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If the proposed rule is adopted, the FDA and others may see in subsequent years empirical evidence to support their contention that establishing and maintaining illicit markets in relevant tobacco products will be challenging, and to the extent that they emerge, it is unlikely they will be significant enough to outweigh the benefits of the product standard. We will post below the Freedom of Information Act request we submitted to U.S

The Wall Street Journal

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Illicit cigarette trafficking via duty free stores is a concern identified by the United States General Accountability Office in its own study, which will be reviewed further below