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Retail employees under 21 years old: Employees under 21 years of age may handle, transport or sell Restricted Products if acting within the scope of employment and if in the presence of the store owner or another employee who is 21 years of age or older

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As the manufacturers of these nicotinamide vape products assert that nicotinamide is the main active ingredient but also claim to have pharmacological activity at nAChRs, the FDA can alternatively categorize these products as a drug and regulate them under the Federal Food, Drug, and Cosmetic Act (FDCA)

"That makes a big difference," Makaroff said