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Additionally, plastic pollution is projected to outweigh all fish in the ocean by 2050 if no significant action is taken

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A sizable literature of peer-reviewed academic studies supports these observations.[11] A 2017 study published in Public Finance Review provides the academic theory and estimates for how tax rates affect smuggling, highlighting that easily transportable goods (e.g., cigarettes) will be attractive cross-border shopping items.[12] A 2018 study published in the same journal supported those findings by examining littered packs of cigarettes across 132 communities in 38 states, finding that 21 percent of packs did not have proper local stamps.[13] In addition to high taxes, the study found that bans on flavored cigarettes in Massachusetts and California have sent smuggling to new heights

68 Next, the Appellate Body considered Article 2.2 of the TBT Agreement: "Members shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade