Exports of tuna from Mexico reached a height of $13 million in 1989 and bottomed out to about $1 million by 1991. This started countless academic and legal papers about “international trade and the environment”. Many international academics accused the United States, a founding member of the “General Agreement on Tariffs and Trade” (GATT) and who has agreed to comply by a set of rules and principles which promote multilateral free trade by restricting the activities of government that interfere with international commerce as imposing their own internal laws and standards of dolphin protection to another country. In 1972, the U.S. Congress passed the Marine Mammal Protection Act (MMPA). The act intended to reduce the dolphin kills "to levels approaching zero" by legally requiring U.S. tuna fishermen to incorporate certain fishing techniques and technology. Furthermore, the act established a permit system, setting a fixed ceiling for dolphin kills and limiting the taking rate for species that were endangered. To ensure that these regulations were adhered to, the MMPA also required U.S. vessels to carry federal observers. Congress appointed the Secretary of Commerce to ensure that the kill rates of the importing countries did not exceed 2 times the taking rate of the U.S. fleet in 1989 and 1.25 times the U.S. rate in 1990. If countries did not meet these standards the Secretary was required to implement a direct tuna embargo. To further ensure compliance with the MMPA's Direct Embargo Provision, Congress included the Intermediary Nation Provision, the Pelly Amendment, and the Dolphin Protection Consumer Information Act (DPCIA). The Dolphin Protection Consumer Information Act (DPCIA), stated that producers, importers, exporters, distributors, or sellers of tuna products could only include a dolphin safe label if the tuna were harvested in a manner that was not harmful to dolphins. Therefore, tuna caught by tuna purse seiners in the ETP could not be labeled as Dolphin Safe. The State Department and the Commerce Department opposed the embargoes in the interests of good foreign relations. Consequently, Earth Institute filed suit in the Federal District Court in San Francisco against the Commerce Department to ensure that the direct and indirect tuna import bans were enforced. The court ruled in favor of the Institute and directed the government to execute these provisions. The U.S. government appealed this decision, but the Ninth Circuit Court of Appeals unanimously upheld the district courts ruling and on February 22, 1991, ordered the U.S. Commerce Department to enact the embargo against Mexico and any other country that violated the MMPA. The economic impact on the Mexican Tuna Purse Seine industry especially in Ensenada has been so severe that only fleets catering to the local market has survived. Since the 1991 embargo, the rules have changed but it has been too late for the Ensenada tuna purse seine industry. The Declaration of Panama of 1995 called for the U.S. to change its definition of Dolphin-Safe ...