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Though pricing trends have been negative for 11 consecutive periods, we believe it is at least partially due to difficulty in capturing/measuring the different SKUs given the rapidly evolving vapor category and proliferation of vapors/tanks/ mods (VTM) and e-cig/VTM refills, which tend to have a lower retail price/refill, Herzog said in a research note

(Optional, maximum 600 words) Outline any potential unintended consequences of the proposed policy that we have not identified in the impact assessment

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