JOB/AG/181  
 
19 February 2020  
(20-1296) Page: 1/26 
Committee on Agriculture  
Special Session  Original: English  
 
NOTIFICATION OF SELECT DOMESTIC S UPPORT VARIABLES IN THE WTO  
SUBMISSION BY THE UN ITED STATES  
The following submission , dated 17 February  2020, is being circulated at the request of the 
delegation of the  United States . 
 
_______________  
 
 
1  OVERVIEW  
1.1.  WTO agriculture notifications are an important part of the implementation process of the 
Agreement on Agriculture (AoA), providing valuable insights into the agricultural trade policies of 
Members and providing a basis for compar ing applied levels against bound commitments.1 WTO 
agriculture notifications can also be a useful tool to compare how measures are implemented across 
Members and provide a basis for informed technical discussions in the agricultural negotiations.  
1.2.  Of the re gular annual notifications, Table DS:1 – detailing the monetary value, description, and 
classification of domestic support measures – is one of the most complex and also one of the most 
discussed in the Regular Session of the Committee on Agriculture ( CoA).  
1.3.  The United States has identified several areas within the domestic support pillar where CoA 
discussions are driven by inquiries seeking to gain further transparency in relation to notifications. 
These areas include: (1) market price support (MPS) (speci fically eligible production, adjustments 
to the fixed external reference price, and product basis); (2) negative support levels; 
(3) classification and non -notification; (4) currency and inflation , and (5) value of production  (VoP)  
data. This list is not e xhaustive.  
1.4.  For each area, this paper attempts to summarize what information has been provided through 
notifications and what has had to be discerned from questions posed in the CoA. This summary is 
based primarily on a review of notifications submitted by Members covering the 2005 to 2018 
notification years, as well as responses to CoA questions dating back to 1995.  Additional Members 
and years were drawn upon in a limited number of c ircumstances to provide a fuller illustrative 
discussion.  
1.5.  This paper is intended to support Members ' ability to engage in a technical discussion regarding 
transparency in notifications.  
 
1 In total there are 12 notification requirements in agriculture falling into one of five areas: (1) market 
access, (2) domestic support, (3) export subsidies, (4) export prohibitions and restrictions, and (5) follow -up 
to the Marrakesh NFIDC Decision.  Of the 12 notification requirements, five are regular or annual notifications, 
namely Table MA:2, Table MA:5, Table DS:1, Table ES:1, and Table ES:2.  As of 13 June 2019, a total of 4,632 
agricultural notificatio ns have been submitted to the WTO.  See G/AG/GEN/86/Rev.35.  JOB/AG/181  
 
- 2 - 
 
  2  MARKET PRICE SUPPORT   
2.1  General background  
2.1(a) Market price support in the AoA  
2.1.  Under the rules of the AoA, Members calculate the Current Total Aggregate Measurement of 
Support (AMS) for purposes of notifying their current trade -distorting domestic support levels 
against their permitted levels, reported as the Final Bound Total AMS.  Where Members have no Final 
Bound Total AMS, the Members ' limit is the de minimis  level, expressed as a percentage of the VoP.  
2.2.  Annex 3, paragraph 1 of the AoA provides that AMS "shall be calculated on a product -specific 
basis for each bas ic agricultural product receiving market price support, non -exempt direct 
payments, or any other subsidy not exempted from the reduction commitments".  Annex  3 further 
provides a specific calculation methodology for determining the value of MPS.  
2.3.  Pursuant t o Annex 3, paragraph 8 of the AoA:  
[M]arket price support shall be calculated using the gap between a fixed external reference 
price and the applied administered price multiplied by the quantity of production eligible to 
receive the applied administered p rice. 
It is in the context of this language that Members notify their MPS measures in Table DS:1.   
2.4.  Since 2005, approximately one -quarter of Members ' Table DS:1 notifications have included 
MPS for one or more commodities  (Figure 1) .2, 3 While there is a downward trend since 2012 in the 
number of Members notifying MPS (see blue bars), this appears to be largely due to users of MPS 
having not submitted their Table DS:1 notifications (see yellow bars) rather than a move away from 
the use of these measures.  In total 24 Members have notified MPS during the 2005 -2018 period.4  
Figure 1: Members notifying market price support, 2005 -2018  
 
Source:  WTO notifications and G/AG/GEN/86/Rev.5 . 
 
