One of the disciplines for State Trading Enterprises (STEs), with respect to the WTO, is the requirement to notify the WTO of all endeavors that fit the definition of an STE. This study argues that the European Union's system of grain interventions and export refunds fits the WTO's definition of an STE. First, a system of agencies that work together for a common purpose can be considered to be an enterprise. Second, the constituents of Europe's grain intervention enterprise receive exclusive and special rights to export grain. Third, the grain intervention system has decisive voice over the timing, quantity and destination of exports. For these reasons the system should be notified to the WTO as an STE.