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17 As mentioned above, Indonesia claimed that the Tobacco Control Act was more trade restrictive than necessary in violation of Article 2.2, but the panel found that Indonesia failed to make its case

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10 However, on closer examination their emission target is only applicable to those under their direct control, and excludes emissions embedded in the purchase of goods and services, transportation and distribution, capital goods, and activities influenced but not controlled by companies 7 10 One reason for this opacity is that it enables tobacco companies to avoid including emissions figures for farmers contracted through third parties, 11 accounting for a significant majority of their activity