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Indeed, the guidelines for implementation of Article 11 and Article 13 of the FCTC only state that parties should consider plain packaging. Emphasizing the clearly non-binding character of the instruments relevant articles, he said that despite that fact WHO and tobacco control advocates continue misinterpreting FCTC guidelines to put pressure on parties to introduce excessive measures. He added that this was why some countries may feel they are under an obligation to implement the suggested provisions, including plain packaging