19 Charnovitz (2003a). 20 For a full explanation of the legal issues, see Charnovitz (2003a). Also Michael Weinstein, “Greens and Globalization: Declaring Defeat in the Face of Victory,” NY Times, April 22, 2001. Charnovitz and Weinstein (2001) argue that the environmentalists fail to realize the progress they have made in recent WTO panel cases, and may thereby miss an opportunity to consolidate those gains. It is not only environmentalists who are under the impression that the GATT rules do not allow PPMs. Some developing countries also claim that PPMs violate the GATT. The motive of the first group is to fight the GATT, while the motive of the second group is to fight PPMs. 21 A system for labeling tuna in the US market as either “dolphin safe” or not was later found consistent with the GATT. The American consumer response turned out to be sufficiently great to accomplish the desired cessation of non-dolphin-safe imports.
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