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Barylko-Pikielna N, Pangborn R M, Shannon I L

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The 2009 Family Smoking Prevention and Tobacco Control Act (TCA) charges the FDA with only allowing e-cigarettes on the market when manufacturers can prove their tobacco-based products are appropriate for the protection of public health. But the FDA delayed enforcing the law until a federal court order required companies to submit pre-market approval applications to the agency before September 2020 in order to continue selling e-cigarettes to consumers