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"Additionally, the proposed rules represent an important step to advance health equity by significantly reducing tobacco-related health disparities." The FDA notes "particularly high rates of use by youth, young adults, and African American and other racial and ethnic groups." The federal government is implicitly denying the moral agency of black people, suggesting that they, like adolescents, are helpless to resist the allure of "predatory marketing" or the appeal of menthol's minty coolness

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There are concerns that these high nicotine concentrations may lead to greater nicotine dependency

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