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If a new tobacco product is considered substantially equivalent to the predicate tobacco product, the manufacturer is required to submit an SE report to FDA justifying a substantial equivalence claim at least 90 days prior to the introduction of the new tobacco product into the market

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"You're either using sugar as a neutral sweetener to help tone down acidity, or you're using something like molasses that is actually an acidic sweetener to tone down alkalinity." The flavor is so incorporated into the leaf that it becomes part of the tobacco's flavor

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