On September 16, 2016, the Appellate Body (AB) of the World Trade Organization (WTO) issued its report in India — Certain Measures Relating to Solar Cells and Solar Modules, upholding the panel report handed down in April 2016. According to the WTO summary of the dispute, the United States requested consultations on February 6, 2013, regarding certain Indian measures that imposed a form of domestic content requirement (DCR) for solar cells and solar modules, claiming that such measures violated Article III:4 of the General Agreement on Trade and Tariffs (GATT) and Article 2.1 of the Agreement on Trade Related Aspects of Investment Measures. India argued that its DCR measures were not in violation of the aforementioned articles based on multiple exceptions, as laid out in Articles III:8, XX(j), and XX(d) of the GATT. The panel report relied on a previous AB report with similar facts, Canada — Measures Relating to the Feed-in Tariff Program, to reject the main thrust of India’s argument centered around Article III:8’s exemption for government procurement. The panel stated that the electricity purchased by the government of India was not in “direct competition” with the solar cells and solar modules subjected to the measures at issue—a key requirement for the exemption. The panel also dismissed the two Article XX claims for exemption as inapplicable to the facts of the dispute. The AB affirmed the panel’s assessment of the issues and reinforced the panel’s claim that the Canada report properly guided the India dispute. The AB report also included a separate opinion from an AB member, which stated that “[t]he Appellate Body cannot be expected to offer interpretative guidance regarding provisions of the covered agreements in an abstract manner beyond the scope of what is required in a particular dispute. To do so would go beyond the Appellate Body's adjudicatory function.” This AB member concluded by saying, “I hope to be able to shed light on how I view the Appellate Body's function, as well as its limits, both in the context of the present appeal, as well as others on which I have been working with my distinguished colleagues at the Appellate Body.”