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However, the evidence presented by PMI indicates that the IQOS labelling or advertising will not ensure accurate consumer perceptions of risk, smokers will not understand they would need to switch completely to IQOS to secure the purported benefits, and consumers will likely view the reduced-exposure claims as reduced-risk claims, rendering them inherently misleading.27 50 51 Independent research also demonstrates that adults and adolescents misinterpret reduced-exposure claims as communicating lower risk even when there is no explicit claim of lower risk.52 TPSAC also found that PMI failed to demonstrate that consumers would accurately understand the risks of IQOS as conveyed in PMIs proposed MRTP labelling and advertising.13 If PMI cannot revise its application to demonstrate that marketing IQOS would actually be appropriate for the protection of the public health and its proposed labelling would not be misleading, FDA would be required by statute to deny PMIs applications, and PMI would not be permitted to market IQOS with or without any related modified-risk claims

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A change can start today