Special Report｜CrossBar's High-Puff Vapes Draw Attention on Pennsylvania's 163-Product Directory as Link Between Earlier 1.3mL PMTA Filings and New 13mL Products Remains Unclear

Pennsylvania began enforcing its electronic nicotine delivery system (ENDS) sales restrictions under Act 57 of 2025 on October 19, 2026. The October 18 directory contained 163 product entries from seven manufacturers, dominated by BAT, Altria, Japan Tobacco and JUUL, which together accounted for 112 entries, or about 68.7%. Of the 15 disposable entries, four CrossBar disposable vapes stood out for their 13mL e-liquid capacity, advertised 20,000-puff rating and broad, flattened design — markedly different from the conventional closed-pod systems and compact disposables that make up most of the directory. A Pennsylvania distributor described CrossBar as one of the few directory-listed options resembling contemporary high-puff disposables and said only three businesses hold distribution authorization for the products.

The listing raises a regulatory question, because Pennsylvania's certification framework includes an eligibility pathway linked to qualifying premarket tobacco product applications (PMTAs) submitted to the FDA by September 9, 2020, while CrossBar 20K's capacity and design resemble high-puff formats that became popular several years later. Historical records identify earlier CrossBar products associated with Romo LLC dba CrossBar, each containing 1.3mL of e-liquid and linked to a September 9, 2020 PMTA filing. The newer 13mL CrossBar 20K products are registered by entities including Blue Nine LLC and VR Products I LLC, which also appear in directory records from North Carolina, Virginia, Nebraska, Tennessee and Mississippi. Public documents do not establish whether brand assets or PMTA application rights were transferred from Romo to Blue Nine, or whether the newer products are covered by the historical applications.

A PMTA compliance expert, Mr. K, identified amendments to pending FDA applications and changes in application ownership as possible explanations, noting that FDA permits amendments while PMTAs are under review but does not allow amendments to add new products to an existing application; additional products require a new PMTA. As a documented example of the commercial value of PMTA-related assets, R.J. Reynolds acquired 16 PACHA products and related assets from Charlie's Holdings for $7.5 million in fixed cash across transactions in 2025, though no evidence reviewed by 2Firsts shows CrossBar underwent a comparable ownership transfer. As more states impose product directory requirements, historical PMTA submissions, product-specific eligibility and asset transfer rights are becoming increasingly relevant to corporate strategy and market access in the U.S. vaping industry.

(Source：2Firsts)