State Laws on E-Cigarette & Nicotine Vending: Legislative, Enforcement & Litigation Update
A comprehensive reference on statutes, AG enforcement actions, pending litigation, and regulatory trends governing vape vending machines and nicotine pouch vending across the United States.
Federal Regulatory Framework
All state-level regulation of vape vending machines and nicotine pouch vending operates within a federal baseline established by two primary statutes and the Food and Drug Administration's implementing regulations.
Grants the FDA authority to regulate "tobacco products," a category that has been administratively extended to include electronic nicotine delivery systems (ENDS), including e-cigarettes, vape devices, and any product "made or derived from tobacco" or intended for human consumption. Under this authority, the FDA may regulate the manufacture, marketing, distribution, and sale of covered products.
Prohibits the sale of tobacco products — including e-cigarettes and ENDS — to any person younger than 21 years of age. As of 2025, all 50 states, the District of Columbia, Guam, the Northern Mariana Islands, Palau, Puerto Rico, and the U.S. Virgin Islands comply with this minimum age requirement.
Prohibits the sale of cigarettes and smokeless tobacco products through a vending machine unless the vending machine is located in a "qualified adult-only facility" — defined as a facility or portion of a facility where the operator ensures that no person younger than 21 years of age is permitted to enter at any time. The FDA has applied these placement restrictions to ENDS/vape products via its deeming authority.
Premarket Tobacco Product Applications (PMTA)
The PMTA process is the central federal mechanism through which e-cigarette products can obtain lawful marketing authorization. Under 21 U.S.C. § 910, a manufacturer must demonstrate that marketing of the product is "appropriate for the protection of the public health." The regulatory status of products under pending PMTA review, or where PMTAs were denied but remain subject to appeal, has become the linchpin of state vapor product directory litigation.
In September 2025, the FDA launched a pilot program to accelerate PMTA review for nicotine pouches. In December 2025, the FDA issued marketing authorizations for six On! Plus nicotine pouch products, making them only the second brand (after ZYN) to receive PMTA authorization. The FDA also issued warning letters to 24 importers of illicit vape products in 2025, and the U.S. Senate directed the FDA to allocate $200 million in fiscal year 2026 specifically for enforcement against unauthorized vapes.
State Vapor Product Registries: The Dominant Legislative Trend
RegistryEnactedThe single most consequential legislative development in 2024–2026 is the rapid proliferation of state vapor product directory laws. These statutes create a state-maintained list of vape products that are lawfully authorized for sale, effectively conditioning retail legality on FDA PMTA authorization status.
Active Registry States
Statutory Language: Selected Registry Provisions
Prohibits the sale, distribution, or importation for sale of any liquid nicotine or nicotine vapor product not included on the Virginia vapor product directory as of December 31, 2025, or subsequently removed from the directory. The directory conditions lawful sale on the product having received, or having a pending, premarket tobacco product application with the FDA as of September 9, 2020.
Establishes a state vapor products directory administered by the Tennessee Alcoholic Beverage Commission (TABC). Only products listed in the directory may be sold at retail. Products must have had a PMTA submitted to the FDA by September 9, 2020, to qualify for directory listing. The TABC receives 12.5% of vapor tax revenue for enforcement purposes. Retailers are subject to a minimum of two random compliance checks per year; results will be published publicly.
Would establish a state-maintained vapor products directory as a condition for legal retail sale, integrating vapor products into Arizona's existing alcohol regulatory framework. Only products listed in the directory would be permitted for sale. Unlisted products would be banned, and violators would face significant penalties. The bill effectively makes Arizona an enforcer of federal FDA compliance, barring any e-cigarette product that has not received FDA marketing authorization or does not have a PMTA timely filed.
Effective July 1, 2025, only vape products authorized by the FDA may be legally sold in North Carolina. The law establishes a directory of lawfully marketed products maintained by the state. Sale of unlisted products constitutes a violation subject to civil penalties. Challenged by the Vapor Technology Association before the Fourth Circuit; oral argument scheduled January 29, 2026.
