One of the most important technological developments in the 1990s has been the emergence of biotechnology. Both the draft Protocol on Biosafety under the Convention on Biological Diversity (CBD) and the Agreement on Sanitary and Phytosanitary (SPS) Measures of the World Trade Organization (WTO) could cover trade in biotechnology products. However, each agreement treats the nascent ¡¥precautionary principle¡¦ differently. Trade disputes in living modified organisms will use either agreement, depending on each country¡¦s status in each agreement. Trade and environment agreements aspire to be mutually supportive, but to do so here requires substantial harmonization between the two agreements.