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[17] Estimates put Chinese counterfeit production as high as 400 billion cigarettes per year to meet international demand.[18] Because of the enormous volume of product that ships into US ports from China, it may be easier and lower cost to smuggle Chinese cigarettes into California markets through US ports than to try to capitalize on tax arbitrage by transporting products across the continental US

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In 2009, when Congress banned flavored cigarettes as criminal enticements to encourage youth smoking, menthol cigarettes were also slated to be banned