Registry Preemption Litigation
LitigationThe central legal question in 2025–2026 is whether state vapor product directory laws — which condition retail sale on FDA authorization status — are preempted by the federal Food, Drug and Cosmetic Act (FDCA). The argument for preemption is that the FDCA vests exclusive enforcement authority over PMTA compliance in the federal government, and a state may not duplicate or parallel that enforcement framework through its own directory statute. Courts have begun to split, creating a circuit-level conflict that may ultimately reach the U.S. Supreme Court.
The U.S. District Court for the Eastern District of Virginia granted a preliminary injunction blocking enforcement of Virginia's vapor product directory law. The court found the enforcement provisions of Va. Code Ann. §§ 59.1-293.17(D) and 59.1-293.20(A)–(D) are preempted by the FDCA. Specifically, the court held that "[b]y specifically incorporating [federal premarket review requirements] as the precondition for determining what products can be sold, any proceeding against a vape manufacturer under Virginia's [vapor product directory] enforcement provisions would exist 'solely by virtue' of that manufacturer's violation of the FDCA … [and] such state law claims stand preempted by the FDCA and the federal government's exclusive enforcement authority." The court carved out non-preempted provisions: state law requirements governing registration, certification, recordkeeping, inspection, and information reporting — which do not turn on FDA authorization status — remain enforceable.
This case challenges North Carolina's vapor product directory law on the same FDCA preemption grounds litigated in Nova Distro. The Fourth Circuit's resolution of the preemption argument in this case will directly shape both the North Carolina and Virginia directory litigation. The Fourth Circuit's ruling — expected in 2026 — will set binding precedent for all states within its jurisdiction (Maryland, Virginia, West Virginia, North Carolina, South Carolina) and will likely influence how district courts in other circuits analyze the same question.
A federal judge issued a preliminary injunction pausing enforcement of Iowa's vapor product directory, ruling that the law violated the U.S. Constitution's Supremacy Clause. The court found that Iowa's directory impermissibly encroached on the FDA's exclusive authority under the FDCA to regulate the marketing and distribution of tobacco products.
In Kentucky, industry plaintiffs sued to block a registry law but the challenge was dismissed in district court. Subsequent appellate proceedings have, as of the date of this report, favored the state's enforcement stance. Kentucky thus represents the opposing pole from the Virginia and Iowa decisions, with courts beginning to split on whether state registry enforcement provisions are preempted by the FDCA.
The fundamental tension in registry litigation is that the FDCA contains both an express preemption clause (preempting state laws that differ from or add to federal tobacco product standards) and an express savings clause (preserving state authority to regulate the sale or distribution of tobacco products in ways not "based on" smoking and health). Courts disagree on whether a state directory that prohibits sale of a product because it lacks FDA authorization is "based on" smoking and health (not preempted) or is impermissible state enforcement of a federal licensing scheme (preempted). The Supreme Court's decision in Virginia Uranium, Inc. v. Warren (2019) and the Tobacco Control Act's structure bear on this analysis, and observers expect the Court may ultimately weigh in.
Vending Machine Placement Laws: Verbatim Statutory Language by State
Statutory TextState vending machine placement laws generally require that vape and nicotine vending machines be located in adult-only establishments where no person under 21 may enter. Most states enacted these laws to track federal placement restrictions. Below are the verbatim statutory provisions for key states.
California
"No cigarette or tobacco product shall be sold from a vending machine unless the machine is located in an area of the premises that is barred to minors, such as a bar or private club where entry is restricted to persons 21 years of age or older."
California additionally requires that vending machines be placed at least 15 feet from any entrance accessible to the public. Self-service displays of any vape or nicotine product are banned unless in an adult-only tobacco retailer or 21+ establishment. A California Cigarette and Tobacco Products Retailer's License is required per location (including per vending machine site) under Cal. Bus. & Prof. Code § 22972. The excise tax on vapor products is equivalent to the cigarette tax — approximately 56.93% of wholesale cost as of 2025.
