The International Law of Recognition and the Status of the Republic of China The International Law of Recognition and the Status of the Republic of China HUNGDAH CHIU* I. INTRODUCTION The Republic of China (ROC) on Taiwan is in effective control of an area of 36,000 square kilometers (14,000 square miles), roughly the combined size of Maryland, Delaware and Rhode Island, and has a population of approximately 20 million, with a per capita income of more than U.S. $6,000.1 In terms of foreign trade, the ROC is the twelfth leading exporting nation of the world2 and the fifth leading trading partner of the United States. The armed forces number about half a million, with reserves of more than 2 million troops.4 Despite these factors, the ROC is not officially recognized by most countries and is represented in neither the United Nations nor its affil- iated agencies.' Only a few international organizations accept the ROC as a member and even within those organizations, the ROC's standing remains uncertain. This paper surveys the status of the * Professor of Law, University of Maryland School of Law. This article is a revised version of a paper prepared for the Conference on the Republic of China on Taiwan-United States Relationship, April 7-8, 1989, Los Angeles, organized by The Claremont Institute in conjunction with The Greater Los Angeles world Trade Center Association and California Taiwan Trade and Investment Council. 1. Chung-yang Jih-pao, Nov. 25, 1989, at 2. 2. Chongguo Jih-pao, Mar. 1, 1989, at 6. 3. Coordination Council for North American Affairs, ROC Trade with U.S. and Eco- nomic Liberalization 1 (June 1989). 4. See generally REPUBLIC OF CHINA 1988: A REFERENCE BOOK (1988); U.S. DEPART- MENT OF STATE, BUREAU OF PUBLIC AFFAIRS, BACKGROUND NOTES TAItVAN (March 1988). 5. On October 25, 1971, the United Nations General Assembly voted to give the Chinese seat to the People's Republic of China (PRC) and thus to exclude the Republic of China (ROC) from participation in the United Nations. Thereafter, United Nations specialized agen- cies took similar measures to exclude the ROC. See Representation of China in the Unitcd Nations, 1971 U.N.Y.B. 126, 126-35, U.N. Sales No. E.731.1. In 1980, the International Mon- etary Fund, the world Bank, the International Development Association and the International Finance Corporation de-recognized the ROC in their respective organizations. See Chiu, Chen, & Lee, Contemporary Practices and Judicial Decisions of the Republic of China Relating to International Law, I CHINESE Y.B. INT'L L. & AFF. 141, 142-43 (1981). 6. As of December 31, 1988, the ROC maintained membership status in only nine orga- nizations: the International Union for Publication of Customs Tariffs (IUPCT); the Interna- tional Committee of Military Medicine and Pharmacy (ICMMP); the International Criminal Police Organization (INTERPOL); the International Office of Epizooties (IOE); the Interna- JOURNAL OF CHINESE L4W ROC in the context of the international law of recognition and the problems it faces in maintaining its foreign relations through unortho- dox channels. II. THE POLITICAL NATURE OF THE INTERNATIONAL LAW OF RECOGNITION Under generally accepted principles of international law, there are four qualifications deemed essential for recognition as a state: (1) a permanent population; (2) a defined territory; (3) a government; and (4) a capacity to enter into relations with other states.' However, because of the decentralized nature of the international legal system, no single authority is available to render an authoritative decision on whether an entity does possess these qualifications. Rather, the deci- sion is left to the individual states of the international community through the system of recognition which is "the acknowledgement of a situation with the intention of admitting the legal implications of such a state of affairs." 8 Ideally, each state would treat the question of identifying whether an entity is a state as a legal issue, not a polit- ical one, and base its decision concerning recognition on objective cri- teria prescribed by international law.' But in practice, most states base this decision on policy considerations. I0 Another issue which often arises in the context of international tional Cotton Advisory Committee (ICAC); the Asian Productivity Organization (APO); the Afro-Asian Rural Reconstruction Organization (AARRO); the Asian and Pacific Council (ASPAC); and the Asian Development Bank (ADB). The ROC's former voting rights in INTERPOL have been given to the PRC, although the ROC is still considered a member under the name "China Taiwan." The ICAC has changed the ROC's name to "China Tai- wan" and the ADB has changed the ROC's name to "Taipei, China." See Contemporary Practice and Judicial Decisions of the Republic of China Relating to International Law, 1986- 88, 7 CHINESE Y.B. INT'L L. & AFF. 225, 227 (1987-88). Moreover, ASPAC is an essentially defunct organization. No ministerial meeting has been held since 1972. However, two organs established by the ASPAC remain in operation - the Cultural and Social Center for the Asian and Pacific Region (CULSOCEN, located in Seoul) and the Food and Fertilizer Technology Center for the Asian and Pacific Region (FFTC, located in Taipei). 