2 Since 1995, 37 Members have notified MPS in their Table DS:1.  
3 A more recent time period dating back to 2005 was used solely for the purpose of reducing the 
number of notifications reviewed and analy sed. 
4 As of June 2018, Bangladesh;  Brazil;  Canada;  China;  Costa Rica;  European Union;  Iceland;  India;  
Indonesia;  Israel;  Japan;  Jordan;  Korea, Republic of; Lao PDR; Norway;  Pakistan;  Philippines;  
Russian  Federation;  Saudi Arabia, Kingdom of; Switzerland;  Chinese Taipei ; Tunisia;  Ukraine  and the 
United  State s. This paper does not include current European Union member States that made notifications 
prior to joining the European Union.  
00.050.10.150.20.250.30.35
0510152025
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Percent of Table DS:1 NotificationsNumber of Members
Notification Year
Members Whose Most Recent Table DS:1 includes MPS, but Have Not Notified Table DS:1
Members Who Notified MPS
% of Table DS:1 including MPSJOB/AG/181  
 
- 3 - 
 
  2.5.  Of these 24 Members , 20 notified MPS for cereals and preparations, with wheat , rice, and maize 
being the commonly notified products within the commodity group (Figure 2) . Cereals was followed 
by dairy products as the second largest commodity group with eight Members notifying either dairy, 
milk, or specific dairy products.  Seven Me mbers notified MPS for oilseeds, fats, and oils with the 
same number also notifying MPS for sugar . 
Figure 2: Number of Members notifying MPS by commodity group, 2005 -2018  
 
 
2.6.  For the analysis contained in this paper, the United States reviewed more than 2,500 CoA 
domestic support questions regarding Members ' notifications, Article 18.6 and Article 18.7.5 Of the 
questions reviewed more than 15 % concerned MPS measures, making MPS  one of the most 
frequently discussed measure types in the CoA. More specifically, of the nearly 500 questions raised 
regarding MPS, more than one -half touched upon at least one of the three main components used 
in calculating MPS: eligible production, app lied administered price, or fixed external reference price.  
Because many questions regarding MPS raised more than one issue, a total of more than 800 issues 
were raised in the CoA covering the three MPS -specific topics, as well as six broader topics that d o 
not relate solely t o MPS (e.g., currency, inflation, negative values, VoP, product basis, and other)  
(Figure 3) . 
 
5 Based on a review of the AG IMS system.  Due to the volume o f questions in the AG IMS system and 
certain issues regarding the ability to systematically identify questions by topic, the United States does not 
consider that this review is likely to include all relevant questions.  However, all efforts were made to ide ntify as 
many as possible.  This review includes questions to the 24 Members that notified MPS during 2005 -2018, as 
well as three Members that had been asked numerous questions about the non -notification of MPS measures.  
JOB/AG/181  
 
