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SHIGEYes, it is

Noting that Article 31(3)(a) of the Vienna Convention does not specify a form that a subsequent agreement must take, the Appellate Body stated that Article 5.2 "can be characterized as a 'subsequent agreement' provided that it clearly expresses a common understanding, and an acceptance of that understanding among Members with regard to the meaning of the term 'reasonable interval.'" 117 Because paragraph 5.2 of the Doha Ministerial Decision provides that "reasonable interval" in Article 2.12 of the TBT Agreement "shall be understood to mean" not less than six months, the Appellate Body concluded that paragraph 5.2 was a subsequent agreement on the meaning of "reasonable interval" within Article 31(3)(a) of the Vienna Convention

doi: 10.26719/emhj.22.001 19

As in any other market, as taxes or sales restrictions on licit products rise, substitution of illicit sources by some users should be expected, although the sensitivity to taxation of illicit trade in e-cigarette products has not been explored yet

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