UNIT-I

Introduction to Trade Law:-

• When countries were colonised, they started trading with each other to
expand their markets. Earlier, developed countries controlled most of the
trade, but today countries with better skills and technology often
dominate.
Trade
▪ Trade is one of the most crucial concepts in the field of economics. As
observed by Ricardo, trade is driven by comparative cost rather than the
total cost of producing goods. For example, one country might be more
productive than others in making goods because it can produce a good
using fewer inputs in terms of capital and labour than other countries
require to produce the same amount of good. Thus countries benefit from
trading according to their comparative advantage.
▪ The two main term related to the trade were
Tariffs
• A tariff is a tax on imported goods.
• Governments use tariffs to make foreign goods more expensive so people
buy local products.
• Tariffs also generate revenue for the government.
Import Quotas
• An import quota is a legal limit on how much of a product can be
imported.
• It restricts the quantity of foreign goods entering a country, usually to
protect domestic industries.
In short: Countries trade to benefit from each other’s strengths, while tariffs
and quotas are tools used to control imports and protect local producers.

Early Origins of Trade (Barter System)

Trade began in the earliest human societies through the barter system, where
people exchanged goods and services directly without using money. For
example, a farmer might exchange grain for tools or clothing. Communities
traded surplus items to meet needs they could not fulfill themselves. This
system worked well in small villages, but as populations grew, it became
inefficient because both parties had to want each other’s goods at the same time
(called the problem of double coincidence of wants). As societies expanded and
political thinkers began studying economic relations, trade moved beyond local
exchanges to inter-regional and eventually international trade, leading to more
organized commercial systems and early economic theories.
🇮🇳 Role of India in Pre-Industrial Global Trade (16th–18th Century)

Between the 16th and 18th centuries, India played a major role in global trade,
especially through its high-quality cotton textiles. Indian fabrics were famous
worldwide for their fine craftsmanship and durability and dominated
international markets. British traders and industrialists admired these textiles
and learned from Indian production techniques, which were largely based on
efficient household industries. However, to protect their own emerging textile
industries, Britain imposed bans and restrictions on Indian textile imports and
discouraged industrial development in India. These protectionist colonial
policies helped Britain build its domestic manufacturing base and contributed to
the Industrial Revolution, while simultaneously weakening India’s traditional
industries and creating long-term global economic inequalities.

Industrial Revolution and Expansion of International Trade

The Industrial Revolution marked a major turning point in trade history.

Technological innovations such as the cotton gin and textile machinery
transformed production from manual methods to machine-based factory
systems. Production increased dramatically, reducing costs and enabling large-
scale exports. This period saw the rise of industrial towns, expansion of
employment opportunities (including for women), and the integration of
markets across countries. As factories produced more goods than domestic
markets could absorb, countries increasingly relied on foreign markets, leading
to rapid growth in international trade. At the same time, many governments
imposed protective tariffs, embargoes, and other restrictions to shield domestic
industries from foreign competition, sparking ongoing debates between free
trade and protectionism.

Nineteenth and Twentieth Century Developments

The 19th century witnessed a major expansion of global trade and economic
interdependence. For example, cotton became a key export commodity for the
United States before the Civil War, linking agricultural production with global
manufacturing networks. Trade volumes increased, and countries became more
connected economically. In the 20th century, advances in transportation
(steamships, railways, aviation), communication (telegraph, telephone), and
industrial technology significantly reduced distances between continents. These
developments enabled faster movement of goods, capital, and information,
fostering the growth of global markets—particularly in textiles and
manufactured goods. By the late 20th century, these trends laid the foundation
for today’s highly interconnected global economy.

Overall: Trade evolved from simple barter exchanges in small communities

to a complex global system shaped by colonial policies, industrialization,
technological progress, and growing economic interdependence among nations.

Globalization and Contemporary Trade

▪ Globalization refers to the expansion of trade and economic integration

beyond national and regional boundaries. It involves:

- Free movement of goods, services, capital, and technology

- Integration of national economies into a global system

- Growth of multinational corporations

- Development of global supply and production chains

- Digital technology has further accelerated globalization by enabling real-

time coordination of production and trade across borders.

