WORLD TRADE
ORGANIZATIONG/TMB/N/409
8 August 2001
(01-3936)
Textiles Monitoring Body Original:  English
AGREEMENT ON TEXTILES AND CLOTHING
Communication from Macau, China
The Textiles Monitoring Body has received a communication from Macau, China in reply to
its request for additional information in the context of the preparation of the Body's Comprehensive
Report on the implementation of the ATC during its second stage, in accordance with Article 8.11
The TMB is circulating this communication to WTO Members for their information.G/TMB/N/409
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Macau Economic and Trade Office
Brussels
7 June 2001
Ambassador András Szepesi
Chairman of the TMB
Dear Ambassador Szepesi,
In reply to your letter dated 14 May 2001, I am pleased to enclose herewith the
comments/clarifications from our Government, regarding the US communication (and its Customs
Service Report) on transshipment.
I thank you for your kind attention to this matter and, please accept the assurances of my
highest consideration.
(Signed for)
Raimundo do Rosário
Head of OfficeG/TMB/N/409
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Re:  Communication from the United States to the TMB in respect of the year 1999
Macau's comments
The Government of the Macau Special Administrative Region (Macau SAR) would like to
clarify the points below:
1. In the second paragraph of the US document, the "22% suspicion rate" is justified "as not
reliable due to the difficulty in targeting manufacturers in Macau because of the MID (manufacturer
identification) problem …".
This is an incorrect statement, as the Macau  Economic Services (MES), following extensive
correspondence and a request from the US Customs Service issued circular-letter No. 11/99/DCO,
dated 16 April 1999 requiring the local industry to identify factory names only, in block
letters - which they have been doing ever since.  This information with the relevant translation of the
circular-letter was forwarded on 10 May 1999 to Strategic Operations, US Customs Service, and tothen Chief Textile Negotiator, USTR.
It is the Macau Government's view that this difficulty should not be stated as a problem,
because MID requirements were already in place since 16 April 1999.
Therefore, Macau cannot see the rationale behind the above-mentioned US Customs
"difficulty in targeting manufacturers in Macau because of the MID".
2. Moreover, after the first Textile Production Verification Trip (TPVT), in January 1999, it was
agreed that the relevant US Customs report would be submitted to Macau "in a couple of months",along with further information on a number of issues  that would enable the MES to better undertake
its own investigations on any problematic findings of the US authorities.
3. The response to Macau's request was belated.  In  fact, copy (incomplete) of the January report
was only provided to Macau in the course of the September TPVT.
It should be stressed that, where cooperation is concerned, Macau has always kept its
commitments under the international agreements to th e fullest extent of the spirit and letter thereof.
Namely, Macau has forwarded to the US authorities information/support requested, even to the
extreme of its own domestic laws.
4. From the comments noted in paragraphs 1 and 2 above, Macau can only reinforce that the
stance towards its US counterpart authorities have always been of the most full cooperation.
Hence, Macau – again – does not see as fair the comparison made with other trading partners,
namely as to the cooperative stream of information provided, since Macau's legislative framework
differs from others.  That is, ours is Roman-German law based, vis-à-vis  their common laws.
Within the constrictions of our own law, Macau doubts whether any other partner has been so
forthwith with information and cooperation efforts as we have.
5. In view of the previous, Macau does not see the rationale for CITA's issuance of the "black
listing" of 77 local factories.  Moreover, 51 of those included therein had already been reported to the
US authorities as closed.G/TMB/N/409
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Macau would also like to point out that it does no t seem fair for the US to comment that "This
list has been subsequently reduced to 74 based on petitions filed by the factories for relief".  The
factories in question should not have been included in the list in the first place, because they were
complying with all domestic and international rules.
6. On the question of market access, Macau would also like to stress that its trading system "is
one of the freest in the world".  This was the conclusion of the recent Trade Policy Review held in
Geneva between 21-23 March 2001.  Macau complie s fully with the requirements set out in
international agreements on trade.
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