product. I’m not saying a line like that can’t work, but it severely limits your field of potential buyers.
The line between unique and unsellable is fine. Very fine. I’ve tried a mountain of juice over the years, and this is a hard fact. Just because you may have formulated the world’s greatest bacon milkshake flavor or the next maple strawberry pizza cake, does not mean people want to vape it. Kudos on your skills, but when people try it and use words like “interesting” and “weird,” they will move on to the next sample.
Flavors need to be something the average vaper would enjoy. It can have a unique twist, but always ask yourself “Would I vape this all day every day?” If the answer is no, move on. EVERY manufacturer/mixologist has left hundreds of quality juices in a cabinet never to be tried again.
Basically, in sharing these tips, I’m just trying to remind everyone that this is a business. Each day it’s becoming more and more like any other. The cause is noble, yes, but without a solid business plan, you may never reach your potential.
Corey Noles is the Editor in Chief of VAPE Magazine. He also owns Busted Knuckle Vapor Fluids and Inked Up E-Liquid Co. Email firstname.lastname@example.org.
Scenic Vapors: Contributor Corner: Jayson Magbanua @mrpinoykid
By Chris Mellides
Photographer: Chris Starcher @dripmedia
In Frame: Tyler Price @dripping_balls
Location: Swallow Falls State Park, MD
“A healthier body is what keeps us going, and we vapers just have to talk to smokers more about vaping and make them turn away from cigarettes for good.”
Inspired by the friends he’s made on a path to becoming a professional photographer, 22-year-old Washington state resident Jayson Magbanua has always dreamt big.
Enamored with the art world and all of the different mediums it encompasses, populating his college studies with art classes seemed natural to Magbanua.
Educated in traditional photography where he was taught how to shoot on and develop film, the young student took what he learned, and applied his skillset and unique discipline to contemporary photography—which by all accounts is far easier and more convenient than having to rely on dated technology.
Like many in his peer group, the most accessible camera he had in college was the one in his pants’ pocket.
“Back in the day I would only use my phone and I would be pretty stoked with how the pictures turned out,” Magbanua said. “I never owned a camera since last year, I believe, but now that I have one it feels like a dream.”
Armed with his digital SLR camera, Magbanua would often take it with him on hikes and camping trips and found himself being quickly drawn to nature photography.
“When I’m trying to find myself I hike and camp,” he said. “Nature pictures are definitely one of my favorites because of the organic feel to them.”
Magbanua found that exploring the outdoors became more enjoyable when he gave up smoking and switched to vaping as a reduced harm alternative.
He admits that while he was a light smoker who would casually light up when in the company of friends, the obvious positive health effects coupled with the allure of vape tricks and the multitude of e-liquid flavors to choose from made transitioning to vapor products in late 2012 an easy choice for him to make.
It was natural for Magbanua to combine vaping and nature photography into his body of work, and it became apparent to him that several photographers, including select friends, had already began carving that niche out for themselves.
“My friends inspire me the most,” Magbanua said. “The support that they give me is incredible. We share the same passion for photography, and we teach each other and love each other.”
Scenic Vapers was a project that Magbanua discovered on Instagram, which he would often post to and use to explore a wealth of photographs from seasoned and amateur photographers alike, all with the swipe of a finger.
It wasn’t long before he began tagging his nature-inspired vaping photos using the Scenic Vapers hashtags that project founders Tyler Price an Ian Silver began to take notice.
Photographer: Billy Lawrence @trippinbillys
In Frame: Paige Drysdale @paige.nicolle
Location: Bell Rock Vortex, Sedona, Arizona
“I remember Tyler Price back in the day when he just started on Instagram, and had always been lurking through his Instagram,” Magbanua said. “Ian silver I don’t really know, but I like his work a lot.”
He added, “They are such humble human beings, and they are now doing good things and that makes me pretty happy.”
Magbanua says that his involvement with Scenic Vapers comes from his utmost respect and love for nature and vaping, and the excitement in knowing that he’s part of a following and a much larger movement.
“The movement and the vibe from the people,” Magbanua says is what interests him about the project. “It’s really nice seeing people explore and take pictures. I’m excited for where the group takes us in the future.”
He also believes that Scenic Vapers can be used as a vehicle for capturing the attention of smokers through photographs and exposing them to vaping as a culture and ultimately a healthier alternative to combustible tobacco.
“This is what we need to do to make the smokers stop smoking,” Magbanua said. “A healthier body is what keeps us going, and we vapers just have to talk to smokers more about vaping and make them turn away from cigarettes for good.”
To submit your photo to Scenic Vapers #CloudCheck for VAPE submission consideration, follow @VapeMagazine @ScenicVapers @Dripping_Balls and @Jedi.Visions and #VapeMagazine #CloudCheck & #ScenicVapers on Instagram.
For the VAPE pictorial column, photos must be in high resolution, but for the IG page everyone has the chance for a feature.
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