September 20 2010, at 12:00 AM Eastern Daylight Time
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Comment 12: Prime Time International Company (Deer, James A.)
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Title: Comment 12: Prime Time International Company (Deer, James A.)
Abstract: James A. Deer on behalf of Prime Time Internation Company concludes that the pipe tobacco can be visually distinquished from RYO tobacco in terms of its packaging and its cut, which in the case of pipe toabcco is a broad ribbon which is not suitable for use with rolling paper. The reducing sugars test could supply an objective and scientific measure of the product characteristics, but the addition of this test should occur only after it is verified that pipe tobacco and RYO have significantly different sugar contents. Finally, from the standpoint of a small manufacturer, the ultimate criteria adopted should not involve the companies in a continuous testing regime which would require a laboratory of expensive equipment. Also see the second comment from this company, Comment 164, dated October 24, 2011.
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Attachments:
Comment 12: Prime Time International Company (Deer, James A.)
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