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Must the designated individual disclose the identity of its clients when submitting an Ingredient Report and/or Nicotine Report?

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Must the designated individual disclose the identity of its clients when submitting an Ingredient Report and/or Nicotine Report?

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Yes. Under 15 U.S.C. Section 1335a(a) of FCLAA and 15 U.S.C. Section 4403(a)(2) of CSTHEA a person or group of persons required to provide a list of ingredients and a specification of the quantity of nicotine may designate an individual or entity to provide the above-referenced lists required by these federal laws. In the event that another individual or entity is designated to submit the required information, such as an attorney acting on behalf of a manufacturer or importer; or a manufacturer acting on behalf of an importer, that individual or entity should clearly state the name of the company for whom the information is being submitted.

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