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VIII - ARTICLE XX(g) OF THE GATT 1994

from CHINA – MEASURES RELATED TO THE EXPORTATION OF VARIOUS RAW MATERIALS

Published online by Cambridge University Press:  03 January 2018

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345. China alleges that the Panel erred in interpreting the phrase “made effective in conjunction with” in Article XX(g) to mean that restrictions on domestic production or consumption must “be applied jointly with the challenged export restrictions”, and that “the purpose of those export restrictions must be to ensure the effectiveness of those domestic restrictions”.

The Panel's Findings and Arguments on Appeal

346. The Panel found that China's export quota on refractory-grade bauxite is inconsistent with Article XI:1 of the GATT 1994. China sought to justify this export quota pursuant to Article XX(g) of the GATT 1994, arguing that refractory-grade bauxite is an exhaustible natural resource that is scarce and requires protection.

347. The Panel first addressed the question of whether China's export quota relates to the conservation of refractory-grade bauxite. Based on its review of the evidence and arguments before it, the Panel found this not to be the case. The Panel nevertheless continued its analysis in order to determine whether the export quota on refractory-grade bauxite was “made effective in conjunction with” restrictions on domestic production or consumption, as required under Article XX(g) of the GATT 1994.

348. The Panel considered that, in order for a measure to be justified under Article XX(g), the measure must satisfy two conditions: (i) it must relate to the conservation of an exhaustible natural resource; and (ii) it must be made effective in conjunction with restrictions on domestic production or consumption.

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Publisher: Cambridge University Press
Print publication year: 2014

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