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I find it quite ironic that the health groups, including CDC and FDA, are undermining the efforts of even tobacco companies to develop the non-combustible market and shift a proportion of their sales from combustible to non-combustible products. And the CDC and FDA are completely undermining the efforts of the non-tobacco-related e-cigarette companies to promote e-cigarettes over real tobacco cigarettes.

Because products are substantially equivalent only if they pose no different issues of public health, and because flavorings can affect product efficacy and safety, it is probable that every different flavor of every different brand must submit a separate application. Thus, at a minimum, there are going to be at least 466 x 49 applications, or 22,834 required applications.


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