RESTRICTEDWORLD TRADE
ORGANIZATIONS/WPDR/M/9
12 March 2001
(01-1185)
Working Party on Domestic Regulation
REPORT ON THE MEETING HELD ON 29 NOVEMBER 2000
Note by the Secretariat
1. The Working Party on Domestic Regulation held its ninth meeting in the afternoon of
29 November.  The agenda for the meeting is contained in Airgram WTO/AIR/1447.  Debateprimarily concerned further discussion of the informal document Checklist of Issues for WPDR .  The
Secretariat introduced its Synthesis  of Members' reports on their domestic consultations with
professional services organizations, as well as a revised listing of international professional
organizations.
A. 
DISCUSSION OF CONCEPTS RELATING TO THE DEVELOPMENT OF REGULATORY DISCIPLINES
2. The Chairperson noted that, as agreed at the previous formal meeting of the Working Party, a
summary of the informal discussions of the Checklist , held in the morning before the formal meeting,
had been circulated for comments, and was subsequently added to the minutes of the meeting.
3. The delegate from Mexico, regarding the minutes of the previous meeting, said that
paragraphs 11 and 12, concerning the development of general disciplines for professional services, did
not fully reflect the view of his delegation, i.e. that Mexico’s preference was to terminate the process
of drafting the disciplines among Members, and then Members could decide whether it was viable to
consult international organizations.  The Chairperson and the representative of Hong Kong, China
noted that the minutes were a summary of views expressed during a discussion held in informal mode.
Item 1- Examples of actual regulatory issues
4. On item 1 of the Checklist  summary, which concerns examples of actual regulatory issues, the
delegation of Japan noted that the Secretariat had agreed to compile a listing of examples, and
enquired on the progress to date.  The Secretariat replied they had reviewed the WPPS accountancy
materials, but did not feel it was appropriate to put out a document until the agreed contributions byMembers had been received.  In response, the delegation of Japan said they wised to provide some
actual examples of the kinds of problems encountered by Japanese services suppliers.  These includedincomplete and opaque legal systems, sudden changes, arbitrary operation, opaque and unreasonable
licensing procedures and procedures (such as licensing criteria and fees).
5. The representative of the United States stated that having a listing would be important, and
urged the Secretariat to provide a listing as soon as possible, without waiting for further contributions
from Members.  The Secretariat replied that, in reviewing the WPPS materials, the most interesting
potential source of information was an OECD contribution, document S/WPPS/W/4/Add2 dated
5 January 1996.
6. The delegate from Canada stated that his government was undertaking a review of their
domestic regulatory measures in respect to their coverage under Article VI:4.  To date, they had not
had much success to date in finding these types of measures domestically.  Canada did have some
examples of problems encountered by their services suppliers when exporting.  They intended toS/WPDR/M/9
Page 2
supply this information to the Secretariat, and were currently attempting to describe the measures in a
manner which did not identify the Member concerned. The delegate suspected that the OECD
document referred to by the Secretariat was unlikely to have many examples not already covered by
Articles XVI/XVII or the accountancy disciplines, and urged Members to make efforts to find other
measures.
7. The representative of Australia said they were also putting together a listing of measures,
which they would make available to the Secretariat.  The delegate from Hong Kong supported the
U.S. view, and urged the Secretariat to go back to the WPPS accountancy questionnaire responses, as
well to items deleted from earlier drafts of the accountancy disciplines.  The delegation of the
European Communities said that regulatory examples were important, and were needed to help draw a
distinction between VI:4 and XVI/XVII measures.  They also wished the Secretariat to put together a
paper, based on the five categories as stated in item 3 of the summary.
8. The Chairperson observed that all the delegations making interventions wanted a draft
Secretariat paper, using available Member contributions and examples from the questionnaires, etc.,
of measures not already contained in the accountancy disciplines.  The delegation of Canada said they
wanted to be very clear on the contents of the Secretariat paper:  i.e., it was to contain specific
measures not already found in the accountancy disciplines, which were also not XVI/XVII measures.
The Chairperson said this was what was intended.  The representative of Malaysia  said they were not
sure of the intention behind a listing, and wished to  know if the Secretariat would be free to examine
the measures currently imposed by Members.  The Secretariat replied that the objective would be to
list VI:4 measures, based on existing WPPS inputs and new inputs from Members, and that countries
would not be named.  There was no intention to identify inconsistent measures.  The first version of
the listing would be a draft, subject to Member revisions.
