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On July 8, 2016, an arbitral tribunal constituted under the auspices of the International Centre for Settlement of Investment Disputes (ICSID) issued an award finding Uruguay had not violated the Switzerland-Uruguay bilateral investment treaty (BIT) by enacting tobacco-control measures designed to protect public health. According to a news report, tobacco company Philip Morris International initiated the arbitration, “seeking compensation for economic damages caused by the nation's anti-tobacco measures,” which included a ban on smoking in public places, raising taxes on tobacco products, prohibiting the use of terms such as “mild” and “light,” as well as mandating large warnings and graphic pictures on cigarette packages. The Tribunal found that the adoption of the legislation “was a valid exercise of the State’s police powers, with the consequence of defeating the claim for expropriation under . . . the BIT.” The Tribunal further noted that the legislative action was a “bona fide” exercise of the government’s police powers, stressing that “in order for a State’s action in exercise of regulatory powers not to constitute indirect expropriation, the action has to comply with certain conditions . . . [such as] that the action must be taken bona fide for the purpose of protecting the public welfare, must be non-discriminatory and proportionate.” The tribunal also declined to find a violation of the fair and equitable treatment provision of the treaty, deciding that states enjoy a “margin of appreciation” under BITs in the context of public health legislation, and acknowledged that “[t]he responsibility for public health measures rests with the government and investment tribunals should pay great deference to governmental judgments of national needs in matters such as the protection of public health.” It concluded that “changes to general legislation (at least in the absence of a stabilization clause) are not prevented by the fair and equitable treatment standard if they do not exceed the exercise of the host State’s normal regulatory power in the pursuance of a public interest and do not modify the regulatory framework relied upon by the investor at the time of its investment ‘outside of the acceptable margin of change.’”