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She adds that the FDA "failed to consider relevant evidence, inter alia, that youthful users do not like menthol-flavored e-cigarettes" and that it has "created a de facto rule banning all non-tobacco-flavored e-cigarettes without following APA notice and comment requirements." To pass muster with the FDA, applicants must demonstrate that approval of their products is "appropriate for the protection of the public health"the nebulous standard prescribed by the 2009 Family Smoking Prevention and Tobacco Control Act

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