9. The representative of Argentina said they had no objection to a Secretariat listing, and gave
two examples of applicable measures:  licensing procedures with no specific time-limit for a response
by the authorities concerned;  and minimum capital requirements, which discriminated against smaller
companies.  The delegation of Brazil also agreed to have a Secretariat document, and said the listing
should be structured by the five types of measures specified in Article VI:4.  The Secretariat
confirmed the paper would be based on this structure.  The delegation of the United States observed
that creation of the listing had already been agreed upon at the previous meeting.  The government ofChile also supported a Secretariat list, and noted it would be helpful for domestic professional
associations.  The representative of Malaysia said the list should be limited to WPPS sources and
inputs from Members.  The Chairperson agreed.
10.  The Mexican delegate supported the listing, but preferred to hear the views of individual
Members as well as to have a consolidated listing.  The Chairperson observed that the Secretariat
input to the listing, i.e. existing WPPS materials, was known, but Members’ inputs were unknown.
He stressed that the listing would be a draft, and subject to changes by Members.  The representative
of Malaysia said Members should share their inpu ts to the listing with other Members.  The
Chairperson supported this suggestion.
Item 3 – Legitimate objectives
11. On item 3, regarding legitimate objectives, the delegation of Canada felt that the summary did
not fully reflect the fact that opinion was divided over the issue of creating an illustrative list of
specific objectives.  The delegate from Uruguay noted that the summary had been written under the
Chairperson’s authority, and Members were earlier given the opportunity to make comments.  The
Chairperson welcomed Members' comments, but noted that substantive comments were the most
important.S/WPDR/M/9
Page 3
12. The representative of Mexico said they supported creation of a positive list of legitimate
objectives, but was also of the view that Members should give more consideration to the existing
Article XIV provisions.  The delegation of the United States reiterated that they were not necessarily
opposed to a positive list, but simply had some doubts as to whether it would actually be possible toput together a positive list, as it could become too large or too difficult to reach a consensus on asmaller list.  The representative of Argentina noted that, as at the previous meeting, they were
somewhat sceptical about listing legitimate objectives, because this might duplicate existing GATSprovisions or become such a long listing as to dilute the effect of the disciplines, but said they were
willing to respect the views of the majority.  He observed that the Secretariat, in paragraph 13 of its
earlier informal paper on the necessity test (Job No. 5929, dated 2  October 1999), had also made the
point about focusing on legitimate objectives not already covered by GATS Article XIV.
13. The Chairperson thanked Argentina for reminding Members about the Secretariat document.
The delegate from Hong Kong, China said they shared the views of Argentina, the United States and
Mexico.  He noted that, in respect to the accountancy disciplines, Members had agreed on a relatively
limited list of legitimate objectives, which were largely adaptable on a wider scale.  He also said that
international standards, while still not very widespr ead in services, could nonetheless be referred to in
this respect.  The representative of the European  Communities said that a non-exclusive illustrative
list would be useful, but understood the concerns.  Sh e warned against mixing Article VI:4 disciplines
with Article XIV provisions.
14. The representative of Brazil said a non-exhaustive illustrative list would be useful, but
understood Argentina’s and Hong Kong, China’s arguments.  He suggested that certain criteria could
be used to restrict excessive expansion, e.g. VI:4(b) requirements or paragraph 4 of the GATS
preamble.  He also agreed with Hong Kong, China on international standards.  The delegate from
Thailand was, like Argentina, somewhat sceptical about listing legitimate objectives. On international
standards, she asked clarification on the point made by Hong Kong, China, as her delegation was of
the view that international standards could reduce arbitrariness, but were not necessarily the least
trade restrictive and could even become unnecessarily burdensome.
15. The representative of Uruguay said Members were of the view that the list should not be
exhaustive, and stated it should be a positive list.  The delegation of Switzerland also continued to
have mixed feelings on a list, and said usefulness should be its main criterion.  The representative of
Hong Kong, China observed that useful international standards were emerging in certain services
sectors, but noted there could only be the presumption that such standards were actually the least trade
restrictive.  The representative of Japan said they were open to either a positive or negative list, but
that an exhaustive listing was probably impossible.  The representative asked what kind of functionMembers had in mind for a listing, and whether a necessity test would still be required in respect to
agreed legitimate objectives.  The delegation of Malays ia said they were open to an illustrative list,
and observed that Members would probably appreciate having information on the background of the
legitimate objectives agreed on in the accountancy disciplines.