- 4 - 
 
  Figure 3: Topics raised in CoA questions regarding MPS, 1995 -2018  
 
Note:  A total of 470 questions were identified regarding MPS, some questi ons were multipart and covering 
multiple topics.  
Source:  WTO AG IMS . 
2.2  Eligible production  
2.7.  In reviewing the notifications of the 24 Members that notified MPS during 2005 -2018, only 
seven included information in their notification clarifying what the volume of eligible production 
represents for at least one product.  These Members are Canada;  Israel;  Japan;  Pakistan;  
Saudi  Arabia,  Kingdom of; Ukraine and the United States.  In many cases, it is only through follow 
up questions in the CoA that it has been  possible to identify how Members are calculating their 
eligible production – specifically, whether the figure reported represents the entirety of a crop for a 
specific product, or some subset of the crop, and if the latter, what the reported subset is.   
2.8.  Where a Member self -identifies an eligible production figure for a commodity that represents a 
subset of the crop, other Members may face difficulty in understanding the significance of the 
reported figure.  This difficulty stems from the fact that current r eporting procedures do not elicit 
information that could shed light on the significance of the figure.  
2.9.  A self-identified eligible production figure that is less than the entirety of the crop may be the 
result of features in the reporting Members ' MPS progr am that leave only a portion of the crop 
eligible to receive market price support.  Alternatively, a self -identified eligible production figure that 
is less than the entirety of the crop may reflect misapplication of AoA rules for identifying eligible 
produ ction.   
Eligible Production
AAP: Applied 
Administered Price 
FERP: Fixed 
External Reference 
PriceCurrencyInflationNegative ValuesSubnationalOtherVOPProd. BasisJOB/AG/181  
 
- 5 - 
 
  2.10.   Approximately 22 % of the topics raised about MPS in the CoA concerned eligible production.  
A review of Members ' notifications in combination with Members ' responses to questions raised in 
the CoA reveals that Members have put forward figures for el igible production based on five broad 
categories: (1) Total National/Regional Production, (2) Total National Production Less a Specified 
Amount, (3) Pre -Determined Targeted Quantities, (4) Procured Quantities, and (5) Unknown.   
2.11.   Members ' discussions on eligible production in the CoA often appear to be aimed at 
understanding these differences and how they are notified, as it is not always apparent from a 
notification itself.   
2.2(a) Eligible Production: Two Members have notified total production, three Members 
have clarified through CoA responses  
2.12.   Two Members, Japan and the United States, have included a footnote in their notification, and 
further clarified in response to questions in the CoA, that all production within the designated area 
– either the entire country or specified sub -region – is entitled or fit to receive the applied 
administered price for at least one product ( Table 1) . Three Members, Costa Rica, Norway and Japan 
have clarified a similar approach in response to CoA questions . As an example of how measures 
typically operate under this definition, the United States ' former dairy products price support 
program, which provided price support for cheddar cheese, non -fat dry milk, and butter, typically 
purchased limited quantities o f each of these products when the program was being implemented.6 
However, despite limited procurement, the United States notified total national production of each 
product as the relevant eligible production.  
 
6 Note, the United States ' Dairy Pro ducts Price Support program was terminated with the 
2014 Farm Bill.  
  JOB/AG/181  
 
- 6 - Table 1:  Notifications are not providing basis for eligible production figures used, 2005 -2018  
Member  Basis for 
eligible 
production 
figures used Product(s)  Information derived from notification or responses to  
Members ' questions in CoA AG IMS  
Bangladesh  Unknown  Rice (Amon, Boro)  Notification   0 
CoA  
Brazil  Procured 
Quantities  Maize  
Wheat  
Rice 
Coffee  
Cotton  
Edible beans  
Sisal Notification   14 
 
13068, 26043, 
44019, 49023,  
59024, 59027,  
66002, 66027,  
70062, 74042,  
79037,  83076  CoA In response to ID 74042, Brazil states "In the case of 'Aquisições do Governo Federal – AGF' (a 
minimum support price programme), the amount of production notified in Supporting Table DS:5 
represents all production that was purchased under that programme , according to the available 
budgetary outlays. As regards the 'Public Option Contracts ', the other Brazilian minimum support 
price programme, the amount of production notified in Supporting Table DS:5 represents all 
production that could be sold to the gove rnment (i.e. the contracted quantity) by producers in 
public auctions ." 
Canada  Total National 
Production 
Less a Specific 
Amount  Milk 
  (butter,  
  skim milk  
  powder)  Notification  G/AG/N/CAN/113: The footnote to STDS:5 states eligible production is "total production less 
product sales for further processing and animal feed under Classes  (Special Classes for skim milk 
powder) 5a, b and c (and 4m for skim milk powder) less total expor ts plus that portion of exports 
that had received the support price ". 13 
 
