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10.1016/j.fct.2018.04.015 82

This dual approach allowed V2s brands to build a following among EU snusers before nicotine pouches became common
(D) Any additional actions the plan or issuer is taking to come into compliance with 146.136(c)(4) or this section, when the plan or issuer will take such actions, and a clear and accurate statement explaining whether the Secretary has concurred with those actions

At that point, the FDA deemed that any product not on the market before 2007 had to go through a Pre-Market Tobacco Application (PMTA)
