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Nicholas (Nick) Ramos draws on years of military leadership, project management, and legal experience to help clients solve difficult business problems from a legal perspective. He assists clients in navigating regulatory compliance issues, complex enforcement actions, and licensing that arise under both state and federal law.

The US Food and Drug Administration (FDA) recently announced plans to publish a proposed rule that would establish a maximum nicotine level in cigarettes and certain “other combusted tobacco products.” At the moment, it is not clear what “other combusted products” FDA might have in mind. According to the Spring 2022 Unified Agenda of Regulatory and Deregulatory Actions, FDA is targeting May 2023 to issue the proposed rule, but that could always change.
Continue Reading FDA Set to Propose Maximum Nicotine Level in Cigarettes

Last year we reported that Vermont Attorney General T.J. Donovan’s office settled with several online sellers over alleged violations of the state’s delivery sales ban of electronic nicotine delivery systems (ENDS) (the Delivery Sale Ban) and that we expected Vermont’s scrutiny to continue. As predicted, Attorney General Donovan’s office recently announced two more settlements with

Most of us are keenly aware of the ongoing fallout from the Russian Federation’s invasion of Ukraine. As the conflict continues, the U.S. government has taken action to support Ukraine, while at the same time, punishing the Russia Federation for its violation of international law and norms. Consistent with this strategy, on March 11, President

As we previously reported, Executive Order 14036 (E.O. 14036) required the Treasury secretary, who oversees the Alcohol and Tobacco Tax and Trade Bureau (TTB), to issue a report to the White House Competition Council (the Council) chair, assessing the current market structure and conditions of competition in the U.S. alcohol market.

In response to

While cannabis legalization moves full steam ahead through much of the Northeast, the southeastern U.S. has been notably slow to uptake major reforms. These states haven’t made major headlines for their progressive cannabis policies, but together they constitute a major market that has, nevertheless, dipped its toe in the water. As such, we thought we’d

On December 3, the Alcohol and Tobacco Tax and Trade Bureau (TTB) issued a proposed rulemaking aimed at modernizing and streamlining permit application and reporting requirements for distilled spirits plants (DSPs), wineries, importers, wholesalers, alcohol beverage dealers, and other permittees. TTB’s proposed changes are good for the industry because they will reduce the regulatory burden

We recently posted that the Federal Trade Commission (FTC) issued warnings to a large number of companies in various industries about “unfair” or “deceptive” trade practices related to third-party endorsements. Some of the businesses that received those warnings included alcoholic beverage companies. FTC’s warnings raise the broader question of what is acceptable when it comes

Governor Gavin Newsom recently signed California Assembly Bill 45 (AB 45) into law, which, among other things, allows hemp-derived cannabidiol (CBD) to be included in any food, beverages, and dietary supplements sold in California. This is not only a break from California’s prior position prohibiting CBD from being included in such products even as the

The alcoholic beverage industry is known for its ability to create new, innovative beverages that do not always fit neatly into the traditional categories of beer, wine, and spirits. Hard seltzer is one example of a new, innovative beverage that has gained significant popularity in recent years. From a regulatory compliance perspective, it is challenging

Vermont Attorney General T.J. Donovan recently announced that his office settled violations of the state’s delivery sale law with three online electronic nicotine delivery system (ENDS) sellers. Since December 2020 and including these most recent settlements, the state has collected $472,500 from 13 companies for such violations, signaling the state’s growing desire to enforce this