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Distributing a free tenth vial of e-liquid with either the ninth or eleventh purchase would not violate the free sample ban because it would effectively amount to a discount that is part of a sales transaction requiring monetary payment, not a free sample, the FDA guidance states

Puff Bar has become the most popular disposable vape brand with its wide variety of flavors and sleek design

Most users find they save between 50% and 70% on their weekly nicotine budget by making the switch to vaping

Near-term priorities Implement flavor restrictions for all tobacco products at the federal level Restrict points of sale Reduce nicotine levels in combustible tobacco products Improve cessation access Medium-term to long-term priorities Cap nicotine levels and delivery in all tobacco and nicotine products Develop new cessation interventions Phase out sales to younger generations Restrict commercial sales of cigarettes and some/all other smoked tobacco products Important considerations for these strategies Before these types of policies can be implemented, critical considerations must be taken into account to ensure success of these policies and to reduce unintended consequences