The decision of the second GATT panel in theTuna/Dolphin dispute again focuses attention onthe perceived conflict between the goah of trade liberalization andnational and international efforts to protect the earth’s naturalenvironment. The author reviews the reasoning of the panel inTuna/Dolphin II, compares it with that of Tuna/Dolphin I, andconsiders the adequacy of GATT law to deal with environmentalconcerns. Although he criticizes some of the reasoning of the panelsin the two tuna/dolphin cases, the author argues that the reports doprovide — though inferentially — a coherent approach for judging theGATT-legality of environmental trade measures that stem frominternational multilateral agreements.