RESTRICTEDWORLD TRADE
ORGANIZATIONG/SCM/W/499
7 March 2002
(02-1159)
Committee on Subsidies
and Countervailing MeasuresOriginal:  English
MEMBERS' DIFFICULTIES IN MAKING SUBSIDY NOTIFICATIONS,
AND THE PLANNED SUBSIDY NOTIFICATION SEMINAR
Reply to Questions in document G/SCM/W/473
of 18 December 2001
Paper Submitted by Bulgaria
The following communication, dated 5 March 2002, has been received from the Permanent
Mission of Bulgaria.
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B. QUESTIONS CONCERNING DIFFICULTIES IN NOTIFYING
1. Does your government face resource constraints in trying to make subsidy notifications?
If so, what are the major bottlenecks in the notification system of your government?  Is the
problem primarily an insufficient number  of staff to handle the notifications, or is it more a
question of insufficiently trained  staff?
Reply
The major bottleneck in the notification system of the Bulgarian government is the problem of
insufficiently trained  staff.
2. Depending on your answer to question 1, above, if the notification questionnaire format
could be simplified, would this make a difference to your government’s ability to make the
required subsidy notifications?
Reply
Bulgaria considers that simplification of the re quirements for the information that should be
submitted under the notification questionnaire format would facilitate the preparation of subsidy
notifications.
3. Balancing your government’s needs for as simp le a format as possible against its needs
to be able to understand other Members’ notifications when it reviews them, how muchsimplification could be introduced without sacrificing transparency?
Reply
The simplification should be aimed towards the requirements for the submitted information
under the notification questionnaire rather than to the scope of questions.
4. Considering the notification format itself, and the concepts underlying it as found in
SCM Articles 1-3, in your government’ s experience, do individuals responsible for makingG/SCM/W/499
Page 2
notifications have difficulties understanding the requirements due to the language used in the
Agreement to define “subsidy”, “specificity”, etc. ?  For example, do these individuals believe
that subsidies are in the nature of cash grants  only, and do not encompass revenue foregone via
tax and duty incentives?  Could some sort of explanation be introduced into the questionnaire
format to make clearer the scope of measures th at are subject to notification?  How might such
an explanation be worded?
Reply
The officials responsible for making the notifications do not encounter difficulties in
understanding the definitions of “subsidy”, “specificity", etc.  Most difficulties concern the
presentation of the available information on subsidies in compliance with the notification
questionnaire.  Nevertheless some explanations introduced into the questionnaire format clarifying the
scope of the measures would be useful.
5. Does your government experience general problems due to the formatting requirements
of the notification questionnaire?  In particular, does your government maintain any pre-
existing information that addresses the substance of the notification questionnaire, but does not
correspond to the questionnaire’s format?  If so, what are the specific problems that your
government encounters when it tries to fo rmat the information as required by the
questionnaire?  If the information were to be notified in its pre-existing format, could it
nevertheless be keyed to the data elements of the subsidy questionnaire?
Reply
Major problems pertain to the fact that the available information on subsidies does not
correspond to the questionnaire’s format and as a result it is difficult to submit comprehensiveinformation on all matters.  However, if the inform ation is notified in its pre-existing format, then it
would not be keyed to the data elements of the subsidy questionnaire.
6. In reviewing other Members’ notifications, would your government find it problematic
to review information that was formatted in a way other than the way foreseen in the subsidy
questionnaire, but that comprehensively ad dressed the substantive elements of the
questionnaire?  How important would it be for this information to be keyed or coded to the
questionnaire format?
Reply
Bulgaria considers that for the thorough understanding of the notifications the information
should be provided by all Members in one and the same way, i.e. the use of the notification
questionnaire format is indispensable.
7. Does your government maintain any info rmation about its subsidy or incentive
programmes on official web sites? How much would your notification of subsidies be simplified
if such information could be submitted in its pre-existing format? As a reviewer of notifications,
what sorts of limits should there be to the substitution of information from web sites for
completed notification questionnaires?  Would references to web sites be a useful supplement to
substantive information provided in a notification?