New York
"Vending machine sales of e-cigarettes [are] permitted in bars, private clubs, and tobacco businesses; in other businesses that have proportionally few employees under 21, the products must not be accessible to the general public and must be visible to and under the direct control of [a] person in charge."
"Sale of flavored vapor products intended to be used for the consumption of nicotine [is] prohibited."
"A tax of 20% of retail price is imposed on all vapor products."
Virginia
"Nicotine vapor products and alternative nicotine products may be sold through a vending machine only if the machine is: (1) posted with a notice, in a conspicuous manner and place indicating that the purchase or possession of such products by persons under 21 years of age is unlawful; and (2) located in a place that is not open to the general public and is not generally accessible to persons under 21 years of age. An establishment that prohibits the presence of persons under 21 years of age unless accompanied by a person 21 years of age or older is not open to the general public."
Every person engaged in the business of placing vending machines and selling tangible personal property through such machines must apply for a Certificate of Registration for each county and city in which machines are placed. Records must be kept for three years and must show the location of each machine; purchases and inventories of merchandise bought for sales through vending machines; and the cost price of merchandise for each machine. Va. Admin. Code § 10-210-6041.
Liquid nicotine is taxed at $0.066 per milliliter for closed-system pods, and at 20% of wholesale price on open-system e-liquid.
Minnesota
"Electronic delivery device means 'any product containing or delivering nicotine, lobelia, or any other substance, whether natural or synthetic, intended for human consumption through inhalation of aerosol or vapor from the product. Electronic delivery device includes but is not limited to devices manufactured, marketed, or sold as electronic cigarettes, electronic cigars, electronic pipe, vape pens, modes, tank systems, or under any other product name or descriptor. Electronic delivery device includes any component part of a product, whether or not marketed or sold separately.'"
Minnesota prohibits vending machine sales of electronic delivery devices in any location accessible to persons under 21 years of age at any time. This subdivision does not apply to vending machines in facilities that cannot be entered at any time by persons under the age of 21 years. A tobacco products license is required to operate vaping product vending machines in Minnesota.
Texas
Vape vending machines in Texas must be located in venues that are entirely restricted to individuals 21 years of age and older. An e-cigarette retailer permit is required. The statute's vending restrictions apply expressly to "e-cigarettes" as defined — a definition that does not currently encompass tobacco-free nicotine pouches under its plain terms.
Note: Texas SB 2024 (effective September 1, 2025) bans all pre-filled disposable e-cigarettes manufactured in China, including from vending machine sales, though the bill leaves existing vending machine placement rules unchanged for otherwise compliant products.
Georgia
Georgia restricts vending machine sales of nicotine products to establishments that are 21+ adult-only. No recent legislation has modified these vending provisions. Georgia requires retailers to obtain a state license ($700 annually) to sell vaping products and imposes a tax of $0.90 per milliliter of e-liquid. No statewide flavor ban has been enacted as of the date of this report.
Arizona
Vending machines selling nicotine products in Arizona are limited to adult-only venues, such as bars, under existing state law. No recent legislation has modified these vending regulations. As of early 2025, SB 1272 (which would create a vapor products directory) had passed through key Senate committees but had not been enacted into law.
Texas SB 2024: Ban on Chinese-Made Disposable Vapes
Enacted Effective Sept. 1, 2025Prohibits the sale or distribution of all pre-filled disposable e-cigarettes manufactured in China. Refillable and open-system devices with U.S.-filled e-liquid remain lawful even if device hardware components are Chinese-manufactured. The law bans: (1) packaging with cartoon characters, candy likeness, or youth-appealing imagery; (2) devices designed to resemble everyday objects such as highlighter pens, toys, or smartphones; and (3) vape devices containing cannabinoids, kratom, kava, psychoactive mushrooms, or similar substances outside of nicotine. Marketing strategies that appeal to minors are prohibited. Vending machine placement rules remain unchanged.
The law represents one of the most restrictive state-level product bans to date, effectively eliminating the disposable vape category from Chinese supply chains — which included the majority of high-volume disposable brands on the market. A legal challenge was filed; the Texas Supreme Court permitted the law to take effect in August 2025, pending resolution of that litigation.
