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Benowitz, N.L., Hukkanen, J., & Jacob, P., 3 rd (2009)

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Nationwide consumption of counterfeit and contraband cigarettes remains at two-year peak level, according to the latest KPMG Report on Illicit Cigarette Consumption in Europe, commissioned by Philip Morris International (PMI)

12 However, it is not always clear whether a product that is derived from tobacco should be regulated as a drug, device, combination product, or a tobacco product (e.g., an ENDS product that makes certain health claims)

Do not give them something that has no backbone