3 BASIC DOCUMENTS OP ASIAN REGIONAL ORGANIZATIONS 991, 991-93 (M. Haas ed. 1974); 5 BASIC DOCUMENTS OF ASIAN REGIONAL ORGANIZATIONS 453, 454 (M. Haas ed. 1979). 7. See, e.g., Convention on Rights and Duties of States, Dec. 26, 1933, art. 1, 49 Stat. 3097, 165 L.N.T.S. 19. See also RESTATEMENT (THIRD) OF THE FOREIGN RELATIONS LAW OF THE UNITED STATES § 201 (1987) [hereinafter RESTATEMENT], which states: "Under international law, a state is an entity that has a defined territory and a permanent population, under the control of its own government, and that engages in, or has the capacity to engage in, formal relations with other such entities." 8. G. SCHWARZENBERGER & E.D. BROWN, A MANUAL OF INTERNATIONAL LAW 566 (6th ed. 1976). 9. H. LAUTERPACHT, RECOGNITION IN INTERNATIONAL LAW 32-33 (1947). 10. J.G. STARKE, AN INTRODUCTION TO INTERNATIONAL LAW 125 (9th ed. 1984); see also RESTATEMENT, supra note 7, § 202(1). [3:193 INTERNATIONAL LAW OF RECOGNITION law is whether a government of a recognized state can represent that state in the international community. Some consider the decisive cri- terion to be whether a government has effective control over its popu- lation and territory, while others would like to introduce additional elements, such as a government's popular support within the state or its willingness to honor international obligations." Like the question of identifying an entity as a state, the determination that a govern- ment can represent a particular state is left to the decision of the indi- vidual states of the international community through the system of recognition. Again, state practice indicates that such decisions are based primarily on policy considerations rather than legal princi- ples. 2 Thus, the law of recognition is a highly politicized part of pub- lic international law. This may partially explain why the question of recognition of states and governments has not been solved satisfacto- rily either in theory or in practice. The discretionary nature of recog- nition frequently results in a state's refusal to grant recognition to an entity which in fact possesses all the necessary attributes of statehood or to a government which is in effective control of a state's population and territory. This discrepancy between politics and law creates diffi- culty and inconvenience in international relations. An entity which meets the qualifications of statehood but lacks formal recognition may not be denied certain rights or escape its international legal obligations.1 3 As stated by one international law- yer, "it is generally admitted that an unrecognized state cannot be completely ignored. Its territory cannot be considered to be no- man's-land; there is no right to overfly without permission; ships fly- ing its flag cannot be considered stateless, and so on."' 4 With respect to the status of unrecognized governments, United States law takes the view that while a state "is not required to accord formal recogni- tion to the government of another state," it is required to treat a regime that is in effective control of a state, as the government of that state.15 In practice, informal relations are sometimes maintained 11. For a summary of various views regarding recognition criteria, see L HENKIN, R. PUGH, 0. SCHACHTER & H. SMIT, INTERNATIONAL LAW, CASES AND MATERIALS 242-47 (2d ed. 1987) [hereinafter CASES AND MATERIALS]. 12. See STARKE, supra note 10, at 126. The Restatement takes the position that a state is not required to accord formal recognition to the government of another state. RESTATE- MENT, supra note 7, § 203(1). 13. CASES AND MATERIALS, supra note 11, at 232. 14. Mugerwa, Subjects of International Law, in MANUAL OF PUBLIC INTERNATIONAL LAW 247, 269 (M. Sorenson ed. 1968). The RESTATEMENT takes a similar position. RESTATEMENT, supra note 7, § 203(1). 15. RESTATEMENT, supra note 7, § 203(1). 19891 JOURNAL OF CHINESE LAW between a state and an unrecognized regime.' 