16. The Chairperson concluded this item by noting th at the Secretariat had suggested starting with
the accountancy list at the next meeting, then adding  or changing elements according to the wishes of
Members as a whole.  He noted that the Secretariat paper, Job No. 5929, contained at least a partial
answer to Malaysia’s question on background.
Item 5 – Criteria for the necessity test
17. The representative of Australia stated that, regarding a question from the previous WPDR
meeting on whether regulatory autonomy was constrained by the necessity test, the chapeau of the
GATS, which unequivocally recognized Members' right to regulate, was overriding.  At the same
time, there were also the mandates given in Articles  VI:4 and XIX, for ensuring that regulations wereS/WPDR/M/9
Page 4
not unnecessarily trade restrictive and promoting trade liberalization, respectively. Regulatory
autonomy was nonetheless preserved, as Members were free to pursue the policy objectives suitable
for their domestic environments.  While pursuing this right to regulate, regulators needed to be
mindful of their GATS commitments, as well as the international trade implications of their regulatory
options;  in the case of Australia, a number of regulations were found to be inconsistent with theirGATS commitments, and had to be rewritten.  When existing GATS requirements were considered,
including GATS Article VI:1 requiring the reasonable administration of measures, Australia therefore
felt that the proposal in their paper for the necessity test was completely consistent with existing
GATS obligations.
18. The delegation of the European Communities enquired whether the Secretariat was preparing
a background paper on jurisprudence relating to the necessity test.  The Secretariat noted there was an
existing paper on this issue from the Committee on Trade and the Environment (document
WT/CTE/W/53/Rev.1, dated  26 October 1998 ), and suggested that, after examining this paper,
Members could decide whether wished to have additional work done.  The Chairperson said there was
the question of updating, after Members had read the document.
Item 7 – Definition of regulation
19.  Returning to the issue of legislative processe s, the delegation of Hong Kong, China said the
summary should state that the issue under discussion was whether these should be excluded in regard
to transparency disciplines.  Their delegation’s view was that disciplines should cover all measures,without exclusions.  The representative of the United States said they were continuing to examine this
issue closely, and noted that many governments would probably be sensitive to the question ofapplying transparency provisions to their legislative processes. The delegate from Argentina said it
would not be appropriate to have some disciplines applicable to all measures, and others applicable toonly a subset, i.e. regulations.  He suggested that, in such cases, Members could instead consideradditional commitments in schedules as an alternative option.  The representative of Brazil agreed
with Argentina’s concerns, saying that the definition of regulation was a very important point.
20. The delegation of Japan said, according to GATS Article 1, paragraph 1, the term “measures”
should be used.  As others had already noted, although the title of Article VI is domestic regulation,
the contents concern “measures”.  On the other hand, the delegation noted that some flexibility may
be required in terms of the application of specific disciplines.  The representative of Uruguay noted
the different realities and legal systems among Members, and said it was necessary to be realistic, and
focus on disciplines applicable to all.  The representative of the United States said the “measures”
mandate was clear, but that it was in the context of developing “any necessary disciplines”.  He saidthat it was still early in the process, and that Memb ers were setting their sights too low if they focused
exclusively on all measures in respect to transparency disciplines.  The delegate from Mexico
supported the comments of the United States and Uruguay, i.e. the need to reflect the various legal
systems.
21. The Chairperson concluded this item by saying it was agreed that Members were only
beginning to discuss these issues.
Item 8 – Transparency objectives
22. The representative of Australia, responding to a question from the previous meeting on the
costs and benefits of transparency, said that transparency benefited consumers and companies most, as
it would assist in creating a more predictable trading environment, and more transparent ways of
doing business, but that there would also be benefits for governments in terms of promoting foreign
market access.  She noted that while transparency had costs, particularly at the sub-national levels, the
use of the Internet and other technologies could help reduce those costs.S/WPDR/M/9
Page 5
Item 13 – Appropriate levels of transparency
23. The representative of Hong Kong, China as ked whether the OECD had conducted work on
cost-benefit analyses in respect to transparency provisions.  The Chairperson asked the Secretariat to
make an enquiry.
