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Last Reviewed: January 5, 2023

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That decisioneven if it opted to regulate all cigars the samemeant the agency understood there were differences and needed to take those differences into account when making rules and providing the evidence to justify said rules: Once the FDA structured the Proposed Deeming Rule in this way, it became incumbent on the agency to address, if challenged, the propriety of subjecting a defined category of cigar product to a particular form of regulation, articulat[ing] with reasonable clarity its reasons for decision, and identify[ing] the significance of the crucial facts. Greater Bos

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