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While the argument around this is that plain packaging is the ultimate form an encumbrance, in its complete suppression, and the Article, mentioning a non-exhaustive list, could perhaps include plain packaging as an encumbrance under it

People know that its the leading cause of preventable diseases in the US, and its link to many types of cancer is undeniable

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Although these products have not been used by consumers for a sufficient period of time to develop definitive scientific conclusions about their level of risk reduction, there is a growing body of scientific evidence that these products may present less risk than smoking