23076, 23077, 
25023, 43017, 
46011, 47020, 
61023, 70066, 
83079, 84107, 
85011, 88053, 
89075  CoA In response to the EU in ID 89075, Canada states "Sales of butter and skim milk powder for 
further processing, total exports and skim milk powder for animal feed are not counted as eligible 
production  in the calculation of market price support since sales of these products for these uses 
are not eligible to receive the support price. All production of butter and skim milk powder that is 
eligible to receive the support price (not that which is purchased) is counted as eligible production  
in the calculation o f market price support. " 
China  Procured 
Quantities  Corn 
Wheat  
Rice 
  (Japonica,  
  Indica)  
Cotton  
Soybeans  
Rapeseed  
Sugar  Notification   18 
 
59037, 59038,  
64053, 64054, 
64055, 65049, 
77011, 77025, 
77056, 77077, 
78068, 79013, 
85021, 88040, 
90077, 90092, 
90094, 90096  CoA In response to ID 65049, China states "…China uses the actual purchased quantity of grain at the 
minimum purchasing price  to calculate market price support amounts ", adding in ID 64054/64055 
that "China used the actual amount of crops procured under the minimum procurement price 
scheme as  'eligible production '…" 
In response to ID 90077, China states "Farmers of the regions where the [minimum purchase 
price and temporary reserve] policies were applied could sell their products at the administered 
prices, if the products could meet the quality and other related requ irements. " 
In response to ID78068, China states "the Minimum procurement price policy is implemented in 
a defined region (the major production region) and a defined time (the harvest season), which in 
reality constitutes limitations for the quantity of pro curement. "   
  JOB/AG/181  
 
- 7 - Member  Basis for 
eligible 
production 
figures used Product(s)  Information derived from notification or responses to  
Members ' questions in CoA AG IMS  
Chinese 
Taipei  Pre-
Determined 
Target 
Quantities  Rice 
  (Japonica,  
  Indica)  
Sugar  
Tobacco  Notification   3 
 
46017, 71007,  
91166  CoA In response to ID 91166, Chinese Taipei states, "The government would announce all purchase 
prices and quantity limits to the public before each harvest … [T]otal eligible quantity of 
guaranteed price purchase is lower than the quantity actually harvested …" 
In response to ID 71007, Chinese Taipei states "Regarding the quantity of production eligible to 
receive the applied administered price, the planned purchases of rice are made only from farmers 
in certain areas, and the rice has to be of a certain specifie d quality . Those farmers not qualified 
or whose quality of rice does not meet the set criteria are not eligible to join the programme. " 
In response to ID 46017, Chinese Taipei states "under our guaranteed -price programmes for rice, 
tobacco and sugar, only part of the production can receive the support, subject to certain 
conditions . Therefore, the amount of eligible production used in the calculation of market price 
support is not the total amount produced  of these commodities ". 
In response to ID 91166, Chi nese Taipei states "There is no limit on the purchase quantity of 
sugar and tobacco leaves . All crop produced under the contract will be purchased by TSC and 
TTLC. Under the contract guaranteed -price program of sugar, the crops of specific species or 
cultivated in the prescribed plantation area will be given the priority to be included in the contract. 
As for the domestic tobacco leaves, there is no restriction in terms of the production area. 
However, the certain quality standards need to be met ." 
Costa Rica  Total/Regional 
Production  Rice Notification   1 
 
82039  CoA In response to ID 82039, Costa Rica states "the eligible production  of 11,887 tonnes corresponds 
only to rice production  of January -February 2015 ". 
European 
Union  Pre-
Determined 
Target 
Quantities  Beef 
Wheat  
(durum, 
common)  
Barley  
Maize  
Sorghum  
Oats  
Triticale  
Butter  
Skim Milk Powder  
Olive oil  
Sugar  Notification   8 
 
