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BAT justified not complying with the requirement on the grounds that the EC labelling directive implemented from the beginning of 1992 is complicated, convoluted and confusing, and the simpler approach of placing a general warning in the traditional place (side of packet) is more appropriate. 77 Of those 58 countries, mostly in Africa and in Latin America, with foreign language HWLs in 1992, only five had replaced them with mandatory HWLs before 2007 when FCTC began to take effect (figure 4)

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