6 Theoretically, a domestic court can deny the legal status of an unrecognized state or government. In practice, however, domestic courts have held that "whether or not a government exists .. is a fact, not a theory. '1 7 For example, in a case concerning an East German corporation's right to sue in the United States, a New York court observed: A foreign government, although not recognized by the polit- ical arm of the United States Government, may nevertheless have de facto existence which is juridically cognizable... The lack of jural status for such government or its creature corporation is not determinative of whether transactions with it will be denied enforcement in American courts.'8 In certain cases, a state may find it necessary in practice to deny the legal effect of non-recognition of a foreign state or government. For example, after the United States de-recognized the ROC on Tai- wan on January 1, 1979, it was compelled to enact the Taiwan Rela- tions Act (TRA) of 1979.19 The effect of this legislation was to treat Taiwan as a state and its governing authorities there as a government, despite the lack of formal recognition for the ROC on Taiwan.20 16. 1 G. H. HACKWORTH, DIGEST OF INTERNATIONAL LAW 327-28 (1940). 17. Wulfsohn v. Russian Socialist Federated Soviet Republic, 234 N.Y. 372, 183 N.E. 24 (1928). 18. Upright v. Mercury Business Machines Co., 12 App. Div.2d 36, 213 N.Y.S.2d 417 (1961). 19. Taiwan Relations Act, Pub. L. No. 96-8, 93 Stat. 14 (1979) [hereinafter TRA]. 20. With respect to the legal status of Taiwan, the TRA provides: Sec. 4(b) (1) Whenever the laws of the United States refer or relate to foreign countries, nations, states, governments, or similar entities, such terms shall include and such laws shall apply with respect to Taiwan. (3)(A) The absence of diplomatic relations and recognition with respect to Tai- wan shall not abrogate, infringe, modify, deny or otherwise affect in any way rights or obligations (including but not limited to those involving contracts, debts, or prop- erty interests of any kind) under the laws of the United States heretofore or hereafter acquired by or with respect to Taiwan. (7) The capacity of Taiwan to sue and be sued in courts in the United States, in accordance with the laws of the United States, shall not be abrogated, infringed, modified, denied, or otherwise affected in any way by the absence of diplomatic rela- tions or recognition. (8) No requirement, whether expressed or implied, under the laws of the United States with respect to maintenance of diplomatic relations or recognition shall be applicable with respect to Taiwan. (c) For all purposes, including actions in any court in the United States, the Congress approves the continuation in force of all treaties and other international [3:193 INTERNATIONAL LAW OF RECOGNITION Another example of the need to disregard the legal consequences of non-recognition may occur in the context of international agree- ments concluded between a state and an unrecognized state or gov- ernment. As Dr. Marjorie Whiteman observed in 1959: It is possible for bilateral treaties or agreements entered into not to constitute recognition. Thus, during the years 1919 and 1920 a number of bilateral treaties or agreements pro- viding for the repatriation of prisoners of war and nations were entered into with the [unrecognized] Soviet govern- ment without being regarded as resulting in recognition. 1 Official contacts between two states or governments which do not recognize each other may also become necessary in international rela- tions. For example, between 1955 and 1971, the United States and the People's Republic of China (PRC) engaged in more than one hun- dred ambassadorial talks, despite the fact that they did not recognize each other until January 1, 1979.1 Similarly, between 1973 and 1978, the United States and the PRC each maintained official liaison offices in the other's capital, despite the absence of mutual recognition23a III. DUAL RECOGNITION, OFFICIAL RELATIONS AND SEMI-OFFICIAL RELATIONS A central issue in the context of international relations involving the PRC and the ROC is whether a state may recognize both govern- ments and thus maintain diplomatic relations with both, a situation referred to as "dual recognition. ' 24 Some scholars believe that dual recognition presents the most satisfactory solution to the Chinese case, since both the PRC and the ROC satisfy the necessary qualifica- agreements, including multilateral conventions, entered into by the United States and the governing authorities on Taiwan recognized by the United States as the Republic of China prior to January 1, 1979, and in force between them on December 31, 1978, unless and until terminated in accordance with law. (d) Nothing in this Act may be construed as a basis for supporting the exclusion or expulsion of Taiwan from continued membership in any international financial institution or any other international organization. 