Summary
24. The Chairperson concluded the discussions by noting that although not all issues had been
addressed, the debate was very constructive.  The Checklist  had proved useful, and would continue to
be used.  He then asked whether Members would prefer to have their discussions reflected in theminutes in formal or informal mode.  The representative of the United States said either mode was
acceptable, but suggested that the summary of the Checklist discussions be updated.  The
representative of Mexico supported the United States on the Checklist  summary, and said they
preferred the discussion be kept as formal.  The delegation of the European Communities agreed with
Mexico.  The representative of Hong Kong, China said the discussions should be formal, and that the
Checklist  summary should be regularly updated.  The Chairperson concluded by noting Members
agreement with this suggestion.
B. DEVELOPMENT OF GENERAL DISCIPLINES FOR PROFESSIONAL SERVICES
25. The Chairperson initiated discussions on this item by noting that, at the previous meeting, the
Secretariat had been requested to begin compiling a synthesis of Members' replies to date regarding
their domestic consultations with professional services associations, to be revised periodically as new
reports became available.  The first draft of the compilation was circulated as Job No. 7667, dated
29 November.  The Secretariat summarized its paper at the request of the Chairperson , noting that it
had complied with Members requests to clearly indicate the number of reports received, as well as the
fact it was a preliminary paper to revised as additional reports were received.
26. The representative of Thailand then made an oral report on their domestic consultations with
six professions:  legal services, engineering, architecture, nursing, medical services and dental
services.  Generally speaking, the first three groups were of the view that the accountancy disciplines
were not appropriate, while the later three professions felt they would be suitable, with some changes.
Further information would be communicated in a written statement to follow.
27. The delegate from Chile stated that his government had already received replies from
engineers, psychologists, sociologists, veterinarian s, and doctors, and were awaiting further replies
before submitting a written statement.  He noted that all these associations had stated that the general
principles expressed in the accountancy disciplines could be applied to their professions, with somechanges needed in regard to ethics, insurance for professional liability, etc.  The delegation of
Uruguay welcomed the Synthesis paper, and asked that a footnote be added in respect to Uruguay on
the first page, stating that the contributions received from some professions to date did not prejudicethe government’s views, together with some additions regarding specific professions.
28. The Chairperson said he and the Secretariat welcomed comments on the text.
29. The representative of Mexico reported on the progress of domestic consultations, with respect
to medicine and architecture.  Noting that reciprocity agreements could be used by educational
institutions for the benefit of students and the medical  profession, he stated that the lack of acceptance
of reciprocity agreements with Mexican universities by some countries was an obstacle to the
implementation of the disciplines.  The disciplines should therefore specifically take such exchanges
into account.  For architecture, he said that principles of reciprocity should also be applied forS/WPDR/M/9
Page 6
exchange of professional services.  The architects had stated that the accountancy disciplines would
be acceptable, with modification.  The delegate conc luded by stating that other professions were being
consulted.
30. The representative of Canada said that the first draft of the Synthesis looked acceptable in its
structure, and that Canada would make a further report on its domestic consultations at the next
meeting.  He noted that, generally speaking, the feedback received on the accountancy disciplines had
been very positive.  The representative of Hong Kong, China said the Secretariat report was an
excellent beginning, and hoped that Members would add further replies.  The delegate from Mexico
requested his points to be added to the Synthesis, and said that a written report would be submitted.
He pointed out that, generally speaking, the professions reporting had found the accountancy
disciplines appropriate.
31. The Chairperson concluded this item by stating that he hoped that the oral reports to the
meeting would soon be followed by written ones.
32. Regarding consultations with international professional services organizations, the
Chairperson noted that Members had agreed to have the Secretariat revise the listing of international
organizations to be consulted, containing organizations selected by Members, to remove regionalorganizations not open to all WTO Members.  This revision was circulated as Job No. 2139/Rev.3,
dated 28 November.  The Secretariat then introduced the paper, noting that in some cases it was
difficult to make a judgement on which organizations to retain, and asking for Member’s views on the
issue.
33. The delegation of Thailand said they would examine the changes, and state their opinion later.
The representative of Mexico said they wished to again note Mexico’s position on this issue.
