This Note has been prepared in response to a request from the Committee on Trade and
Environment for factual background information on GATT/WTO dispute settlement practice relating
to the application of Article XX to environmental measures. The Note is an updated and revised
version of document WT/CTE/W/53/Rev.1. An outline of the structure of this Note is provided at the
end of the document. The Note focuses on paragraphs (b), (d) and (g) of GATT Article XX, which
are the three exceptions usually referred to in so-called "environmental" disputes, the latter term being
understood in a broad sense as covering disputes relating to the protection of the environment, as
such, and also the protection of human health. The Note is limited to environmental disputes
involving Article XX and therefore excludes health cases brought under the Agreement on the
Application of Sanitary and Phytosanitary Measures (SPS).