In a letter to the industry dated August 16, 2011, the FDA announced that it will begin inspecting every factory engaged in the manufacture or processing of cigarettes, cigarette tobacco, roll-your-own tobacco and smokeless tobacco. The inspections will begin in October 2011, and pursuant to the Tobacco Control Act, inspections will be conducted at least once every two years. Although the FDA has not yet established requirements for tobacco product good manufacturing practices, the inspections will focus on product registration and brand listing, ingredient listing, packaging, labeling and advertising requirements. The inspections will also address marketing authorizations for any new or modified risk tobacco products.
If you would like assistance in preparing for the upcoming inspections, which may occur without any notice, please let us know. Troutman Sanders has also been assisting its clients with preparations for the upcoming good manufacturing practices requirements.