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Start from the Information Requirements Specified by Congress and Apply the Least-Burdensome Principle Return to the basic information requirements that Congress specified in the Tobacco Control Act: 41 Health and risk information to demonstrate that the product presents less risk than other tobacco products Product description Manufacturing description Compliance with standards Product samples Labeling samples Other information as required The final item is open-ended, but this should be subject to a strict application of the least-burdensome principle, which has long been enshrined in regulatory executive orders 42 and, more recently, adopted in other FDA centers

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By marketing itself to teenagers as this cool-kid product, they become addicted for a lifetime, which is highly problematic, she says

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