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Hatton v. United Kingdom

made them less amenable to cooperation. Assuming that the failure to conserve endangered species is a violation of international law, the use of unilateral measures only as a last resort, after multilateral negotiations have failed or as an emergency measure to preserve the environment during negotiations, would also be consistent with the provisions concerning countermeasures in the new International Law Commission articles on state responsibility. Despite the understandable omissions in the Appellate Body's compliance report, there is no doubt that WTO jurisprudence has taken a decisive turn in the right direction—by fully integrating international trade law into general international law; by interpreting GATT Article XX in accordance with the principles of environmental protection, the conservation of natural resources, and the goal of sustainable development proclaimed in the preamble to the WTO Agreement; and by finally confirming that Article XX may be used to justify trade restrictions taken for environmental purposes, provided that they are applied in a nondiscriminatory manner. In giving due weight to the goal of sustainable development, the Appellate Body has simply made effective the precedence given to policies and measures to protect human, plant, and animal health and life that have been inherent in Article XX from the beginning but that have been almost completely ignored by trade policy specialists. Whether WTO representatives will eventually accept this unexpected new approach remains to be seen, as heretofore they have been reluctant to recognize that international trade cannot be hermetically sealed off from the rest of human activity and its consequences. It now seems clear that any impediment to using trade-restrictive measures to protect the environment or to conserve natural resources stems not from any defect or deficiency in the law, but from political factors and policy preferences of WTO members that have acted as if Article XX and the provisions of international environmental law did not exist. While it is encouraging to know that WTO members have finally agreed to engage in serious negotiations on environmental issues, the results of this endeavor are uncertain, to say the least. In any event, the clear winners in the instant case were the sea turtles, who hopefully will benefit from a variety of new measures and agreements to protect them.