21. Assistant Legal Adviser Whiteman to the Legal Adviser (Becker), memorandum, Mar. 25, 1959, MS. Department of State, file 762A.02/3-2559, reprinted in 2 DIGEST OF INTERNATIONAL LAW 52 (M. Whiteman ed. 1963). 22. K. YOUNG, NEGOTIATING WITH THE CHINESE COMMUNISTS: THE UNITED STATES EXPERIENCE, 1953-1967 (1968). 23. Presidential Assistant Kissinger Visits Asia, 68 DEPARTMENT OF STATE BULLETIN 313, 315-17 (Mar. 19, 1973) [hereinafter BULLETIN]. 24. Li-fa Yuan Kung Pao, Nov. 9, 1988, at 177. Dr. Lin-cheng Chang of National Tai- wan University expressed her view at a meeting of the Foreign Affairs Committee of the Legis- lative Yuan, April 13, 1988. 19891 JOURNAL OF CHINESE LAW tions for statehood under international law. In practice, the PRC has always insisted that a state must sever its diplomatic relations with the ROC when recognizing the PRC, and therefore it is cur- rently politically impossible to follow an approach of dual recogni- tion. Below are two sets of examples. The first set illustrates how several states, after attempts at dual recognition, made the choice of maintaining relations solely with the PRC. The second set demon- strates changing attitudes favoring a stronger desire for dual recogni- tion of both the PRC and the ROC. (1) France On January 27, 1964, the PRC and France announced the estab- lishment of diplomatic relations, with ambassadors to be exchanged within the following three months.26 The ROC embassy filed a strong protest against this "unfriendly" act by France, but did not sever dip- lomatic relations.2 7 However, under strong pressure from the PRC, France urged the ROC to withdraw its embassy voluntarily, or face expulsion by the French. On February 10, 1964, the ROC terminated its diplomatic relations with France.2" (2) Congo (formerly Brazzaville) On August 15, 1960, the French Congo became an independent state and soon established diplomatic relations with the ROC. Shortly after the country was renamed the People's Republic of Congo in August 1963, it commenced negotiations with the PRC to establish diplomatic relations. Both sides agreed that on the date of the establishment of diplomatic relations, "the representative of Tai- wan in Congo will lose his status as a diplomatic representative. 29 On February 22, 1964, the PRC and the People's Republic of Congo formally announced their decision to establish diplomatic relations. The ROC's embassy remained open until April 17, 1964, when it was forced to close. (3) Benin (formerly Dahomey) When Dahomey declared its independence on August 1, 1960, 25. See id. 26. Erasmus, General de Gaulle's Recognization of Peking, 18 THE CHINA QUARTERLY 195-97, printed in COHEN & CHIU, 1 PEOPLE'S CHINA AND INTERNATIONAL LAW, A DoCU- MENTARY STUDY, 237-239 (1974). 27. Id. 28. Id. 29. See DANGDAI ZHONGGUO WAIJIAO (Diplomacy of Contemporary China), at 136-37 (1987). [3:193 INTERNATIONAL LAW OF RECOGNITION the ROC extended its recognition and sent a special envoy to attend the independence celebration. But the PRC also extended recognition to Dahomey. On January 19, 1964, Dahomey and the ROC decided to establish diplomatic relations, and an embassy of the ROC was set up in the port city of Cotonou. On November 12, 1964, however, Dahomey and the PRC decided to establish diplomatic relations, and an ambassador was appointed by the PRC in February 1965. Two months later, the ROC severed diplomatic relations with Dahomey and closed its embassy. On January 3, 1966, Dahomey announced that it was severing diplomatic relations with the PRC. On April 21, 1966, the ROC resumed diplomatic relations with Dahomey. Finally, on January 10, 1973, Dahomey announced the resumption of diplomatic relations with the PRC, and the ROC declared the suspen- sion of its diplomatic relations on January 17, 1973.31 The second group of examples includes: (1) Grenada On October 1, 1985, the PRC established diplomatic relations with Grenada.32 On July 20, 1989, the ROC also established diplo- matic relations with Grenada.33 On August 8, 1989, the PRC sus- pended its diplomatic relations with Grenada.' (2) Liberia In August 1957, the ROC established diplomatic relations with Liberia.35 On February 17, 1977, Liberia established diplomatic rela- tions with the PRC,36 and a week later, on February 23, the ROC suspended its diplomatic relations with Liberia.37 In 1988, the ROC established a Trade Mission of the ROC in Liberia.38 On October 9, 1989, the ROC and Liberia decided to resume diplomatic relations,39 and on October 10, 1989, the PRC suspended diplomatic ties with Liberia. ° 30. Erasmus, supra note 26, at 257-58. 31. Id 32. ZHONGGUO WAmAo GAILAN (Survey of Chinese Diplomacy) 368 (1987). 33. Foreign Broadcast Information Service--Daily Report, China [FBIS--China], July 21, 1989, at 50, 51. 