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The report of the WTO Appellate Body in the shrimp-turtle case may prove to be of fundamental importance for the development of the GATT/WTO system. It asserts that a WTO member can unilaterally condition access to its market on compliance with environmental policies, as long as the regulations are administered in an even-handed manner and do not amount to disguised protectionism. Will the incidence of unilateral trade measures increase dramatically as a result of this decision?

The use of non-tariff barriers to trade, which began to be important in the 1970s, has continued to increase throughout the 1980s. Notwithstanding the difficulties and limitations it faces, the Uruguay Round probably presents the only present opportunity of coming to grips with many existing exemptions to, and distortions of, GATT rules.