Trade and the environment have been in congruence by the treatment of environment‒
harmful subsidies. Several environment‒friendly scholars in the 1990s suggested using
countervailing duties endorsed by the WTO Subsidy Agreement to counteract such harmful
subsidies as a prospective instrument for environmental protection. The United States recently
brought this idea to the WTO; however, the proposal seems not to attract much attention from
other member countries. The article revisits the past debate on the practicability of
countervailing duties for environmental protection through recent developments of the WTO
subsidy law. It is argued that, with the WTO jurisprudence on subsidization by natural resource
exploitation rights, countervailing duties can be employed for natural resource conservation but
not for environmental protection at large; however, there are limitations on the applicability of
this green trade instrument for the conservation purpose. The instrument can be applied to certain
“industrial” natural resources, such as minerals or commercial forests, but may be impractical for
“consumer” natural resources such as fisheries or public grasses.