24042, 58022, 
66064, 69017, 
69053, 73047,  
83126, 87030  CoA In response to ID 87030, the EU states "There is no longer an automatic obligation for EU to buy 
beef meat into intervention. Regulation (EU) No 1308/2013, Article 13(1)( c) provides that if the 
market prices falls below 85% of the reference threshold pric e then the EU may  open a tender to 
buy beef meat for the types of meat that qualifies for intervention . As a consequence of this change 
of op legal framework and based on the outcome of the panel in Korea/beef there is no 'eligible ' 
beef meat production du ring 2014/15 marketing year for the purposes of the AMS calculation. " 
In response to ID 69017, the EU states "The current European Union's notification under review 
includes changes resulting from the decisions of the Health Check of the CAP which was agre ed in 
2008 and implemented since the 2010 EU budget year. The Health Check sets limits of buying into 
public intervention at  'zero' for durum wheat, barley, maize, sorghum and paddy rice  as provided 
for in Article 13.1(a) of Council Regulation (EC) 1234/20 07. As a result, public intervention is not 
automatically available for these products. A reply to the second question is that there have been 
no purchases of these products into public intervention since these changes were introduced. "  
In response to ID 66064, the EU states "The European Union has applied a consistent approach in 
the price gap calculation and has used the entire European Union production of the products for 
which the intervention is open ." 
In response to ID 83126, the EU states "…the EU takes into account total common wheat as eligible 
production  in calculating its Market Price Support (MPS) ".  
  JOB/AG/181  
 
- 8 - Member  Basis for 
eligible 
production 
figures used Product(s)  Information derived from notification or responses to  
Members ' questions in CoA AG IMS  
Iceland  Unknown  Milk Notification   1 
 
86013  CoA  
India  Procured 
Quantities  Coarse cereals  
  (bajra, jowar,  
  maize,  
  barley, ragi)  
Wheat  
Rice 
Cotton  
Pulses  
  (gram, arhar,  
  urad, moong, 
lentils)  
Mustard  
Mustard seed  
Rapeseed/  
  Mustard  
Sunflower  
Groundnut  
Soybeans,  
  yellow  Notification   38 
 
63056, 63057,  
63058, 65061,  
67028, 73053,  
75018, 75062,  
75076, 75114, 
75121, 75123, 
76072, 77084, 
77114, 78036, 
78041, 83009,  
84071, 85021, 
85029, 85090,  
85091, 85104, 
85105, 86016,  
86094, 86110, 
87017, 87024,  
87068, 88130, 
88042, 88068, 
91101, 91177  CoA In response to ID 86094, India states, "Only a portion of the marketable surplus offered by the 
farmers, and meeting prescribed specifications, is procured under MSP operations. The eligible 
production is, therefore, the quantity, which is actually procure d at administered price. " 
In response to ID 63057, India states it uses "the quantity of purchased production as 'eligible 
production ' for calculating the market price support ". 
Indonesia  Procured 
Quantities  Rice Notification  G/AG/N/IDN /26: The footnote to STDS:5 states that eligible production in 2000 is based on the 
BULOG 's procurement.  3 
 
29032, 89041,  
89078  CoA In ID 89041, Indonesia states "With respect to the determination of eligible production, the 
quantities that Indonesia provides in its notifications were the procured quantities used for market 
operations for price stabilization . Regarding the quantity of rice that BULOG may procure, it  is 
limited to the amount stipulated in BULOG's annual budget . This budget is also reflected in the 
State Budget. " 
Israel  Pre-
Determined 
Target 
Quantities  Milk  
Eggs  
Poultry Meat  
(production quotas 
and guaranteed 
min. price)  Notification  In G/AG/N/ISR/66, Israel notifies  "absorption of surplus " for vegetable products and  "production 
quotas and guaranteed min. price " for milk and eggs. The notification background section states 
"…despite the continuous decrease in the administered target price  for milk, in 2017 the market 
price support has increased due to the increased quota in line with population growth ".  2 
 
