FDA WARNING_LETTER - www.smokesfourless.com

The FDA Center for Tobacco Products reviewed Smokesfourless.com and determined that cigarette tobacco and roll-your-own tobacco products offered for sale are in violation of the Federal Food, Drug, and Cosmetic Act (FD&C Act).

The website sells loose tobacco products, including D&R, VPB, PenHooker, and 2 Daughters, promoted as cigarette tobacco and/or roll-your-own tobacco, despite some being labeled "pipe tobacco." The site's overall presentation, including descriptions like "Roll Your Own" and the sale of cigarette-making accessories, indicates these products are intended for cigarettes, meeting the definitions of "cigarette tobacco" and "roll-your-own tobacco" under the FD&C Act.

Violations include: 1. **Modified Risk Tobacco Products:** Products like VPB Blue ("Light blend"), Ryback Gold ("a bit lighter"), and PenHooker Silver ("ultra high-grade light") are described using "light" or similar descriptors. These are considered modified risk tobacco products under section 911(b)(2)(A)(ii) of the FD&C Act and are sold without a required FDA order, making them adulterated under section 902(8). 2. **Flavored Tobacco Products:** The product "Wintergold" (mint) is offered for sale, purporting to contain a characterizing artificial or natural flavor. This violates section 907(a)(