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Thus, in order to assess any user fees on any class of tobacco products beyond the six listed in section 919 of the [FFDCA], FDA would need to demarcate a new set of tobacco product classes among newly deemed tobacco products, and fashion an entirely novel framework for determining class percentage allocations and allocations within each class of tobacco product

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Incomplete coding of F17.210 and Z87.891 is likely to lead to a quality and audit issue

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