FDA WARNING_LETTER - Humble Juice Co. LLC - June 07, 2019

The FDA and FTC issued a Warning Letter to Humble Juice Co. LLC on June 7, 2019, for misbranding e-liquid tobacco products. The agencies reviewed the company's website (humblejuiceco.com) and social media accounts (Instagram, Facebook, Twitter), as well as an influencer's Instagram account (pvrkerr), finding that several e-liquid products were advertised and sold without the required nicotine warning statement.

Specific products cited include HMBL SALT Mango Pineapple, HMBL SALT Blue Blood High, HMBL SALT Strawberry Kiwi, HMBL SALT Apple Jay Jay, HMBL SALT 99 Pink Balloons, and HMBL SALT Watermelon Patch. This violates 21 U.S.C. § 387c(a)(7)(B), 21 U.S.C. § 387c(a)(1), and/or 21 U.S.C. § 387c(a)(7)(A) of the FD&C Act, and 21 C.F.R. § 1143.3, which mandates the warning: "WARNING: This product contains nicotine. Nicotine is an addictive chemical."

The FTC also noted concerns under Section 5 of the FTC Act (15 U.S.C. § 45) regarding deceptive practices due to the failure to disclose nicotine's addictive nature.