The debate between free traders and environmentalists has increasingly been drawing global attention throughout the last decade. It centers, generally speaking, around the question of how best to resolve the often conflicting goals of international trade liberalization on the one hand, and an increasing need for global environmental protection on the other. Measures to protect the environment often affect trade between different states, while at the same time trade measures might affect environmental conditions. For example, a country may use trade-restrictive measures, such as tariffs, quotas, or taxes, to protect its own natural resources and environment. It may even go further and use similar measures to protect the global commons or strengthen another state's less efficient environmental controls. The growing recognition of the need to link international trade and environmental issues on a global scale is evidenced by the fact that, for the first time in the history of the General Agreement on Tariffs and Trade (GATT), Uruguay Round participants agreed to include sustainable environmental development as one of the objectives when establishing the World Trade Organization (WTO) in 1994.¹

The political awakening and increasing public concern over the state of our environment has led to a growing number of legal instruments on both national and international levels designed to limit the harm to the environment from human activity. Traditional measures concentrated mainly on end-of-pipe solutions, i.e., they tried to set emission standards and to reduce the amount of pollutants emanating from particular production plants. Many measures adopted in recent years have sought to take a holistic approach and to identify and arrest environmental problems before they actually occur. States started exploring various possibilities of creating economic incentives for specific industries to produce more environmentally friendly products rather than imposing the will of the state on manufacturers. Germany was the first country in the world to put forward the concept of eco-labels in its national environmental plan of 1971.² The so-called Blue Angel program, named after the label showing a blue angel spreading its wings, was finally launched in 1978 and has served as a model for all other efforts of similar character of other countries.³ Since then, eco-labeling programs, i.e., the idea of applying labels to products to inform consumers of their environmentally friendly or damaging character, has become increasingly popular. Their main objective can be described as being "to harness market forces and channel them towards promoting more environmentally friendly patterns of production."⁴ An easily recognizable label informs consumers that a credible board of experts has certified and assessed a certain product's characteristics. By helping the consumer to make an informed purchasing decision and mobilizing the so-called green consumer, manufacturers should be encouraged to change their entire product development process into a more environmentally friendly direction.