Some forms of globalization included are as follows:

Trade Theories — In Easy Words

Mercantilism

• An old trade system where a country tries to become richer by exporting

more and importing less.
• The goal is to keep wealth (gold, money) inside the country. This led to
the monopolization of trade.
• Trade is controlled so the country benefits, often harming others.
• It often leads to monopolies and strict government control.
Neomercantilism

• A modern version of mercantilism.

• A policy that allows goods to be imported and exported without tarrif or
restrictions.
• Countries still try to boost exports and support domestic industries.
• Governments help businesses through subsidies, free trade zones, and
export promotion.
• Imports may still be controlled to protect local industries.
• Goal: economic growth and industrial development (but sometimes
conflicts with free trade rules).

Absolute Advantage

▪ This trade consists of a mechanism mainly relying on the nation's

resources, i.e., when a country can effectively produce goods using fewer
resources, such as capital and labour than other potential competitors. In
this trade, the nation mainly focuses on its advantage by trading its surplus
and importing the goods it lacks. One of the main drawbacks of this
perspective is that the countries lacking absolute advantages trades are not
allowed, thus, they gaining little from their trade. Absolute advantage tends
to be an enduring characteristic; as long as the resources are available or
have a potential market, trade may continue, or else the trade loses its
efficiency, making nations vulnerable.

• A country has absolute advantage if it can produce a good using fewer

resources than others.
• Such countries export what they produce efficiently and import what they
cannot.
• Countries without this advantage may gain little from trade under this
idea.

Comparative Advantage

• Even if a country is not the best at producing anything, it can still benefit
from trade.
• It should specialize in goods it produces at a lower opportunity cost (i.e.,
what it sacrifices less to produce).
 • Encourages specialization and makes all countries better off.
• Comparative advantage can change over time due to technology or labor
changes.
• This theory-
• Enhance global productivity
• Encourages specialization
• Allows all nation to benefit from trade

Factor Endowments

• Trade depends on a country’s natural resources and factors like land,

labour, and capital.
• Countries export goods that use their abundant resources and import
goods that require scarce resources.
o Labour-rich countries → labour-intensive goods
o Capital-rich countries → capital-intensive goods
• These advantages can improve with investment in education, skills, and
infrastructure.

Emergence of Trade:

1. states started concluding bilateral treaties, with a view to mutually reducing