C. DATE OF NEXT MEETING
34. The Chairperson suggested that an informal WPDR meeting be held in February 2001 before
the next formal meeting, which he recommended be held in March in connection with the next
meeting of the Council.  The delegation of the European Communities said this was a good idea, and
Members approved the suggestion.S/WPDR/M/9
Page 7
ANNEX
SUMMARY OF DISCUSSION ON THE CHECKLIST OF ISSUES FOR WPDR
(As requested by Members at the WPDR meet ing of 29 November, this summary will be
continually updated on the Chairperson’s responsibility to reflect the current views of Members
on the Checklist of Issues for WPDR (Job No. 5067, dated 17 August 2000).   Like the Checklist,
this summary does not prejudge the scope or cont ent of the issues discussed, nor the ability of
Members to raise other related issues.)
General issues
One Member stated that consideration should be given to the temporary nature of GATS
Article VI:5.  The Secretariat was asked to comment,  and stated that Article VI:5 would need to be
addressed following the creation of regulatory disciplines under Article VI:4.
1. Examples of actual regulatory issues:
Members agreed to have the Secretariat list examples of the kinds of measures that would be
addressed by disciplines under GATS Article VI:4, based on contributions by Members and a reviewof the Working Party on Professional Services accountancy materials by the Secretariat.  The
Secretariat paper was to list specific measures not already found in the accountancy disciplines, which
were also not XVI/XVII measures. The Chairman noted that the elaboration of this list would not
preclude parallel discussions among Members on the same issue.
2. Linkage between transparency and necessity:
Delegates referred to both the advantages (increased accountability) and disadvantages
(additional administrative burden) of greater transparency.  Several delegations stated that greater
transparency in the regulatory process could contribute to ensuring that regulations would not be more
trade restrictive than necessary.  However, some also said that transparency alone had its limits, and
therefore could not be a substitute for regulatory disciplines.  The Chairperson asked the delegationsgiving comments to further elaborate their viewpoints in subsequent discussions.
Necessity
3. Legitimate objectives:
Many  Members making comments favoured the creation of a concise, non-exhaustive,
illustrative list of legitimate objectives. Many also  felt a listing of "non-legitimate objectives" would
be too limiting, and was undesirable. A number of delegations stated they were not necessarily
opposed to a positive list, but simply had some doubts as to whether it would actually be possible toput together a positive list, as it could become too large or too difficult to reach a consensus on a
smaller list.  One Member said that international standards, while still not very widespread in services,
could nonetheless be referred to in this respect.
Several delegations were of the view that Members should give more consideration to the
existing Article XIV provisions.   One Member stated that priority should be given to the creation of
specific disciplines, and the listing of legitimate objectives should come afterward. Another
delegation said the determination of legitimate objectives rested solely with Member governments. A
third delegation asked what kind of function Members had in mind for a listing, and whether a
necessity test would still be required in respect to agreed legitimate objectives.  The issue ofS/WPDR/M/9
Page 8
horizontal- versus sectoral-level listings of legitimate objectives was generally thought to be an issue
for negotiation.
4. Scope of the necessity test:
Nearly all the delegations making comments felt that GATS Article VI:4 did not extend
beyond the five items listed.  The definitions in paragraph 4 of S/C/W/96 were generally felt to beacceptable, but could be reviewed if necessary.  Some delegations said any horizontal disciplines
should only be applicable to sectors where specific commitments have been made;  other delegations
felt this was also an issue for negotiation.
5. Criteria for the necessity test:
The Chairman noted that documents on this topic had been submitted by Members.  Several
delegations said they had begun domestic analyses of the implications of the differences interminology.  One Member asked where the burden of proof would lie in respect to necessity.
Another expressed concern over the Working Part y attempting to define terms whose application
extended beyond services trade and should be defined by panels or the Appellate Body.
One delegation stated that, regarding the question of whether regulatory autonomy was
constrained by the necessity test, the chapeau of the GATS, which unequivocally recognized
Members right to regulate, was overriding.  At the same time, there were also the mandates given in
Articles VI:4 and XIX, for ensuring that regulations were not unnecessarily trade restrictive and
promoting trade liberalization, respectively. Regulatory autonomy was nonetheless preserved, as
Members were free to pursue the policy objectives suitable for their domestic environments.  Whilepursuing this right to regulate, regulators needed to be mindful of their GATS commitments, as well
as the international trade implications of their regulatory options.
The Secretariat was asked whether it had previously compiled information on the
jurisprudence relating to the application of necessity in the WTO. The Secretariat noted there was anexisting paper on this issue from the Committee on Trade and the Environment (document
WT/CTE/W/53/Rev.1, dated 26 October 1998 ), and suggested that, after examining this paper,
Members could decide whether wished to have additional work done.  The Chairperson said there was
the question of updating, after Members had read the document.