26058, 67033  
CoA In response to ID 67033 regarding why there is no eligible production of poultry, Israel states 
"there is no effective production quota for poultry ". 
Israel  Unknown  Milk, Eggs, 
(production quotas 
and guaranteed 
min. price)7 Notification   0 
CoA  
 
7 In G/AG/N/ISR/66, Israel notifies market price support for "production quotas and guaranteed minimum price ". The "total production quotas " are categorized 
under pre -determined targeted quantities above.  Israel reports eligible production and external reference prices for tomatoes, cucumbers, onions, and potatoes, but no 
applied administered price. Israel's notifications do not provide an exp lanation of how the "absorption of surplus" is operated. The United States has excluded it from this 
analysis.   
  JOB/AG/181  
 
- 9 - Member  Basis for 
eligible 
production 
figures used Product(s)  Information derived from notification or responses to  
Members ' questions in CoA AG IMS  
Japan  Total/Regional 
Production  Beef and veal  
Meat of Swine  
Silkworm Cocoons  
Sugar  
 (beet, cane)  Notification  G/AG/N/JPN/137: The footnote to STDS:5 states that eligible production for beef and veal, meat 
of swine, silkworm cocoons and sugar is equal to to tal production .  3 
 
30052, 31042, 
52021, 63063  CoA  
Japan  Total National 
Production 
Less a Specific 
Amount  Starch  
  (potato,  
  sweet      
  potato  Notification  G/AG/N/JPN/137: The footnote to STDS:5 states that eligible production for potato and sweet 
potato is equal to the production of potato and sweet potato for the manufacture of starch.  5 
 
12099, 30052,  
40023, 42030, 
52020  CoA In response to ID 30052, Japan states "Of the total production of sweet potatoes  (1.18 million 
tonnes) 295,000 tonnes is used for the production of starch , for which the market price support is 
applied. " 
Japan  Procured 
Quantities  Barley  
Wheat  Notification  G/AG/N/JPN/137: The footnote to STDS:5 states that eligible production for wheat and barley is 
the government purchase volume . 5 
 
12099, 30052,  
40023, 42030,  
52020  CoA In response to AG -IMS ID 42030, Japan states "Until 1999, the Japanese government purchased 
a large part of the domestic wheat and barley production to support the domestic price. As from 
2000, most of domestic wheat and barley production has been marketed  via the private sector. 
This has resulted in the quantity of domestic production receiving price support being substantially 
reduced to the amount purchased by the government. Market price support is calculated on the 
basis of the quantity of production a ctually purchased by the government  and eligible to receive 
the administered price, in accordance with paragraph 8 of Annex 3 of the Agreement. In the past 
Japan has used for certain agricultural products the total quantity of production as the quantity fo r 
the AMS calculation. However, in the case of wheat and barley, the products are primarily marketed 
through the private sector since 2000, and government purchases are very limited. The price paid 
by the government has no support effect on the price of th ese products. " 
Jordan  Procured 
Quantities  Barley  
Wheat  Notification   4 
 
57012, 64070,  
77085, 83089  CoA In response to ID 57012, Jordan states, "…Such eligible production figures represent the quantities 
purchased by the Government , but do not equal the total quantity of production. " 
In response to ID 64070, Jordan states "…The procurement of wheat and barley by the government 
is subject to certain specifications to ensure better quality . The government tends not to purchase 
crops that do not me et quality standards. Some local production that does not meet the standards 
is sold domestically or exported. " 
Korea, 
Republic of  Procured 
Quantities  Barley  
(naked, unhulled)  
Maize  
Soybeans  Notification   4 
 