tariffs with regard to certain specified goods which were of interest to them.
▪ Anglo-French Treaty of 1860 was the earliest bilateral treaty calling for
a “tariff truce” and aiming at mutual tariff reductions. And this stage
continued up to the end of Second World War.
▪ By the end of Second World War, having realized the limitations of
bilateral approach, the states went for a multilateral approach for the
first time.
▪ The General Agreement on Tariffs and Trade was the product of this
approach. GATT aimed to reduce tariffs and promote fair trade among
multiple countries
2. The principle of non-discrimination along with tariff reduction became
the basis for this new multilateral regime. The principle of non-
discrimination means that states shall not discriminate between goods by
reference to their places of origin. This principle later evolved into the Most
Favoured Nation (MFN) concept under international trade law.
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The history of trade reflects humanity’s journey from simple barter exchanges
to a complex, globalized economic system. Trade has been shaped by
technological innovation, economic theories, political interests, and
international cooperation. From mercantilism to globalization, each stage has
contributed to modern international trade law and economic interdependence,
making trade a cornerstone of global development.
International Trade:
▪ is the exchange of capital, goods, and services across international
borders or territories because there is a need or want of goods or services
and agreements governing the same between nations
▪ Carrying out trade at an international level is a complex process when
compared to domestic trade. When trade takes place between two or
more states factors like currency, government policies, economy, judicial
system, laws, and markets influence trade.
▪ To ease and justify the process of trade between countries of different
economic standing in the modern era, some international economic
organizations were formed, such as the World Trade Organization. These
organizations work towards the facilitation and growth of international
trade
▪ International Trade Law (ITL) is the law regulating international
commerce. It has two aspects: public and private.
▪ The public aspect of ITL seeks to coordinate commercial policies of
states; and it is a part of Public International Law.
▪ The private aspect of ITL governs international commercial transactions
between the people belonging to different states. This is substantially
covered under Private International Law.
▪ In addition, the bodies like the United Nations Commission on
International Trade Law (UNCITRAL) have been trying to develop
standard laws on various aspects of transnational transactions and states
are expected to incorporate them in their respective legal system. This
process is known as unification of laws.
▪ International trade is referred to as the exchange or trade of goods and
services between different nations. This kind of trade contributes and
increases the world economy.
▪ Imports and exports are two terms related to the global market, where an
import is brought from the global market, and an export is a product sold
to the global market.
▪ The most commonly traded commodities are electronics, apparel,
machinery, capital goods, food and raw material, etc.,
▪ International trade has increased exceptionally that includes services such
as foreign transportation, travel and tourism, banking, warehousing,
communication, advertising, and distribution and advertising.
▪ Other equally important developments are the increase in foreign
investments and production of foreign goods and services in an
international country.
▪ This foreign investments and production will help companies to come
closer to their international customers and therefore serve them with
goods and services at a very low rate.
▪ International trade and production are two aspects of international
business,
▪ Foreign trade is exchange of capital, goods, and services across
international borders or territories. In most countries, it represents a
significant share of gross domestic product (GDP). While international
trade has been present throughout much of history, its economic, social,
and political importance has been on the rise in recent centuries.
▪ M. J Wasserman and C.W. Hultman, “International trade consists of
transaction between residents of different countries”.
▪ Anatol Marad & Eugeworth, “International trade is a trade between
nations”.
▪ International trade can be defined as the trade where capital, goods, and
services are exchanged across international borders or amongst territories
because of a specific need for the specific goods or services.
▪ In other words, international trades are economic transactions that are
made between countries.
▪ This trade allows countries to expand their existing markets and access
goods and services that are otherwise difficult to avail in the domestic
markets.
▪ Increase in globalization has increased competitive pricing, thus bringing
a cheaper product to the consumer’s home
 ▪ The purpose of ITL has been to foster free trade among nations. The
main aim of International Trade Law (ITL) is to promote free trade
between countries. This means people and businesses should be able to buy
goods from any country where they are cheapest and best in quality, and
sell their products anywhere in the world where they can get the best price,
without unnecessary barriers.
Article 301 of Indian Constitution: Trade, Commerce shall be free
throughout the territory of India.
▪ Article 301 of the Indian Constitution declares that trade, commerce, and
intercourse throughout India shall be free, aiming to create a single
economic unit by removing barriers between states and fostering national
unity, though this freedom isn't absolute and is subject to restrictions in the
public interest under other articles in Part XIII (Articles 302-307)

Trade Commerce

The possession of goods or Commerce involves all the activities that

services is given from one aid in promoting the exchange of goods
person to the another in and services from the manufacturer to the
payment. Trade can be last customers. Primarily, the activities are
performed between 2 parties or banking, transportation, advertising,
more than 2 parties. warehousing, insurance, etc.,

Narrow scope Broad scope

Social activity Economic activity

An association of buyer & An association of manufacturer and

seller consumer

More capital requirement Less capital requirement

 Fewer frequency of Regular frequency of transactions
transactions

Classification of International Trade:

