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To make an APPH case against flavored products, the FDA must show that flavors cause vaping uptake AND that the behavioral response to making flavors unavailable legally would not lead to a more harmful pattern of tobacco and nicotine use, for example, smoking or use of unregulated, criminally supplied ENDS

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Availability was determined by three separate proxy measures (number of users as determined by household surveys, number of seizures by law enforcement agencies and estimates of the market size)

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