Under this reasoning, it seems to follow that most Hemp-CBD smokable products, which are free of nicotine and tobacco, would not be considered tobacco products. The newly published Guidance seems consistent with this rationale
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It heats tobacco rather than burning it, which changes the taste, the aerosol, and the overall sensory experience
A large premium cigar does contain naturally occurring chemicals, and nicotine, perhaps as much as a pack of cigarettes, but that cigar is not generally inhaled
July 1, 1985
Chaffee et al., Flavored Tobacco Product Use Among California Adolescents Before and Immediately After a Statewide Flavor Ban, Nicotine and Tobacco Research 27, no