ETRMA experience

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EC Conference on WTO TBT notification
procedureBrussels, 29 March 2007

• ETRMA experience
• F. Cinaralp, Secretary General

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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 gt 4200 companies 360 000 employees
• Turnover gt 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

• Registering to EC TBT database and requesting for
  receiving ALL notifications
• (countries category of products)
• Identifying in the notification, the objectives
  of the new technical regulation and
• its compliance with international rules
• Requesting to notifier country, the text of the
  technical regulation standards or
• other documents (implementation guideline,
  administrative prescriptions) to which
• it refers to
• Checking 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
  (26) 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 notifications
• As of today, 9 countries have amended their
  regulations in line with Industry/EC
  recommendations
• 3 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, the implementation
  guideline (test methods, certified laboratories,
  ) and the administrative 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 released
• Korea 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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In conclusion,

• 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.

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Thank you for your attention!