Full compliance details for your state
State by State Laws for Vape VendingFlavor Bans: State-by-State Landscape
EnactedPendingComprehensive ban effective January 1, 2025, prohibiting all flavored e-cigarettes except tobacco. Extended to cover online sales and nicotine analogs. Additional "Unflavored Tobacco List" requirement effective January 1, 2026.
Comprehensive ban including menthol. Enacted 2019, among the first statewide bans in the country.
Ban on all flavored vapor products intended for nicotine consumption. N.Y. Pub. Health Law § 1399-mm-1(2) (2025). Menthol included in the ban for vapor products.
Comprehensive ban on flavored e-cigarettes except tobacco and menthol flavors.
Comprehensive ban on flavored e-cigarettes except tobacco and menthol.
Flavored vape ban became effective January 2025; implementation on hold under a temporary restraining order due to pending litigation as of early 2025.
Partial restrictions; flavored products limited to sale at age-restricted adult-only vape shops.
Denver City Council passed ordinance banning flavored tobacco and nicotine products, effective January 1, 2026. Eagle, CO also enacted a local flavor ban effective January 1, 2026.
Approximately 15 states are expected to consider some form of flavored tobacco and nicotine product ban in the 2026 legislative sessions. With California's statewide ban now operative, neighboring states Oregon and Washington are expected to reconsider legislation. Local activity continues to accelerate, with major cities implementing flavor bans at the municipal level.
State Attorney General Enforcement Actions: 2025
EnforcementBeginning in January 2025, state attorneys general across the country launched a coordinated wave of enforcement actions targeting retailers and distributors of unauthorized or flavored e-cigarette products. These actions have employed consumer fraud statutes, flavor ban violations, PACT Act violations, tobacco licensing laws, and ingredient disclosure requirements as independent bases for state-law claims — specifically to avoid the FDCA preemption arguments that have undermined direct FDCA-based enforcement by AGs.
| State | Action & Case | Status |
|---|---|---|
| California | AG filed suit against two companies importing Flum brand e-cigarettes (high-nicotine, fruit-flavored, animated screens), alleging: violation of state flavor ban; operating without proper licenses; making false statements in license applications. January 2025. | Active litigation |
| California (SF) | City & Cty. of San Francisco v. Bass Gift Shop SF, et al., CGC-24-618016 (S.F. Superior Ct.). Suit against 11 vape shops in four Bay Area counties selling flavored products in violation of state and local laws. Defendants agreed March 3, 2025 to surrender all unlawful products and pay $250,000 in civil penalties, attorney's fees, and costs. | Resolved — consent judgment |
| Connecticut | AG issued investigative subpoenas to twelve retailers and two wholesalers for selling illegal imported flavored e-cigarettes. Purpose: identify suppliers and distributors of unlawful products. January 2025. | Investigation ongoing |
| Hawaii | AG sent letters to over 800 tobacco retailers and distributors advising them not to sell tobacco products not authorized by FDA. January 2025. | Warning phase |
| Illinois | Illinois v. Chicago Merchandise Co., No. 2025CH00422 (Ill. Cir. Ct.). Suit against three Illinois businesses that imported and sold Posh brand e-cigarettes from China without FDA authorization; at least one defendant received an FDA denial order. | Active litigation |
| Minnesota | State of Minnesota v. Venture Concepts Grp. LLC dba High Light Vape Co., No. 62-CV-25-382 (Minn. Dist. Ct., 2nd Judicial District). Suit over e-cigarette marketed as disguised "highlighter" for stealth vaping in prohibited locations; fruit flavors; inadequate age verification. April 2025: consent judgment — sales restricted and monetary penalties imposed. | Resolved — consent judgment |
| New Jersey | Approximately 11,000 businesses received warning letters reminding them of the state's ban on flavored e-cigarettes. January 2025. | Warning phase |
| New York | People of N.Y. v. G-Smoke360 Corp. dba G Smoke, No. EF2025-112607 (N.Y. Sup. Ct., Herkimer Cty.). Suit against vape shop operators for selling flavored e-cigarettes, sales to minors, and operating without required licenses. January 2025. In February 2025, AG filed against thirteen e-cigarette manufacturers and distributors including those marketing Puff Bar, Elf Bar, Geek Bar, Breeze, and MYLE, alleging violations of flavor ban, PACT Act, tobacco licensing, and ingredient disclosure laws. | Active litigation |
