Journal of World Trade 37(4): 783–799, 2003.
© 2003 Kluwer Law International. Printed in The Netherlands.
Robert Hudec and Domestic Regulation: The
Resurrection of Aim and Effects
Amelia P ORGES and Joel P. T RACHTMAN*
I. THE PROBLEM OF PROHIBITIONS OF DISCRIMINATION AND
NON-PROTECTIONIST DOMESTIC REGULATION
It is no longer possible to discuss Article III of the General Agreement on Tariffs
and Trade (GATT), or the entire question of discrimination in international trade,
without referring to the work of Robert Hudec. Hudec approached the problem of
defining the national treatment obligation under Article III of GATT with his
customary rigour and insight. His roots in the legal realist movement allowed him to
see great complexity hidden under the relatively simple appearance of the non-
discrimination test, which, after all, is the only restriction on inward-oriented
national measures under the original GATT. His positivism required him to examine
the complexity and nuance offered by each case, in order to understand the factors
that caused the Panel or Appellate Body to decide as it did. His pragmatism, his
practical experience and his concern for the international system caused him to
suggest important limits to the scope of the national treatment obligation—limits
that seem obvious only once we understand the complexity and nuance that he
presented. His positivism also required him to respect the regulatory prerogatives of
states.
Another Hudec hallmark was his inductive and unflinching approach to legal
issues, which started from events as they had happened and asked how theory fit the
facts, including the actions of the government actors in the trading system, rather than
asking how real world data could be shoehorned into what theory would dictate.
Connected to this was his constant concern for how legal outcomes corresponded to
the policy goals that the General Agreement on Tariffs and Trade (GATT)/World
Trade Organization (WTO) legal system was designed to serve. Both made the
system’s servants in governments, in private practice, and in the Secretariat and
Appellate Body his devoted readers.
Although he was a great trade scholar, Hudec, perhaps as a reflection of his personal
modesty, or perhaps simply as a result of his deep understanding of the structure of society,
did not place trade above other values: “The policing activity of domestic regulatory
measures is a delicate task, one that requires reaching an acceptable balance between the
* Amelia Porges is at Sidley, Austin, Brown & Wood LLP, Washington DC; formerly Senior Counsel for
Dispute Settlement, USTR and Senior Legal Officer, GATT Secretariat. Joel P. Trachtman is Professor of
International Law, The Fletcher School of Law & Diplomacy, Tufts University. The views expressed are personal
and not those of any of these organizations.