UNITED STATES - STANDARDS FOR REFORMULATED
AND
CONVENTIONAL GASOLINE
Appellate
Body Report and Panel Report
Action
by the Dispute Settlement Body
At
its meeting on 20 May 1996, the Dispute Settlement Body adopted the attached
Appellate Body report on "United States - Standards for Reformulated and
Conventional Gasoline" (WT/DS2/AB/R) and the attached panel report on
"United States - Standards for Reformulated and Conventional
Gasoline" (WT/DS2/R) as modified by the Appellate Body report. The panel report should therefore be read in
conjunction with the Appellate Body report.
Both
reports have been derestricted upon their adoption by the Dispute Settlement
Body.
United States - Standards for Reformulated
and
Conventional Gasoline
AB-1996-1
Report
of the Appellate Body
World
Trade Organization
Appellate
Body
|
United States - Standards for Reformulated and Conventional Gasoline United States, Appellant Brazil Venezuela, Appellees European Communities Norway, Third Participants |
AB-1996-1 Present: Feliciano,
Presiding Member Matsushita, Member |
I. Introductory
The
United States appeals from certain conclusions on issues of law and certain
legal interpretations contained in the Panel Report, United States - Standards for Reformulated and Conventional Gasoline,
WT/DS2/R, 29 January 1996 (the "Panel Report"). That Panel had been established to consider
a dispute between the United States, on the one hand, and Venezuela, later
joined by Brazil, on the other. The
dispute related to the implementation by the United States of its domestic
legislation known as the Clean Air Act of 1990 (the "CAA") and, more
specifically, to the regulation enacted by the United States' Environmental
Protection Agency (the "EPA") pursuant to that Act, to control toxic
and other pollution caused by the combustion of gasoline manufactured in or
imported into the United States.
This regulation is formally entitled "Regulation of Fuels and Fuel Additives - Standards for Reformulated and
Conventional Gasoline", Part 80 of Title 40 of the Code of Federal
Regulations, and is commonly referred to as the Gasoline Rule.
II. Issues
Raised In This Appeal
A. The Claims of Error by the United
States
It
is important to focus upon the subject matter of this appeal. We seek to do this first by identifying the
issues which have been raised by the Appellant, the United States. In what follows we highlight those same
issues by listing certain other issues dealt with in the Panel proceedings but
which have not been brought before
the Appellate Body in this appeal, and which we accordingly exclude from
consideration in this Appellate Report.
In
its Notice of Appeal, dated 21 February 1996, and its Appellant's Submission,
dated 4 March 1996, the United States claims that the Panel erred in law,
firstly, in holding that the baseline establishment rules of the Gasoline Rule
are not justified under Article XX(g) of the General Agreement and, secondly, in its interpretation of
Article XX as a whole.
More
specifically, the United States assigns as error the ruling of the Panel that
the baseline establishment rules do not constitute a "measure"
"relating to" the conservation of clean air within the meaning of
Article XX(g) of the General
Agreement. Consequently, it is also
the view of the United States that the Panel erred in failing to proceed
further in its interpretation and application of Article XX(g), and in not
finding that the baseline establishment rules satisfy the other requirements of
Article XX(g) and the introductory provisions of Article XX.
The
sharply limited scope of this appeal is underscored by noting the number of
findings which the Panel had made but which have not been appealed from by the
United States. Very briefly, the United
States does not appeal from the findings or rulings made by the Panel on, or in
respect of, the consistency of the baseline establishment rules with
Article I:1, Article III:1, Article III:4, and
Article XXIII:1(b) of the General
Agreement and the applicability of Article XX(b) and
Article XX(d) of the General
Agreement and of the TBT Agreement. Understandably, the United States has also
not appealed from the Panel's ruling that clean air is an exhaustible
natural resource within the meaning of Article XX(g) of the General Agreement.
V. FINDINGS AND CONCLUSIONS
For
the reasons set out in the preceding sections of this report, the Appellate
Body has reached the following conclusions:
(a) the Panel erred in law in its conclusion
that the baseline establishment rules contained in Part 80 of Title 40 of the
Code of Federal Regulations did not fall within the terms of Article XX(g) of
the General Agreement;
(b) the Panel accordingly also erred in law
in failing to decide whether the baseline establishment rules contained in Part
80 of Title 40 of the Code of Federal Regulations fell within the ambit of the
chapeau of Article XX of the General
Agreement;
(c) the baseline establishment rules
contained in Part 80 of Title 40 of the Code of Federal Regulations fail to
meet the requirements of the chapeau of Article XX of the General Agreement, and accordingly are not justified under
Article XX of the General Agreement.
The
foregoing legal conclusions modify the conclusions of the Panel as set out in
paragraph 8.1 of its Report. The Appellate Body's conclusions leave intact
the conclusions of the Panel that were not the subject of appeal.
The
Appellate Body recommends that the
Dispute Settlement Body request the United States to bring the baseline
establishment rules contained in Part 80 of Title 40 of the Code of Federal
Regulations into conformity with its obligations under the General Agreement.
It
is of some importance that the Appellate Body point out what this does not mean. It does not mean, or imply, that the ability of any WTO Member to
take measures to control air pollution or, more generally, to protect the
environment, is at issue. That would be
to ignore the fact that Article XX of the General Agreement contains provisions designed to permit important
state interests - including the protection of human health, as well as the
conservation of exhaustible natural resources - to find expression. The provisions of Article XX were not
changed as a result of the Uruguay Round of Multilateral Trade
Negotiations. Indeed, in the preamble
to the WTO Agreement and in the Decision on Trade and Environment, there
is specific acknowledgement to be found about the importance of coordinating
policies on trade and the environment.
WTO Members have a large measure of autonomy to determine their own
policies on the environment (including its relationship with trade), their
environmental objectives and the environmental legislation they enact and
implement. So far as concerns the WTO,
that autonomy is circumscribed only by the need to respect the requirements of
the General Agreement and the other
covered agreements.
Signed in the original at Geneva
this 22nd day of April 1996 by: