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ETRMA experienceETRMA experience

F. Cinaralp, Secretary GeneralF. Cinaralp, Secretary General

EC Conference on WTO TBT notification procedure

Brussels, 29 March 2007

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• European tyre and rubber manufacturers’ Voice towards the European institutions and international organisations

• 2 major sectors: Tyre & General Rubber Products

• Membership : – 10 Tyre Corporate members:

– 10 Associations from major EU countries to represent Rubber Goods manufacturers

• Represents > 4200 companies; 360 000 employees

• Turnover > € 47b (EU-27)

• Offices in Brussels – www.etrma.org

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TBT notifications on « tyres » since July 2004

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TBT notifications on “tyres”

26 TBT notifications since July 2004

• North America : Canada, USA (2)

• Latin America: Equator, Peru, Colombia, Venezuela, Trinidad and Tobago, St Lucia

• Europe: Armenia

• Africa: Ghana, Nigeria, Kenya

• Gulf countries: Qatar (2), Kuwait

• Asia: Indonesia, Sri Lanka, China (2), India (2), South Korea (2), Malaysia

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Nature of texts notified

• 24 technical regulations on tyres setting local certification procedure for imports with sometimes additional marking and licence fees

• 1 Conformity Assessment Programme: Ghana

• 1 Exporting rules guideline: Nigeria

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Why Industry should contribute ?

• To avoid creation of ‘artificial’ technical barriers to trade at high and unjustified costs to Industry

• To provide industry feedback allowing the European Commission to properly assess the effective functioning of the WTO TBT Agreement

• To bring maximum countries to recognize the international technical regulations, for common benefits

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Key parameters for proper industry assessment of the notification

•RegisteringRegistering to EC TBT database and requesting for receiving ALL notifications (countries + category of products);

• IdentifyingIdentifying in the notification, the objectives of the new technical regulation and its compliance with international rules;

• RequestingRequesting to notifier country, the text of the technical regulation + standards or other documents (implementation guideline, administrative prescriptions) to which it refers to;

•CheckingChecking WTO deadline, taking into account EC own timeframe (not indicated on EC website !), to possibly request ASAP for a deadline extension for commenting (delay for communication of text, translation into English, …).

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Building up of ETRMA contribution

• Sector strategy: prioritization of markets• 1 key asset: existence of international rules for

automotive components UN/ECE 1958 Agreement and relevant technical regulations are recognised by WTO as international standards

• ETRMA contribution to EC is built-up on:– Sector technical analysis based on international technical

regulations;– Trade impact analysis including assessment of the

administrative provisions;– Proposals to amend the notified reg. accordingly.

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ETRMA supporting network• Share the comments with:

» Member companies & associations» Sister organisations from major markets: Japan, the US, …. » European sectoral organisations: ACEA, …

with the objective to: 1- reinforce industry positions;2- obtain support from their respective governments to EC

intervention at WTO TBT Committee (eg Indonesia, India or Korea)

• ETRMA establishes sometime direct contacts with the authorities of the notifying country- a démarche that is often accompanied by EC

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Outcome reached

So Far:• ETRMA provided analysis and comments for all (2626) technical

regulations/conformity assessment/export rules which targeted tyres;

• European Commission based its argumentation on ETRMA contribution when commenting to national authorities for the 26 26 notifications;

• As of today, 99 countries have amended their regulations in line with Industry/EC recommendations;

• 33 Countries have notified revised version of their regulations further to comments received including from EC: Qatar, India, China

• Key dossiers still open: India, China, South Korea, Kenya

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What works well ?

• Immediate e-mail alerts from EC TBT Unit;• TBT Unit support to obtain related technical documents +

relevant standards;• Coordination between EC Industry Unit + TBT Unit to follow

up with Industry;• Industry analysis is requested by the EC and by Member

States;• Contribution within the deadline;• For some major markets, maintaining the dialogue with EC to

possibly pursue the actions through bilateral channels

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What could be improved at EC level?

EC anticipation of third countries technical regulatory initiatives through :

» promotion for harmonisation of international technical rules (EU-China Auto Dialogue, EC-CEN Asean seminars …);

» early involvement of EC Delegation in notifying country when conflict with international trade rules is detected (allocation of proper resources)

A more ‘offensive’ attitude in officially addressing TBT cases in WTO Committee and not only in the margins.

IIII

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What should be improved at WTO level ?

The European Commission should require that the technical regulation, technical regulation, the implementation guidelineimplementation guideline (test methods, certified laboratories, …) and the administrative provisionsadministrative provisions (testing cost, time span, costs, …), be mandatory attached to the notification.

In addition, Industry/EC should get the texts translated at least into one of WTO languages when notification is releasedKorea –notified in Korean –because listed as “developing country”!

The notifying country to inform the other WTO members of the adoption/entry into force of the technical regulation and of its final content.

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The WTO TBT notification procedure is an additional tool, to be used by industry and the governments

to reduce ‘artificial’ technical barriers to trade, to promote international harmonisation of

technical regulations and,to improve the efficiency of the procedure.

In conclusion,

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Thank you for your

attention!