| Ohio | Ohio ex rel. Yost v. Central Tobacco & Stuff Inc., No. 24-CVH-070664 (Ohio Ct. C.P. Oct. 29, 2024); Ohio ex rel. Yost v. Orrville Tobacco & Vape Shop LLC, No. 2024-CVC-H-0327 (Feb. 5, 2025); Ohio v. Elevate Smoke LLC, No. A2403034 (Feb. 20, 2025). Three cases dismissed on grounds that CSPA claims were preempted by the FDCA. Appeals pending in two cases. | Dismissed (preemption); appeals pending |
The Ohio Preemption Decisions — Significance for Operators
The Ohio cases are significant because they represent the most operator-favorable outcomes in the AG enforcement wave. Ohio courts held that the state AG's consumer fraud claims under the Ohio Consumer Sales Practices Act (CSPA) were impliedly preempted by the FDCA, reasoning that the state law claims "would not exist but for the underlying federal regulatory scheme." This reasoning, if adopted broadly, would significantly limit the ability of state AGs to bring claims against sellers of unauthorized vape products using state consumer protection law as an enforcement vehicle. The appeals remain pending, and other circuits have not yet adopted this reasoning.
Nicotine Pouch Vending: Regulatory Snapshot
Nicotine PouchesNicotine pouches — tobacco-free, oral nicotine products — occupy a distinct regulatory position from e-cigarettes in most state statutes. Because they contain no tobacco leaf and are not inhaled, they often fall outside the explicit definitions of "tobacco product," "e-cigarette," or "vapor product" used in state vending machine restriction statutes. This creates a regulatory gap that is closing rapidly as states move to tax and regulate pouches as alternative nicotine products.
Federal Status
The FDA classifies nicotine pouches as "tobacco products" for regulatory purposes because they contain nicotine derived from tobacco, even though they contain no tobacco leaf. PMTA authorization is required. As of December 2025, only ZYN (authorized January 2025) and On! Plus (authorized December 2025) have received full FDA marketing authorization for nicotine pouches.
Texas: The Regulatory Gap in Action
The Texas vending machine restriction statute applies expressly to "e-cigarettes" as defined. Nicotine pouches are not classified under "e-cigarette," "vapor product," or "tobacco product" in Texas law — provided they contain no tobacco leaf. Under the current statutory framework, there are no vending machine placement restrictions specific to nicotine pouches, no excise tax on nicotine pouches, and no special retail or vending permit required beyond a standard Sales & Use Tax Permit from the Texas Comptroller.
However, this gap is actively contested: the Texas Comptroller challenged whether nicotine pouches should be taxed under existing tobacco tax law. The Texas Supreme Court is reviewing the matter as of mid-2025. Operators should monitor the outcome of that case.
State Taxation — 2025–2026 Developments
| State | Tax / Requirement | Effective |
|---|---|---|
| Washington | 95% tax on the taxable sales price of nicotine products including nicotine pouches, e-cigarettes, and vapor liquids. | January 1, 2026 |
| Kentucky | Tobacco, nicotine, or vapor product license required ($500). Random inspections. Applies to nicotine pouches. Note: stringent vape-specific restrictions from 2025 do not yet apply to pouches. | January 1, 2026 |
| Nebraska | New or increased tax on nicotine and tobacco products enacted in 2025 session. | Varies |
| Alabama | New excise tax on consumable vapor products enacted 2025. | 2025 |
| Hawaii | Increased state cigarette tax; 50% wholesale tax on vaping products. Annual license required ($1,000). | 2025 |
| Indiana | Increased taxes on cigarettes, other tobacco products, alternative nicotine products, and closed-system vapor cartridges. | 2025 |
In 2025, at least 20 states introduced bills to levy excise taxes on nicotine pouches, and several enacted new or updated tax structures. In 2026, states that do not currently tax vapor products or nicotine pouches are expected to introduce legislation. The FDA's nicotine pouch PMTA pilot program is accelerating the authorization pipeline, which will in turn make it easier for states to build registry-style authorization conditions around pouches as they have for e-cigarettes.
