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The Appellate Body stated that this case involved de facto discrimination and drew on jurisprudence developed under Article III:4 of the General Agreement on Tariffs and Trade 1994 (GATT 1994), which is similar to Article 2.1 of the TBT Agreement, to hold that "likeness in Article 2.1 [] is based on the competitive relationship between and among products." The Appellate Body accepted that domestic regulations may legitimately distinguish between products to serve a public health interest

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A single Zyn 3MG pouch delivers less nicotine than a cigarette, while a 6MG pouch can be closer to the nicotine delivery of one or more cigarettes, depending on usage