The objective of this paper is to investigate international regulatory development and underlying approaches, and analyze trade implications for genetically modified organisms (GMOs). To explore potential application of legitimate trade measures against GMOs, it visited and compared most relevant international agreements and rules for environmental and trade goals. Special attention is given to trade measures potentially applicable to agricultural GMOs under which the provisions of the Cartagena Protocol on Biosafety are comparatively analyzed with the multilateral environmental agreements (MEAs) and the WTO agreements.