2026 Legislative & Regulatory Outlook
Forty-six states will hold legislative sessions in 2026. The following trends are expected to dominate the tobacco and nicotine vending regulatory landscape:
1. Continued Registry Expansion
The vapor product directory trend shows no signs of abating, with registry bills advancing in Georgia, North Dakota, South Carolina, Tennessee (now enacted), and Texas. The Fourth Circuit's ruling in Vapor Technology Association v. Wooten (North Carolina case) will determine whether federal preemption arguments can halt this expansion in a significant number of states.
2. Excise Tax Increases
In 2025, 10 states enacted new or increased tobacco and nicotine product excise taxes — a higher rate than in recent years. Budget pressures in 2026 are expected to drive additional states to impose excise taxes on vapor products and nicotine pouches. States that currently do not tax these products are at particular risk of new legislation.
3. Flavor Ban Expansion
Approximately 15 states are expected to consider some form of flavored tobacco and nicotine product ban in 2026. Local ordinance activity is expected to continue growing, with major metropolitan areas implementing municipal-level flavor restrictions. The NATO is leading advocacy in Massachusetts opposing "nicotine-free generation" proposals that would ban tobacco and nicotine product sales to anyone born after a fixed date.
4. Federal Enforcement of Illicit Vapes
The Trump administration's enforcement posture toward illicit vape imports from China — particularly unauthorized disposable devices — is expected to intensify in 2026. Congress directed FDA to allocate $200 million for enforcement in FY2026, and a multi-agency task force comprising FDA, DOJ, and DHS is expected to expand coordination on port-of-entry interdiction. State AGs are expected to continue bringing parallel enforcement actions, with preemption arguments remaining a significant variable.
5. FDA Transparency and PMTA Pipeline
The FDA has committed to increased transparency in 2026, with Center for Tobacco Products officials attending industry conferences and engaging directly with nicotine pouch PMTA applicants under the pilot program. Brands participating in the pilot — including FRE, ALP, VELO, and On! — may receive marketing authorizations in 2026, expanding the pool of registry-eligible products.
References & Authorities
Federal Statutes & Regulations
- Family Smoking Prevention and Tobacco Control Act, Pub. L. No. 111-31, 21 U.S.C. § 387 et seq. (2009)
- Consolidated Appropriations Act of 2020 (Tobacco 21), Pub. L. No. 116-94, amending 21 U.S.C. § 387f(d)(5)
- 21 C.F.R. § 1140.16 — Vending Machine Restrictions (FDA)
- 21 U.S.C. § 910 — Premarket Review of New Tobacco Products (PMTA)
- PACT Act — Prevent All Cigarette Trafficking Act, 15 U.S.C. § 375 et seq.
State Statutes — Cited Herein
- Cal. Bus. & Prof. Code §§ 22960, 22972 (2025)
- Minn. Stat. § 609.685, subdiv. 1(c) (2025)
- N.Y. Pub. Health Law §§ 1399-aa(13), 1399-aa(17), 1399-cc(1)(e), 1399-cc(7), 1399-dd, 1399-mm-1(2), 1399-mm-2(1), 1399-ll, 1399-bb(1), 1701(1) (2025)
- N.Y. Tax Law § 1181 (2025)
- N.Y. Gen. Bus. Law § 399-gg(1) (2025)
- Tex. Health & Safety Code § 161.086 (2025)
- Tex. SB 2024, 89th Leg., R.S. (2025) (effective September 1, 2025)
- Va. Code Ann. §§ 18.2-246.8(B), 18.2-371.2(A), (B), (D), (F), (I), 58.1-1021.01, 58.1-1021.02, 58.1-1021.04:1(C)(1), 59.1-293.10, 59.1-293.11(A), 59.1-293.17(D), 59.1-293.20(A)–(D) (2025)
- Va. Admin. Code § 10-210-6041
- Tenn. SB 1301 / HB 1415 (2025), codified as Tenn. Code Ann. § 57-4-101 et seq.
