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12 , 13 , 14 However, it should be emphasised that most studies included in these systematic reviews are observational in nature

The undersigned public health, medical, civil righs and community organizations conclude that the Draft Guidance fails to recognize the well-established history of signficant variations in youth flavor preferences over time, often caused by regulatory decisions, and this fundamental flaw threatens to open the regulatory door to a wide array of FDA-authorized products that would appeal and be accessible to youth, without signficant countervailing health benefits to adults who smoke

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