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193 FDA contracted with the Institute of Medicine (now known as the National Academy of Medicine), and concluded in 2015 that "increasing the minimum age of legal access to tobacco products will likely prevent or delay the initiation of tobacco use by adolescents and young adults the impact on initiation of tobacco use of raising the minimum age of legal access to tobacco products to 21 will likely be substantially higher than raising it to 19, but the added effect of raising the minimum age of legal access beyond age 21 to age 25 will likely be considerably smaller." 194 While the FFDCA authorizes FDA to establish, by regulation, restrictions on the sale and distribution of tobacco products, the agency is prohibited from establishing a federal minimum age that is greater than 18

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