Reply
The Ministry of Finance maintains on its web site general information about the subsidies
provided in Bulgaria but it does not correspond to the notification requirements and cannot be used
for a substitution of notifications.  However we consider that references to web sites would be a useful
supplement to the information provided in the notifications.
8. Concerning General Rule 6, which requires that  notification of subsidies provided “to
specific products or sectors” be organised on a product- or sector-specific basis, does this rule
pose problems for your government when notifying subsidies that are provided on a horizontal,G/SCM/W/499
Page 3
rather than a product- or sector-specific basis?   What are the specific steps and difficulties in
preparing sector- or product-specific informatio n for subsidies provided on a horizontal basis?
Reply
For the time being we have no difficulties in the fulfilment of the requirements under General
Rule 6.
9. Does this rule present problems for notification of subsidies that are provided on a
product- or sector-specific basis (e.g., some agricultural subsidies)?
Reply
For the time being we have no such problems.
10. Would a redrafting of General Rule 6 to ref er to subsidies "provided on the basis of
specific products or sectors" help to resolve this  problem?  (The idea would be to clarify that
programme-based information, rather than product- or sector-specific information would berequired for subsidies provided on a horizontal basis, which product- or sector-specific
subsidies would continue to need to be notified on that basis.)
Reply
Please refer to the answer to question 8.
11. Would such a redrafting pose problems for the review of subsidy notifications, and if so,
what would those problems be?
Reply
Please refer to the answer to question 8.
12. To what extent does the general requirement to provide statistical information on the
trade effects of notified subsidies (chapeau of item 9) impede or delay the presentation ofsubsidy notifications?
Reply
Bulgaria encounters real difficulties with this requirement, particularly in respect of the
criteria for assessment of the subsidy’s trade effect.  Therefore this requirement can delay to some
extent the presentation of notifications.
13. To what extent does the need to compile the specific kinds of statistical information
referred to in items 9(a) and 9(b) impede or delay the presentation of subsidy notifications?
Reply
We find this requirement very difficult.
14. How important is this statistical informat ion about other Members’ subsidies to your
government when reviewing subsidy notificati ons?  Could these reporting requirements be
made less stringent in some manner?  If so, how?
Reply
The statistical information is of importance for the assessment of subsidies but very often it is
not provided by Members.  Most of the countries do not provide statistical information, but only
statements that the subsidies have no direct trade effects or the effect is minimal, etc.G/SCM/W/499
Page 4
15. Does your government find, in preparing subs idy notifications, th at there is conceptual
overlap or redundancy in some of the information elements as currently drafted?
Reply
To great extent this issue concerns questions 5 and 6.
16. If your government believes there to be overlap, how might this be eliminated?  What
drafting improvements might be introduced to clarify such situations, while preserving the
substantive requirements of Article 25 from which the questionnaire is drawn?
Reply
Please refer to the answers to questions 3 and 4.
17.  Do the requirements to provide information on the policy objective or purpose of the
subsidy, its background and authority, and to whom and how it is provided pose significant
difficulties to your government in preparing its subsidy notifications?  How might theserequirements be simplified?
Reply
Bulgaria encounters some difficulties related to the provision of comprehensive information
on these matters.
18. Does the requirement to furnish an explanation where a particular element of
information cannot be provided pose particular difficulties to your government in preparing its
notifications?  If so, is there a way to simplify this requirement while preserving its substantive
content?
Reply
It is particularly difficult to prepare the notifications in case of lack of information. However
some explanations in this respect should be provided.
19. Is there sufficient flexibility in item 7 of the subsidy questionnaire (information on the
amounts of subsidies provided) for your government to be able to notify such information
without undue difficulty?  If not, is there a way to simplify this requirement while preserving its
substantive content?
Reply
We have no difficulties to provide information for the amounts of subsidies provided.
