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The FDA would have to follow its rule-making process to execute this Congressional mandate. The persistence of illicit trade creates a paradox for public health officials: While cigarette taxes are designed both to generate revenue and discourage smoking, the study's findings suggest they are high enough that a significant portion of the city's estimated 565,000 adult smokers may be circumventing the price increases meant to push them toward quitting

Therefore, companies started lowering some of the most dangerous among them, such as tar and nicotine