- North Carolina Session Law 2024-49
- Ala. Code § 28-11-14 et seq.
Case Law
- Nova Distro, Inc., et al. v. Miyares et al., No. 3:25-cv-857 (E.D. Va.) (Preliminary Injunction granted Dec. 18, 2025)
- Vapor Technology Association, et al. v. Wooten et al., No. 25-1745 (4th Cir.) (oral argument Jan. 29, 2026)
- Ohio ex rel. Yost v. Central Tobacco & Stuff Inc., No. 24-CVH-070664 (Ohio Ct. C.P. Oct. 29, 2024)
- Ohio ex rel. Yost v. Orrville Tobacco & Vape Shop LLC, No. 2024-CVC-H-0327 (Ohio Ct. C.P. Feb. 5, 2025)
- Ohio v. Elevate Smoke LLC, No. A2403034 (Ohio Ct. C.P. Feb. 20, 2025)
- State of Minnesota v. Venture Concepts Grp. LLC dba High Light Vape Co., No. 62-CV-25-382 (Minn. Dist. Ct.) (consent judgment April 2025)
- People of N.Y. v. G-Smoke360 Corp., No. EF2025-112607 (N.Y. Sup. Ct., Herkimer Cty.) (filed Jan. 16, 2025)
- Illinois v. Chicago Merchandise Co., No. 2025CH00422 (Ill. Cir. Ct.)
- City & Cty. of San Francisco v. Bass Gift Shop SF, et al., CGC-24-618016 (S.F. Superior Ct.) (consent judgment March 3, 2025)
Secondary Authorities & Government Sources
- Public Health Law Center — U.S. E-Cigarette Regulations: 50-State Review (updated June 15, 2025), publichealthlawcenter.org
- Campaign for Tobacco-Free Kids — State Court Cases: Illegal Products (updated May 2025), tobaccofreekids.org
- Tobacco Insider — Illegal Vapes Tracker and Tobacco Lawsuits USA (updated March 2026), tobaccoinsider.com
- MultiState Associates — State Tobacco Legislation in 2025: Vaping, Nicotine Pouches, and More (February 5, 2026), multistate.us
- National Association of Tobacco Outlets (NATO) — 2026 Tobacco Regulatory Outlook, as reported in CSP Daily News (January 9, 2026), cspdailynews.com
- Troutman Pepper Locke — Unpacking the Illicit E-Cigarette Crackdown by State AGs, Law360 (March 19, 2025), troutman.com
- Holon Law Partners — Virginia's New Vapor Product Directory: What Retailers and Manufacturers Need to Know (September 9, 2025), holonlaw.com
- Tobacco Law Blog — Federal Court Bars Enforcement of Virginia Vapor Directory (December 24, 2025), tobaccolawblog.com
- Clark Esposito Law — States Intensify Crackdown on Vape Products (October 1, 2025), clarkespositolaw.com
- Prilla — Nicotine Pouch Regulation Roundup 2025 (November 21, 2025); Nicotine Pouch Regulation: New Taxes & Flavor Bans 2026 (February 2, 2026), prilla.com
- VapeTM — Navigating New Vape Regulations: June 2025 Legal Developments; State-by-State Vape Vending Compliance Guide, vapetm.com
- VapeRanger — Vaping Regulations for 2025 in the United States, vaperanger.com
- 13News Now — New Virginia Law Will Soon Ban Certain Vape Products (December 17, 2025), 13newsnow.com
- Duke-UNC TTS — The Rising Wave of State Bans on Disposable Vapes (November 24, 2025), dukeunctts.com
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State by State Laws for Vape Vending