34. RMRB, Aug. 8, 1989, at 1. 35. Lien-ho Pao (overseas ed.), Oct. 3, 1957, at 1. 36. ZHONGGUO WAumAO GAMAN, supra note 32, at 368. 37. Id at 208. 38. Id 39. Chung-yang Jih-pao (int'l ed.), Oct. 10, 1989, at 1. 40. FBIS chi-89-194 Oct. 10, 1989, at 17. 19891 JOURNAL OF CHINESE LAW (3) Belize On February 6, 1987, the PRC established diplomatic relations with Belize.41 On October 11, 1989, the ROC established diplomatic relations with Belize.42 Two weeks later the PRC suspended its diplo- matic relations with Belize.43 As illustrated above, a "dual recognition" approach to maintain- ing foreign relations with the ROC and the PRC is not possible. The ROC has thus developed several approaches to establish foreign rela- tions. First, the ROC has sought to maintain an official presence by setting up a mission or delegation under the name "Republic of China" in certain countries that have recognized the PRC. Such mis- sions and delegations serve as the functional equivalent of formal dip- lomatic organs. Ironically, this practice originated with the PRC in 1973 when it established an official liaison office in the United States, despite the fact that the latter continued to maintain diplomatic rela- tions with the ROC.44 At present, the ROC maintains such presences in Vanuatu45, Tunisia46, Liberia, Bahrain, Ecuador, Fiji, Kuwait, Libya, Mauritius, and the United Arab Emirates.47 The ROC also maintains an official presence in Singapore, which recognizes neither the ROC nor the PRC. Second, the ROC has pursued its foreign relations with some countries by establishing nominally private organs which nonetheless perform the equivalent of official functions. Japan initiated this prac- tice of maintaining semi-official relations in 1972 when it recognized the PRC, severed diplomatic relations with the ROC, and subse- quently founded the Interchange Association. 48 This nominally pri- vate organ, which has offices in both Taipei and Kaohsiung, operates as an embassy in all but name. Such policies seem to be largely moti- vated by Japan's extensive economic, trade and cultural ties with the ROC. Likewise, the ROC established a similar organization, the Association of East Asian Relations, with offices in Tokyo, Yoko- hama, Osaka, and Fukuoka.49 Both organizations and their staffs 41. ZHONGGUO WAIJIAo GAILAN, supra note 32, at 342 (1988). 42. Shih-chieh Jih-pao, Oct. 13, 1989, at 1. 43. RMRB, Oct. 11, 1989, at 1. 44. For details, see BULLETIN, supra note 23 and accompanying text. 45. Shih-chieh Jih-pao, July 26, 1989, at 7. 46. Chung-yang Jih-pao (int'l ed.), Nov. 13, 1989, at 2. 47. See 7 CHINESE Y.B. INT'L. L. & AFF., supra note 6, at 512-21. 48. This Japanese arrangement for maintaining substantive relations with the ROC on Taiwan, after Japan's de-recognition of and severance of diplomatic relations with the ROC, was later referred to as the "Japanese formula." See D. ROWE, INFORMAL DIPLOMATIC RELATIONS: THE CASE OF JAPAN AND THE REPUBLIC OF CHINA, 1972-1974 (1975). 49. See 7 CHINESE Y.B. INT'L. L. & AFF., supra note 6, at 516. [3:193 INTERNATIONAL LAW OF RECOGNITION enjoy a certain degree of diplomatic privileges and immunities. Following its recognition of the PRC on January 1, 1979, the United States adopted an approach similar to that of Japan. Taking it one step further, the United States enacted the Taiwan Relations Act (TRA), which set up the American Institute in Taiwan (AIT), with offices in Taipei and Kaohsiung as substitutes for its former embassy and consulate-general respectively. For its part, the ROC replaced its embassy and consulates-general in the United States with the Coordi- nation Council for North American Affairs (CCNAA), which has offices in Washington, D.C. and several other U.S. cities.5° Their offices and staffs enjoy privileges and immunities similar to those enjoyed by international public organizations such as the United Nations.5 1 In addition, all agreements concluded by the AiT and the CCNAA are treated in the same manner as those concluded by the United States and countries with which it has diplomatic relations.5" Moreover, pursuant to sections 6 and 10(a) of the TRA, such agree- ments have full force and effect under the law of the United States. 3 The model of U.S.-ROC relations demonstrates that two countries can maintain enforceable agreements without establishing an official relationship. IV. PARTICIPATION IN INTERNATIONAL ORGANIZATIONS A problem often encountered by the ROC in the conduct of its foreign relations is its inability to participate in multilateral interna- tional conventions conducted under the auspices of the United Nations and its affiliated agencies. For instance, as previously men- tioned, the ROC is the world's twelfth leading trading country, yet it is not a contracting party to the United Nations Convention on Con- tracts for the International Sale of Goods.' Nonetheless, the ROC at times has concluded unofficial agreements with individual countries to conduct their bilateral relations in accordance with standards con- tained in international conventions.55 Another problem the ROC faces is its inability to participate in 50. IdL at 519-21. 