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The Appellate Body began its analysis by "consider[ing] Article 2.1 as a whole in its context and in light of the object and purpose of the TBT Agreement." 29 The Appellate Body focused on the Preamble of the TBT, in particular, the second, fifth, and sixth recitals

However, as the devices are not regulated, the amount of nicotine delivered by e-cigarettes varies widely, Steinberg said