a. Import Trade: It refers to purchase of goods from a foreign country.
▪ Import trade involves the purchase of goods or services from another
country. The manufacturing or creation of the merchandise occurs in one
territory, and another purchases it for entry there.
▪ This transaction often occurs when the purchasing country lacks goods or
services within its borders and must turn to another to meet its needs. In
other cases, it’s because products originating from other countries are
cheaper than those manufactured within the buying country. Additionally,
many inputs are imported for the creation of new products that are
subsequently exported to other locations.
Countries import goods which are not produced by them either because of cost
disadvantage or because of physical difficulties or even those goods which are
not produced in sufficient quantities so as to meet their requirements. In 2020-
21, USA imported goods & services close to $2.41-3.21 trillion, India - $661.86
billion.
Reasons for Importing
Countries import goods for several reasons, but two primary factors drive
import trade:
▪ Cost-Effectiveness: Many countries can import certain goods at a lower
cost than they can produce domestically. For example, importing raw
materials from regions where they are abundant is often cheaper than
producing them in-house. This price advantage allows businesses and
consumers to access goods at competitive prices, improving affordability
and market variety.
▪ Unavailability of Goods: No country produces everything it needs.
Imports fill these gaps by bringing in essential goods that aren’t available
or cannot be produced domestically. For instance, countries with colder
climates rely on tropical nations for fruits and vegetables.
Effect of Imports on Trade Balance and GDP
 ▪ Importing goods affects a country’s trade balance, which is the
difference between the value of exports and imports. A country that
imports more than it exports runs a trade deficit, which can affect
national economic indicators like GDP.
▪ Trade Balance: While some imports are necessary, a significant trade
deficit can strain an economy by increasing reliance on foreign goods.
However, controlled and strategic imports can also boost industries that
need imported materials for production, ultimately contributing to
exports.
▪ GDP Impact: Imports can influence a country's GDP by affecting
domestic industries. While importing necessary goods boosts
consumption and satisfies demand, excessive imports can harm local
manufacturers by creating steep competition.
▪ An optimal balance between imports and exports is essential for
sustaining economic growth without overwhelming domestic industries.
Challenges Faced by Domestic Economies Due to Imports
(a) Import Trade: While importing goods offers benefits, it also presents
challenges, especially for domestic industries:
▪ Pressure on Local Industries: Domestic manufacturers often face stiff
competition from imported goods, especially if those products are priced
lower due to cheaper labour or raw materials in the exporting country.
This can stifle the growth of homegrown industries and lead to job losses.
▪ Trade Imbalances: Relying too heavily on imports can create a trade
deficit, increasing national debt and dependence on foreign markets.
Countries with persistent trade deficits may face currency devaluation,
leading to inflation and other economic difficulties.
▪ Currency Fluctuations: Importing goods in foreign currency exposes
economies to exchange rate risks. A sudden domestic currency
depreciation can make imports more expensive, leading to higher costs
for businesses and consumers.
(b) Export Trade: It means the sale of goods to a foreign country. In this trade
the goods are sent outside the country. China is the largest exporter,
▪ Export trade involves goods or services produced in one country and
sold to another.
 ▪ These products can range from raw materials like minerals and
agricultural produce to complex machinery, automobiles, and even digital
services like software.
▪ Exporting allows countries to monetise their specialised products, access
foreign markets, and generate income from international buyers.
▪ Examples of Export Trade:
- India’s IT Services: India is a global leader in exporting software and
technology services to the United States and Europe.
- Japan’s Automobile Industry: Japan exports a significant portion of its
automobile production to the United States, contributing to its strong trade
surplus.
▪ Exporters are the key players in the export trade process. They produce
goods, manage complex supply chains, comply with international
regulations, and ensure their products reach customers safely and on
time.
▪ Exporters often collaborate with logistics providers, freight forwarders,
and customs brokers to streamline the shipping and documentation
processes.
Key Responsibilities of Exporters:
▪ Identifying Market Demand: Exporters conduct thorough research to
understand the demand for their products in different countries.
▪ Compliance with Regulations: They ensure that all exports meet the
legal and quality standards of the home and destination countries.
▪ Managing Logistics: From packaging to transportation, exporters handle
logistics to deliver products efficiently and safely.
Importance of Exports to National Economies
Exports are a cornerstone of economic growth, providing numerous benefits to
national economies:
▪ Boosts Economic Growth: Countries with a strong export sector often
experience faster GDP growth due to the inflow of foreign capital.
▪ Creates Employment: Export activities create millions of jobs,
particularly in industries like manufacturing, agriculture, and logistics.
 ▪ Strengthens Foreign Exchange Reserves: Exporting helps countries
earn foreign currency, strengthening their foreign exchange reserves,
which are crucial for stabilising the national currency.
▪ Improves Trade Balance: A healthy export sector can improve a
country’s trade balance, reducing deficits and contributing to economic
stability.
▪ For instance, China’s rapid economic rise is largely attributed to its strong
export-led growth strategy, transforming it into the world’s manufacturing
hub.
▪ Similarly, Germany’s economy thrives on its high-tech machinery and
automobile exports, making it a global economic powerhouse.
(c) Entrepot Trade: When goods are imported from one country and are
exported to another country, it is called entrepot trade. Here, the goods are
imported not for consumption or sale in the country but for re- exporting to a
third country. So importing of foreign goods for export purposes is known as
entrepot trade.
▪ Entrepôt trade refers to importing goods into a country or a port and
then re-exporting those goods with little to no additional processing.
Often, the goods are stored temporarily before being shipped to their final
destination.
▪ For example, a company in Singapore might import electronics from
Japan, store them temporarily, and then export them to various Southeast
Asian countries without altering the products. These intermediary
transactions make entrepôt trade an essential component of global
commerce.
▪ The entrepot trade, also known as transshipment, involves importing
products into a territory to later export them to another country
without distributing them domestically.
▪ This trade is common between countries with raw materials but lacking in
technology, and those with manufacturing capabilities; that’s why raw
materials are imported, processed, and then re-exported to distribution
destinations.
▪ Entrepot trade also fosters stronger commercial ties between countries
and capitalizes on their respective strengths. Warehousing and
transportation services play a crucial role in this process, providing
 storage for raw materials and finished products before delivery to their
final destinations.
▪ Ex: India imports rubber from Thailand, processes it, and re-exports it to
another country like Japan. Singapore and Middle East countries are the
best examples for entrepot trade. Entrepot is mainly used to refer to duty-
free ports with the high volume or re-export. At entrepot, goods do not
face any import or export duties upon shipment from the port
Examples and Economic Importance of Entrepôt Trade
▪ Entrepôt trade hubs like Singapore and Hong Kong are well-known
examples. These ports act as pivotal points in international trade routes,
where large volumes of goods pass through their borders, even though the
final destination may be a different region.
▪ Singapore: One of the world’s busiest entrepôt ports, Singapore
processes vast amounts of oil, electronics, and manufactured goods for re-
export to global markets. The nation’s strategic location between the
Indian Ocean and the South China Sea makes it a key transit hub.
▪ Dubai: Dubai is an important entrepôt for the Middle East, Africa, and
parts of Asia, facilitating the re-export of goods such as gold, electronics,
and machinery.
▪ The economic importance of entrepôt trade lies in its ability to boost a
country’s GDP without significant production activities.
▪ Countries with entrepôt ports often earn revenue from tariffs, logistics
services, warehousing, and other trade-related activities. This trade also
supports job creation in logistics, shipping, and related services,
strengthening the local economy.
Reasons for Entrepôt Trade
▪ Countries engage in entrepôt trade for several reasons, the most
significant of which is access to goods, machinery, and technology that
might not be available domestically.
▪ Access to Machinery and Technology: Developing countries rely on
entrepôt hubs to access advanced machinery or technology. These goods
are imported from developed countries, stored temporarily, and then re-
exported to countries that lack direct trading relationships with the
original supplier.
 ▪ Strategic Location: Ports in regions such as Singapore and Hong Kong
offer strategic advantages due to their proximity to major global shipping
routes, allowing goods to be moved efficiently across borders.
▪ Cost Efficiency: By leveraging entrepôt trade, countries can reduce
logistical costs and delivery times. This is particularly important for
perishable goods, where time is critical.

