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Again from the FDA Guidance for Tobacco Retailers documentation: "In determining whether to impose the NTSO or reduce the period of time FDA seeks to impose in the NTSO, FDA will generally consider whether a retailer has taken effective steps to prevent the sale of tobacco products in violation of the minimum age requirements, including: adopting and enforcing a written policy against sales to minors

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In that dispute, Altria (operating under a licensing agreement with IQOS manufacturer Philip Morris International) was forced by the ITC to stop selling imported IQOS devices