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For example, the FDA has recently announced its intent to ban the sale of menthol cigarettes nationwide.[11] If the lesson out of Massachusetts is any indication, such a ban, which would criminalize the sale of over a third of the current national market, could have a massive impact on revenue generation.[12] Massachusetts has collected roughly 25 percent less revenue since imposing a menthol ban in June 2020,[13] and while Massachusetts has to contend with smuggling of menthol cigarettes from other states where they are still legal, a federal ban would likely lead to a rise in international smuggling of menthol cigarettes