Agency Information Collection Activities: Submission for OMB Review; Comment Request; FTC File No. P14504
As a small single location vape shop owner, I am commenting in regard to the inclusion of "vape shops" and the other smaller retail entities in your data collection effort. I have 3 major points. First is that the labor and financial burden placed on a small single location business such as mine would cause a significant negative impact to my operation. The expenses and labor hours associated with the data request would create a significant loss of staff needed to operate my business and the extra expenses would take several months to recover from. This in turn affects my businesses growth and earnings. I can see this possibly causing even greater harm to newer companies entering the market and the smaller established locations. Secondly, the data collected from a retail establishment such as a "vape shop" would, for the most part, be redundant. Retailers such as myself purchase goods from wholesalers and distributors. If you are already collecting data from these sources, you have already captured the needed data on sales and product movement. The same would hold true for both hardware and the e-liquid. Limiting the data requests to the larger entities that provide products to the end retailers would accomplish your data goals and reduce the burden on the small independent businesses. My last point is in regard to the data collected about marketing. Retail shops market and advertise their shops. In very few instances does a "vape shop" market or advertise for a single product type or brand. How a shop spends advertising funds provides no useful data to health professionals or regulators. This seems like a wasted effort and simply adds additional burdens to small business.