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10 Step 1: Estimate illicit tobacco arriving through importation Step 2: Estimate the size of domestic chop-chop cultivation Step 3: Analyse the licensed warehouse system Step 4: Compare total illicit amounts to legal clearances Step 5: Deduct seizures to determine net gap The findings of the ATOs latest independent assessment of the extent of use of illicit tobacco in Australia is presented in Table 13A.5.3

167 If retailers have repeated violations of the restrictions on the sale and distribution of tobacco products, FDA may seek a NTSO, which would prohibit sale of tobacco products at that retail outlet

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