世界贸易组织(WTO)和欧洲联盟(EU)在贸易法规方面存在着明显的不同。WTO法与欧盟法关系上最有争议的方面就是欧盟否认WTO法的直接适用。一方面,欧洲法院经常主张GATT/WTO法不能在欧洲法律体系内直接适用,法院在许多案件中贯穿了这一原则。但另一方面,当认识到WTO法在一定程度上能约束其成员国尽快融入欧盟法律体系时,欧洲法院在某些案件的处理上又承认WTO法的直接效力。因此,WTO法、欧盟法和成员国国内法之间的冲突不断增加,如何减少冲突日益成为值得关注的问题。 There is a clear difference in trade laws between the World Trade Organization (WTO) and the European Union (EU). The most controversial aspect of the relationship between WTO law and EU law is that the EU denies the direct application of the WTO law. On the one hand, the European Court of Justice often maintains that the GATT / WTO law can not be directly applied within the European legal system, and that the court runs through this principle in many cases. On the other hand, when recognizing that the WTO law can restrain its member states from being incorporated into the EU legal system as soon as possible, the European Court of Justice also recognizes the direct validity of the WTO law in some cases. Therefore, the conflicts between the WTO law, the EU law and the domestic laws of the Member States are constantly increasing. How to reduce the conflicts has become an issue worth paying attention to.