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However, because the Act only specifically identifies a few descriptors as making such implicit relative-risk claims (e.g., light), manufacturers seem to be operating on the assumption that they are allowed to use descriptors and imagery that are likely to mislead consumers by making implicit reduced-risk claims until substantial enough independent research evidence accumulates to show they are misleading and otherwise violating the law and finally prompt FDA to initiate enforcement action (as occurred with the misleading additive-free and organic descriptors)

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