ABSTRACT
Trade remedy measures have always been central issues of the trade policies of East Asian countries, not simply because they have been the primary targets for such measures, but also because those countries have used them more actively in recent years. Accordingly, when East Asian countries join free trade agreements (FTA) races, trade remedy systems often become focal points for FTA negotiations. Considering the fact that China and Taiwan have had relatively little experience in using the World Trade Organization (WTO) trade remedy systems, it is interesting to compare the vast differences between the Korean and Japanese systems. Codification of legally inconsistent practices by formally deleting the 'facilitation of structural adjustment' requirement in FTA safeguard systems should be rectified to prevent further deterioration of the WTO safeguard mechanism. Both the WTO Anti-dumping and Subsidy Agreement specify the non-discrimination principle. The typical FTA bilateral safeguard system has shown two important departures – good and bad – from the WTO Safeguard Agreement.
