Restriction of international trade is possible in a few different ways with GATT and SPS Agreement taken into account. Restrictive measures can thus be based first on multilateral agreement, among which the loose Protocol of Cartagena would be the only one in GMO field, second on international standards which are not established in this field, or third based on scientifically justified risk assessment for which sufficient evidence of actual risk was yet not obtained. Popular precautionary principle despite efforts from European union cannot find its way into international legal sphere while countries cannot find common ground due to excessive differences in understanding of the GMO concept and subsequently national rules on authorization and labeling. International environment has long been governed by status quo in this field, whereas countries each create their own rules on GMO. Due to this fact the DSB practice opens the door to national legislation with extraterritorial effects, which could substitute the lack of international regulation.