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It is a complicated procedure that lasts up to a year a period during which those cigarettes are still being sold. [C]ompanies use the text of the law, the literal understanding of the words of the law in the directive, and have come up with products that fool you to your face. In Hungary, Romania, and the U.K., JTI has admitted to concerned health officials that their products do contain menthol, but insisted the cigarettes lack a characterizing flavor, essentially daring them to prove otherwise