RESTRICTEDWORLD TRADE
ORGANIZATIONG/SCM/W/490
11 February 2002
(02-0670)
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 Bangladesh
The following communication, dated 7 February 2002, has been received from the Permanent
Delegation of Bangladesh.
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B. QUESTIONS CONCERNING DIFFICULTIES IN NOTIFYING
Q1. 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 Government of Bangladesh does face resource constraints in trying to make subsidy
notifications.  The major bottlenecks of the Government are insufficient number of trained staff
having a clear understanding on subsidies, lack of proper information regarding subsidies and no
central information centre for such subsidies.  The primary problem is insufficient number of trained
staff.
Q2. 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
It is not the question of how simple is the notification format.  In fact, difficulties arise with
the definition of subsidy and how to estimate the level of subsidy.  It would be appropriate if the
Secretariat develops a guideline for defining subsidies and estimation of level of subsidies including aformat of notification through upd ating the document No, PC/IPL/11.
Q3. 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 much
simplification could be introduced without sacrificing transparency?G/SCM/W/490
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Reply
The government of Bangladesh feels that if the document PC/IPL/11 is revised in line with
the above guidelines, transparency will not be affected.
Q4. 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 making
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 questionnaireformat to make more clear the scope of measures that are subject to notification?  How might
such an explanation be worded?
Reply
As indicated earlier, the individuals dealing with  the issues related to subsidy notification do
not have a clear understanding as to which type of assistance can be considered as subsidy.
Furthermore, they do not have enough expertise for estimation of the level of subsidy.
Q5. Does your government experience general pr oblems 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 itnevertheless be keyed to the data elements of the subsidy questionnaire?
Reply
One of the major problems in making a subsidy notification is collection of information
regarding subsidy from any government.  Various Ministries and agencies are involved in providing
various types of assistance.  So collection and compilation of information is one of the majorconstraints in making subsidy notification.  However, the Government feels that if it could be done
once, difficulties will be much less in making future notifications.
Q6. 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
The Government of Bangladesh has never been engaged in reviewing other Members'
notifications.
Q7. Does your government maintain any info rmation about its subsidy or incentive
programmes on official web sites?  How much wo uld 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 webG/SCM/W/490
Page 3
sites for completed notification questionnaires?  Would references to web sites be a useful
supplement to substantive information provided in a notification?
Reply
The Government of Bangladesh does not maintain any information about subsidy or
incentives programmes on the official web sites.
Q8. Concerning General Rule 6, which requires that  notification of subsidies provided “to
specific products or sectors” be organized on a product- or sector-specific basis, does this rule
pose problems for your government when notifying subsidies that are provided on a horizontal,
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
General rule 6 does not pose any difficulties for us at this stage.
Q9. Does this rule present problems for notifi cation of subsidies that are provided on a
product- or sector-specific basis (e.g., some agricultural subsidies)?
Reply
General rule 6 does not pose any difficulties for us at this stage.
Q10. Would a redrafting of General Rule 6 to refer 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 be
required for subsidies provided on a horizontal basis, which product- or sector-specific
subsidies would continue to need to be notified on that basis.)
Reply
No comment.
Q11. Would such a redrafting pose problems for the review of subsidy notifications, and if so,
what would those problems be?
Reply
No comments.
Q12. 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
At present, the Government of Bangladesh does not have any information regarding the trade
effect of subsidies.  Hence, it is not possible to provide this information.
Q13. 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?G/SCM/W/490
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Reply
It should be mentioned that compilation of subsidy related information is one of the major
constraints of the Government of Bangladesh in making subsidy notifications.  The informationreferred to 9(a) and 9(b) created additional dfficulties in this regard.
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 Government of Bangladesh feels that revi ewing other Members' notifications is important
for its trade expansion.  However, due to lack of expertise in this area, the Government has not been
able to do such a review until now.
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
No.
Q16. 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
Not applicable.
Q17. 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 significantdifficulties to your government in preparing its subsidy notifications?  How might these
requirements be simplified?
Reply
In fact, requirements to provide information on the policy objective or purpose of subsidy
pose difficulties in many cases.  However, we are not in a position to suggest any simplification of
these requirements.
Q18. 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
We are not in a position to respond to this question at this stage.G/SCM/W/490
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Q19. 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
In fact, it is one of the major difficulties faced by the Government of Bangladesh in making
subsidy notifications.  It would be appropriate to develop a guideline for defining and estimation of
amount of subsidy.
C. QUESTIONS PERTAINING TO THE SUBSIDY NOTIFICATION SEMINAR
Q1. Concerning the number and nature of pa rticipants 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?  If
more than one, please describe the differen ces in these individuals ’ responsibilities.
Reply
Various organizations in Bangladesh such as the Ministry of Finance, Bangladesh Bank,
Ministry of Industry and Ministry of Agriculture are responsible for gathering information about
subsidies.  The Bangladesh Tariff Commission and the Ministry of Commerce have the primaryresponsibility for preparing and submitting the subsidy notifications.
Q2. 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?
Reply
It would be appropriate to have at least four participants in the seminar.
Q3. Would two days be a sufficient/appropriate length for the seminar?  If not, what would
be more appropriate?
Reply
Two days might be a sufficient length for the seminar.  An additional one day may be
allocated to deal with country specific problems.
Q4. 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 coordinate 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 emphasized thatto be effective, such follow-up should be immediate and intensive.)  Ideas suggested to date haveincluded establishment of informal contacts am ong capital-based officials, planning of future
focused technical assistance activities, etc.G/SCM/W/490
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Reply
The proposed schedule is good enough to have a first hand knowledge on subsidy
notification.  However, one session may be devote d to the estimation of amount of subsidy and its
trade effect.
Q5. Does your government normally send capital-based representatives to the Committee’s
regular meetings?  If not, why not?
Reply
No, the Government of Bangladesh cannot send capital-based representatives to the
Committee's regular meetings due to financial constraints.
Q6. 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 a
complete and timely manner?  (That is, does your government view the seminar as a priorityevent 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
Yes.
Q7. 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 moreappropriate?
Reply
As mentioned earlier, it is necessary to have four participants from Bangladesh in the seminar
in order to realize the purpose of the seminar.  However, if financial sponsorship is provided to only
one participant, it would not be possible to send additional participants from Bangladesh due tofinancial constraints.
Q8. 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.)?
Reply
It would be appropriate to finance all costs.
Q9. 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?G/SCM/W/490
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Reply
The Government of Bangladesh is not in a position to make any financial contribution to this
seminar.
Q10. 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 participants
from 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
A second opinion would be preferable.
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