C. QUESTIONS PERTAINING TO THE SUBSIDY NOTIFICATION SEMINAR
1.  Concerning the number and nature of participants in the seminar, how many
individuals in your government have day-to-day responsibility for gathering information about
subsidies and for preparing and submitting subsidy notifications based on that information?  Ifmore than one, please describe the differen ces in these individuals ’ responsibilities.
Reply
Three officials in the Ministry of Finance are responsible for handling subsidy information
and notifications.  Two are responsible for gathering of information and one - for preparing and
submitting of notifications.
2. Would it be sufficient for your government to have two participants in the seminar?  If
not, why not, and how many participants would be optimal from your government’s point of
view?G/SCM/W/499
Page 5
Reply
Three participants would be optimal for the Bulgarian side.
3. Would two days be a sufficient/appropriate le ngth for the seminar?  If not, what would
be more appropriate?
Reply
We consider that three days would be more appropriate.
4. Would the following schedule be appropriate: First session: detailed presentation of the
basic definitions in Articles 1, 2 and 3 of the SCM Agreement, and presentation of the subsidy
notification obligations in the light of these definitions. Second session: Presentations by
Members concerning the specific problems they experience in preparing subsidy notifications.
Third session: Information sharing and brainstorming among Members as to possible practical
solutions for the identified problems (ways to co-ordinate and streamline gathering and
formatting of subsidy information).  Fourth session: Follow-up steps to ensure that information
shared and lessons learned would be retained and implemented.  (It has been emphasised that tobe effective, such follow-up should be immediate and intensive.)  Ideas suggested to date have
included establishment of informal contacts am ong capital-based officials, planning of future
focused technical assistance activities, etc.
Reply
In our opinion, the seminar should take at least three days and it must focus on practical
issues.
5. Does your government normally send capital-based representatives to the Committee’s
regular meetings?  If not, why not?
Reply
Bulgarian government does not send capital-based representatives to the Committee’s regular
meetings due to the encountered significant financial constraints.
6. Does your government view this subsidy noti fication seminar as an important event in
improving its ability to understand the subsidy rules, and to make subsidy notifications in acomplete and timely manner?  (That is, does your government view the seminar as a priority
event for its participation?)  Does your government  plan to send capital-based participants to
the seminar?  If so, how many and what are their functions? If not, why not?
Reply
Bulgaria plans to send to the seminar three representatives: the head of the State Aid
Department, a chief expert and a senior expert from the State Aid Department.
7. In the view of your government, would financial sponsorship only of participants from
least-developed country Members be appropriate?  If not, why not?  What other objective
criteria for eligibility for financial sponsorship could be developed that might be more
appropriate?
Reply
Provision of financial sponsorship for other countries encountering significant financial
difficulties should be considered.
8. If your government would be prevented from sending participants to the seminar due to
financial constraints, what is the minimum level of financial sponsorship that would make it
possible to send participants (e.g., airfare only, airfare and subsistence for the days in Geneva,
etc.)?G/SCM/W/499
Page 6
Reply
The financial sponsorship should include airfare and subsistence (daily allowances and
accommodations) for the days in Geneva or at least only travel expenses or only subsistence for the
stay in Geneva.
9. Assuming that it is not possible to finance the seminar out of existing trust funds in the
WTO (a possibility currently being explored), and assuming a total budget of approximately
CHF 225,000, would your government consider making a donation to finance it?  If so, how
much would your government be in a position to contribute?
Reply
Bulgaria would not be in a position to make a financial donation.
10. If the seminar were financed by earmarked contributions from individual Members,
and there were a surplus in the budget for the seminar (due to fewer than expected participantsfrom Members eligible for financial sponsorship,  however they might be identified), how should
any such surplus be disposed of?  Two possible  options have been discussed (i) returning the
surplus to the sponsors on a pro-rata basis; or (ii) making the surplus available on a first-come,
first-served basis to other developing countr y Members.  Are there other, more appropriate,
options?
Reply
We consider option (ii) more appropriate.
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