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A controlled study compared tobacco cigarettes, e-cigarettes, and sham smoking

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(iv) The certifying party shall provide, to an officer or representative duly designated by the Secretary, such qualitative statement of the composition of the flavor or product covered by the certification as may be reasonably expected to enable the Secretary's representatives to determine which relevant raw and finished materials and flavor ingredient records are reasonably necessary to verify the certifications

Failing to declare can result in penalties, confiscation, or both