A question was raised concerning whether there was a difference between restrictiveness and
burdensomeness in the context of Article VI:4.  The Secretariat replied that there was a difference,and that a measure could be more burdensome than necessary, but not to the point of being trade
restrictive and vice-versa.
6. "Third aspect" of the necessity test:
One delegation said that consideration must be give to the criteria to be used in applying the
"third aspect" (i.e. the idea that a measure that has the effect of restricting trade can be considered
"necessary" only if there is no alternative measure less restrictive of trade which may be reasonably
available to a Member to achieve the same policy objective);  another delegation said that the "third
aspect" could be excessively burdensome considering the vast scale of services sectors.  The reply
was made that the "third aspect" was in fact a means for examining alternatives to particular
regulations.S/WPDR/M/9
Page 9
Transparency
7. Definition of regulations:
One delegation stated it wished to clarify that , in the context of transparency disciplines,
legislative processes were excluded from consideration by the Working Party as one of the types of
regulation to which prior comment requirements could be applied.  Other delegations agreed, but feltthere may be no need for a new definition, as regulations were already included under the GATS term
"measure" as defined in Article XXVIII.  One delegation stated that their only legislative mechanism
for prior comment was for standards under the TBT and SPS agreements.  One representative said the
“measures” mandate was clear, but that it was in the context of developing “any necessary
disciplines”.  The representative said that it was still early in the process, and that Members were
setting their sights too low if they focused excl usively on all measures in respect to transparency
disciplines.
A number of delegations were of the view that  it would not be appropriate to have some
disciplines applicable to measures, and others applicable to only a subset, i.e. regulations.  One
delegation suggested that, in such cases, Members could instead consider additional commitments in
schedules as an alternative option.  Another delegation said that some flexibility may be required in
terms of the application of specific disciplines.  A third delegation noted the different realities andlegal systems among Members, and said it was necessary to be realistic, and focus on disciplines
applicable to all.
One delegation said that Members should consider whether regulations as defined under the
GATS were equivalent to those as defined under the TBT and other WTO agreements, and whether
notification requirements should only apply in areas where no international standards existed.
8. Transparency objectives:
Several delegations urged caution in regard to further transparency obligations, and asked
Members to consider costs as well as benefits.  They noted this item was related to item 12 of the
Checklist concerning administrative burden.  One delegation stated that dual standards of notification,
e.g. between different levels of government, could not be permitted in regard to transparencyprovisions.
Responding to a question on the costs and benefits of transparency, one delegate said that
transparency benefited consumers and companies most, as it would assist in creating a more
predictable trading environment, and more transparent ways of doing business, but that there would
also be benefits for governments in terms of promoting foreign market access.  The delegate noted
that while transparency had costs, particularly at the sub-national levels, the use of the Internet and
other technologies could help reduce those costs.
9. Prior comment provisions:
A number of Members opposed the creation of any prior comment provisions, saying they
were unnecessarily burdensome, especially for sub-national entities.  Some delegations stated that
prior comment provisions as part of the law-making process were not permitted under their domesticlegislation.  One Member observed that the accountancy disciplines have a "best endeavours" clause,
and said this could be repeated. Other Members said caution was required, and that the definitional
and prior comment issues needed to be examined in greater detail.S/WPDR/M/9
Page 10
10. Notifications related to prior comment provisions:
One delegation said that notifications in government gazettes should be the minimum
requirement, with Internet listings also encouraged, but that notifications to the WTO were not
required.  Others, as noted above, opposed the creation of any prior comment provisions.
11. Compliance with existing notification requirements:
Several delegations stated that the notification requirements under GATS Article III were not
being observed, and needed strengthening.  Other delegations were opposed, stating that Members
already had difficulty meeting existing requirements.   One delegation said there seemed to be some
confusion among Members concerning the differences in the transparency criteria of Article VI and of
Article III.
13. Appropriate levels of transparency
One delegation asked whether the OECD had conducted work on cost-benefit analyses in
respect to transparency provisions.  The Chairperson asked the Secretariat to make an enquiry.
Note:  Comments on item 12 (Administrative burden) of the Checklist were made in the context of
discussion of other items.  No separate comments were made.
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