are the most toxic way to smoke tobacco Chemicals in Cigarettes and Tobacco: What's Burning? High-puff e-cigarettes may become more

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"RJRV has adduced evidence that the FDA has effectively banned all non-tobacco-flavored e-cigarettes, pursuant to its new and secret heightened evidentiary standard," Jones writes, "without affording affected persons any notice or the opportunity for public comment." The question of whether that de facto ban qualifies as a "substantive rule" is "not a close call," the 5th Circuit says