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PMI states that IQOSs tobacco sticks are specifically designed to function with the holder, and refers to IQOS interchangeably as IQOS, the IQOS system, consisting of the tobacco sticks, holder, and charger and as the Tobacco Heating System.7 On its website, PMI markets the three main IQOS components as a singular tobacco product, the IQOS tobacco heating system.54 The fact that HTPs are considered tobacco products under the FCTC is confirmed in several statements issued by the Convention Secretariat.55 In 2016, the FCTC Conference of the Parties (COP), the treatys governing body, stated that All new and emerging tobacco products should be regulated under the WHO FCTC
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