The proponents of the sustainable use of natural resources should not take a black or white view of the wildlife trade. Unlike the preservationists within CITES, who see no positive role for trade, advocates of sustainable use recognize that, in the appropriate circumstances, trade can play a beneficial role. At the same time, however, they must acknowledge that the regulation of the wildlife trade is important if conservationist goals are to be achieved.

Given this nuanced perspective on the connections between trade and conservation, a commitment to sustainable use does not issue directly in a specific view of the appropriate relationship between CITES and WTO. While many advocates of sustainable use would hold that CITES has not shifted sufficiently from its anti-trade starting point, it does not follow that the solution must be to make CITES subordinate to the trade liberalizing stance of WTO. Since decisions about the application of trade measures to the wildlife trade are best made not on the basis of an a priori opposition to or support of trade liberalization, but in the light of the circumstances prevailing in the individual case, there is a case for thinking that CITES should retain some autonomy in making decisions about which trade measures to apply. This position can be consistently combined with pressing the case for CITES' continued evolution in the direction of support for sustainable use.

On the other hand, if CITES is to play a role in promoting the constructive utilization of wildlife, it is important that decisions are taken on a multilateral rather than a unilateral basis. As has been seen, the decisions of the WTO dispute panels have typically expressed support for multilateral decision making. Nevertheless, there remains some ambiguity about the distinction between multilateral and unilateral measures. CITES is a multi-lateral treaty that allows scope for unilateral measures. It is, therefore, equally unattractive for supporters of sustainable use for CITES to be completely exempt from any of the provisions of the WTO in a way which entirely removes the possibility of any appeal to the WTO's dispute settlement mechanism.

In light of these comments, and in view of the analysis made in this paper the following conclusions are drawn as to the best approach for resource-dependent countries to the relationship between the WTO and MEAs such as CITES.