United States - Suspension of Customs Liquidation regarding certain Japanese Consumer Electronic Products

Other titles

United States / Zenith Case
Zenith Radio Corporation vs United States


Third Parties

Products at Issue

Products at issue
Consumer electronic products
Type of product
Product sub-type
Machinery; electrical and electronic equipment

Related disputes


Key legal aspects

Legal basis
  • n.a.
Claims raised
  • GATT Article VI:4
  • GATT Article XVI Ad Note
Defences raised
  • n.a.


Type Working Party
Chairperson E. Farnon (New Zealand)
Other members Representative of Australia, Representative of Brazil, Representative of Canada, Representative of EEC, Representative of India, Representative of Japan, Representative of Malaysia, Representative of Sweden, Representative of Switzerland, Representative of United States, Representative of Yugoslavia


Type Working Party
Legal basis at issue
  • n.a.
Claims at issue
  • GATT Article VI:4
  • GATT Article XVI Ad Note
Defences at issue
  • n.a.
No of Pages (total / legal reasoning) 4
  • -
  • Inconsistency found
  • Inconsistency found
  • -


Request for consultations
  • (01/01/1977)
Request for establishment


Outcome of the proceedings
Report issued
Additional Info L/4508 (06/07/1977) Report of the Working Party on the United States / Zenith Case: This case concerns an exemption of a consumption tax for certain products when exported from Japan, and a decision by the US Customs Court to assign countervailing duties on those exports. The Working Party agreed that the Japanese tax practices in question were in full accord with the provisions of the GATT and that, should the court decision be upheld finally and if countervailing duties were imposed, the imposition of such duties would be in contravention of the provisions of the GATT including Article VI:4 and the note to Article XVI, and would constitute a prima facie case of nullification or impairment of Japan's rights under the GATT. They further shared the view that the US Customs Court decision and the subsequent US action was already in violation of the GATT and was causing a serious adverse trade impact upon the Japanese exports in question to the United States. The Working Party requested that its report be transmitted urgently to the Council for expeditious consideration.

L/4543 (26/08/1977) United States / Zenith Case - Ruling by the Court of Customs and Patent Appeals - Communication from the US.

L/4693 (28/07/1978) United States / Zenith Case - Ruling by the United States Supreme Court - Communication from the US. "Normal customs appraisement and liquidation of the affected Japanese electronic products will resume shortly upon issuance of the final court order."