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Guidance: Child oral health: applying All Our Health

(d) A substitute food is one that may be used interchangeably with another food that it resembles, i.e., that it is organoleptically, physically, and functionally (including shelf life) similar to, and that it is not nutritionally inferior to unless it is labeled as an imitation. (1) If there is a difference in performance characteristics that materially limits the use of the food, the food may still be considered a substitute if the label includes a disclaimer adjacent to the most prominent claim as defined in paragraph (j)(2)(iii) of this section, informing the consumer of such difference (e.g., not recommended for frying)

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A menthol ban in the United States would likely have a larger impact, particularly among Black smokers

Why do smokers want to quit

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