Need for International Trade:

The aim of international trade is to increase production and to raise the
standard of living of the people. International trade helps citizens of one
nation to consume and enjoy the possession of goods produced in some
other nation
[Link] use of natural resources: International trade helps each country to make
optimum use of its natural resources. Each country can concentrate on
production of those goods for which its resources are best suited. Wastage
of resources is avoided.
[Link] of all types of goods: It enables a country to obtain goods which it
cannot produce or which it is not producing due to higher costs, by importing
from other countries at lower costs.
[Link]: Foreign trade leads to specialisation and encourages
production of different goods in different countries. Goods can be produced
at a comparatively low cost due to advantages of division of labour
[Link] of large-scale production: Due to international trade, goods are
produced not only for home consumption but for export to other countries.
Nations of the world can dispose of goods which they have in surplus in the
international markets. This leads to production at large scale and the advantages
of large scale production can be obtained by all the countries of the world.
[Link] in prices: International trade irons out wild fluctuations in prices. It
equalizes the prices of goods throughout the world
[Link] of technical know-how and establishment of new industries:
Underdeveloped countries can establish and develop new industries with the
machinery, equipment and technical know-how imported from developed
 countries. This helps in the development of these countries and the economy of
the world at large.
[Link] in efficiency: Due to international competition, the producers in a
country attempt to produce better quality goods and at the minimum possible
cost. This increases the efficiency and benefits to the consumers all over the
world.
[Link] of the means of transport and communication: International trade
requires the best means of transport and communication. For the advantages of
international trade, development in the means of transport and communication
is also made possible.
[Link] co-operation and understanding: The people of different countries
come in contact with each other. Commercial intercourse amongst nations of the
world encourages exchange of ideas and culture. It creates cooperation,
understanding, cordial relations amongst various nations.
[Link] to face natural calamities: Natural calamities such as drought, floods,
famine, earthquake etc., affect the production of a country adversely. Deficiency
in the supply of goods at the time of such natural calamities can be met by
imports from other countries.
[Link] advantages: International trade helps in many other ways such as benefits
to consumers, international peace and better standard of living.

