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The paper Cigarette Taxes and Illicit Trade in Europe claims that a one-euro increase in tax per pack in a country is expected to increase illicit market share by 5 to 12 percentage points and increase illicit cigarette sales by 25% to 120% of the average consumption

63 Under pressure from diverse environmental campaigns, mass conversion of broadleaf woodlands to coniferous plantations has been put to a halt, and even somewhat reversed: as a consequence, the planting of broadleaves has increased dramatically

The rule is also entirely consistent with what Congress required in the 2009 Family Smoking Prevention and Tobacco Control Act