51. See Agreement on Privileges, Exemptions and Immunities Between the American Institute in Taiwan and the Coordination Council for North American Affairs, October 2, 1980, United States-Taiwan, reprinted in 1 CHINESE Y.B. INT'L L. & AFn., supra note 6, at 235-240. 52. See TRA, supra note 19, § 12(a). 53. See 52 Fed. Reg. 9, 1558 (Jan. 14, 1986). 54. U.N. Doc. A/CoNF. 97 United Kingdom Command Papers 18, (Miscellaneous Series, Cmnd., No. 8074), 19 INTERNATIONAL LEGAL MATERIALS 671 (1980). 55. See 7 MINISTRY OF FOREIGN AFFAIRS, TREATIES BETWEEN THE REPULIC OF CHINA AND FOREIGN STATES 260-61, 294-97 (1986). 1989] JOURNAL OF CHINESE LAW many international public organizations. This is largely due to the PRC's insistence on excluding the ROC. In 1983, the PRC appeared willing to reconsider its policy of isolating the ROC from some inter- national organizations when Deng Xiaoping said that after the admis- sion of the PRC to the Asian Development Bank (ADB), Taiwan could retain its seat under the name, "Taipei, China."' 56 In March 1986, under these conditions, the PRC was admitted to the ADB.5 7 The administration of the late President Chiang Ching-kuo protested this change of the ROC's name, but did not withdraw from the ADB. In May 1989, when the ADB held its annual meeting in Beijing, the ROC's new president, Li Teng-hui, approved the participation of its delegation, though still protesting the change of the ROC's name.58 However, since the PRC issued a statement on December 19, 1988, indicating its intent to exclude the ROC from participation in all international public organizations affiliated with the United Nations, the ADB case of dual recognition now appears to be an isolated one.59 V. CONCLUSION At present, it is unlikely that the United States or member states of the North Atlantic Treaty Organization, all of which have strategic and political interests in maintaining friendly relations with the PRC, will formally recognize the ROC since to do so would jeopardize their relations with the PRC. Nevertheless, where formal recognition seems a political impossibility, these countries have sought alterna- tives such as those discussed above. Moreover, Third World coun- tries face similar concerns in deciding whether to maintain diplomatic relations with the ROC. Like diplomatic recognition, the recognition choices of interna- 56. Li-yu (Winston) Yang, 8 QISHI NIANDAI 17 (1983). 57. RMRB, May 2, 1986, at 1. 58. 6 FREE CHINA J., Apr. 10, 1989, at 1. 59. RMRB (overseas ed.), Dec. 20, 1988, at 1. The statement claims, inter alia, that: Back in 1971, the United Nations General Assembly adopted a resolution which restored the legitimate seat of the People's Republic of China in this world body. Accordingly, the United Nations has expelled Taiwan from all its organizations, and the offices of organizations of the UN system must not have any dealings with Tai- wan. This principle also applies to other inter-governmental, international organiza- tions. As for individual inter-governmental, international organizations, such as the Asian Development Bank, the Taiwan authorities are allowed to join it in the name of "Taibei, China" subject to agreement reached through consultations between the Chinese government and the international organization concerned. This is only a kind of special arrangement and cannot be regarded as a model universally applicable to other inter-governmental, international organizations. Tran& in Press Release issued by the PRC Embassy in Washington, D.C., U.S.A., No. 24, Dec. 20, 1988, at 2. [3:193 1989] INTERNATIONAL LAW OF RECOGNITION 203 tional multilateral conventions and international public organizations are also politically motivated. At present, the ROC is a member of only a few such organizations because the PRC rejects the policy of dual recognition. Absent dual recognition, and lacking alternatives, these international organizations will continue to deny membership to the ROC. Nevertheless, the ROC's increasing economic power is likely to be paralleled by an increase in political power which may thus alter the present state of the ROC's international relations. Third World nations may find that the ROC's developmental experience and eco- nomic and technical assistance make it worthy of recognition. Like- wise, developed countries may also see these benefits.