The Australian plain packaging measures could limit the right of the trademark’ s owner of tobacco products to use the trademark and some WTO members think these measures appear to be inconsistent with its obligations under the following provisions of the TRIPS Agreement, especially Article 20 of TRIPS. Article 20 of TRIPS may limit the right of the trademark’ s owner, and there are three applicable conditions, including“in the course of trade”,“special requirements”and“unjustifiably encumbered”. Although the Australian plain packaging measures may result in special requirements to the use of trademarks for tobacco products in the course of trade and encumber the use of trademarks for tobacco products, but the use of trademarks for tobacco products shouldn’ t be unjustifiably encumbered by these measures. Article 20 of TRIPS can apply to the Australian plain packaging measures.