“In summary, the FDA failed to articulate a reasoned basis for requiring warning labels for premium cigars. Despite its professed interest in ‘help[ing] correct current misperceptions about newly deemed products,’ Hr’g Tr. at 61, the agency did not separately consider whether users or prospective users of premium cigars in fact harbor misconceptions about the product or otherwise remain in the dark about the health risks attendant to premium cigar use. Instead, the agency focused only on the general ‘health risks of premium cigars,’ 81 Fed. Reg. at 29,020–27, and assumed that its findings as to the ‘established data on the health effects . . . of traditional large cigars’ are not only ‘applicable to . . . premium cigars, given that they share the same characteristics and are smoked in similar ways,’ 81 Fed. Reg. at 29,020, but also that these health effects are a sufficient basis for requiring warning labels. That approach was inadequate. ‘By failing to analyze’ whether consumers are in fact misinformed or underinformed as to premium cigar health effects, ‘the agency has failed to offer the rational connection between facts and judgment required to pass muster under the arbitrary and capricious standard.’.