ISSUES & CHALLENGES

▪ Ensuring Fair Market Operations- One of the most pressing challenges
is maintaining fair market operations. Unfair trade practices, such as
dumping (selling goods below cost to eliminate competition), distort
markets and harm domestic industries in importing nations.
Governments and international bodies like the WTO strive to create a level
playing field. Still, challenges arise with protectionist measures and trade
policies aimed at sheltering local industries from foreign competition.
Key issues:
- Trade barriers: Tariffs and non-tariff barriers can distort free market
operations.
- Geopolitical tensions: Ongoing trade wars between countries, such as the US
and China, create instability in global trade.
▪ Role of International Laws and Organizations Like WTO-
International laws and trade agreements are crucial for setting the
framework for trade activities. The World Trade Organization
(WTO) is vital in resolving disputes, promoting fair trade, and facilitating
negotiations among countries. However, there are challenges:
- Dispute resolution: WTO’s dispute resolution process has faced delays,
undermining its credibility.
- Geopolitical influences: Political disagreements between countries affect the
enforcement of international laws. For example, countries increasingly
favour bilateral trade agreements over multilateral ones to secure favourable
terms.
The WTO continues to work on initiatives like the Trade Facilitation
Agreement, which aims to reduce bureaucratic red tape and promote smoother
trade across borders.
▪ Customs Measures Implemented by Countries- Customs measures are
tools that governments use to control imports and exports, regulate trade,
and protect domestic industries. These measures include tariffs, quotas,
and various non-tariff barriers. While they help protect local industries,
they also present challenges for businesses engaged in international trade.
- Tariffs: Custom duties can raise the cost of imports, affecting profitability and
trade competitiveness.
- Compliance: Businesses must navigate complex regulations, leading to
increased costs and delays.
- Retaliatory tariffs: Trade wars between major economies often lead to higher
tariffs, creating uncertainty in global markets.
Globalization and Trade:
▪ People have derived benefits from the geographical locations of one
another since ages. This has been done by way of migration, trade and
business relations.
 ▪ by introduction of free trade agreements and novel developments in the
international relations which enable the states to benefit from each other’s
interests. This process of inter-state integration and interaction is
called globalization.
▪ Globalization, the word means to make “global”, meaning making
global ties or making something or usage of something accessible and
not restricted to a single territory. The process is leaving a significant
impact on the international community and on its environment, politics,
society and economic development. Besides, globalization has made
gradual changes in the health sector and individual well-being of
societies.
▪ Globalization by removing the barriers also frees the States from their
technological deficits. This improves not only the industrial sector but
greatly impacts the healthcare segment as well when the States have
begun to import advanced machinery and other assets that couldn’t be
manufactured within their territories. This also boosts the development in
the developing and underdeveloped countries by the flow of information
and technology across borders.
▪ An increasing share of spending on goods and services is devoted to
imports and an increasing share of what countries produce is sold as
exports.
Advantages of Globalization
▪ It creates greater opportunities for firms in less industrialized countries
to tap into more and larger markets around the world
▪ This can lead to more access to capital flows, technology, human
capital, cheaper imports and larger export markets
▪ It allows businesses in less industrialized countries to become part of
international production networks and supply chains that are imp for
trade
Disadvantages
▪ The growth of international trade is exacerbating income inequalities,
both between and within industrialized and less industrialized
nations
▪ Global commerce is increasingly dominated by transnational
corporations which seek to maximize profits without regard for the
development needs of individual countries or the local populations
▪ Protectionist policies in industrialized countries prevent many
producers in the Third World from accessing export markets;
▪ The volume and volatility of capital flows increases the risks of
banking and currency crises, especially in countries with weak
financial institutions
▪ Competition among developing countries to attract foreign
investment leads to a “race to the bottom” in which countries
dangerously lower environmental standards
▪ Cultural uniqueness is lost in favor of homogenization and a
“universal culture” that draws heavily from American culture