17055, 20050, 
20053, 64075  CoA In response to ID 64075, Korea states it "...has consistently used 'production actually purchased ' 
as 'eligible production ' since the time it calculated the initial Base Total AMS. This methodology is 
consistent with Article 1(a)(ii) of the AoA". 
Lao PDR Procured 
Quantities  Rice Notification   1 
 
87032  CoA In response to ID 87032, Lao PDR states "In supporting Table DS:5, Lao PDR determined the 
notified quantity of eligible production of 36,157 tonnes based on the actual subsidized amount of 
the rice production instead of the total amount of rice production  to be eligible. "  
  JOB/AG/181  
 
- 10 - Member  Basis for 
eligible 
production 
figures used Product(s)  Information derived from notification or responses to  
Members ' questions in CoA AG IMS  
Norway  Total/Regional 
Production  Wheat  Notification   3 
 
86018, 86098  
87152  CoA In response to ID 87152, Norway states that "at the CoA meeting in February 2018 Norway 
answered a question from Canada (ID 86018) related to market price support for wheat " and would 
like to underline that "wheat not fulfilling the criteria for human consumption is indeed included in 
the calculation of market  price support for wheat  but is subject to a lower price than wheat for 
human consumption. The variation in market price support for wheat from one year to the next is 
thus a result of variations in both the total amount of eligible production  and the appl ied 
administrative price, based on the portion of wheat for human consumption and animal feed 
respectively ". 
Norway  Total National 
Production 
Less a Specific 
Amount  Milk 
Goat milk  
Pork 
 Barley  
 Oats Notification   3 
 
86018, 86098, 
87152  CoA In response to ID 86018, Norway states that notified EP amounts for all products in question are 
the same as the amounts in the total production figures from Statistics Norway  less specified 
volumes  since the excluded volumes are not eligible to receive th e applied administered price. In 
the case of wheat, barley and oats, the notified amounts exclude seed production . In the case of 
milk, the notified EP amounts are limited to milk delivered to dairies . The volumes consumed or 
processed on farms are not included in the notified EP amount. In the case of pork, the notified 
EP amounts exclude on -farm consumption and sow or boar meat .  
 
Norway  Unknown  Beef and veal, 
Poultry, Eggs, Rye, 
Oilseeds  Notification   0 
 CoA  
Pakistan  Pre-
Determined 
Target 
Quantities  Wheat  Notification  G/AG/PAK/16: The footnote to STDS:5 states that eligible production is "actual procurement by 
public sector agencies on pre -determined targets  from resource poor farmers defined in 
Article 6.2". 9 
 
15091, 20059,  
77022, 77063,  
77019, 77093,  
88033, 88124, 
88125  CoA In response to ID 77063, Pakistan states "All wheat produced in Pakistan is not eligible for 
procurement because the procurement policy is based on pre -determined targets . Bags are 
distributed for procurement to poor farmers after verification of land record and only those farmers 
who have received bags are eligible to sell. " 
In response to ID 77093, Pakistan states "Farmers are free to sell in the market or to the 
government procurement agency. Procurement is always made on the basis of predetermined 
target  and these are indicated in each year's notification. " 
Philippines  Procured 
Quantities  Corn 
Rice Notification   7 
 
17065, 22077,  
54020, 70048,  
87035, 87118, 
87151  CoA In response to ID 70048, the Philippines states "Procured quantities constituted eligible production  
in the calculation of market price support … for the period of 2005 -2010. " 
In response to ID 87118, the Philippines also states, "There is indeed predetermined annual 
limitations through the annual legislation of the budget for the rice/paddy buffer stock ing of the 
National Food Authority (NFA)…. This programme seeks to ensure that NFA has, in its stock 
inventory, at least 14 days of the national consumption in any given day, except in the lean season 
where the inventory should be sufficient for 30 days. " The Philippines adds "…for 2011 -14, the NFA 
average annual domestic procurement of rice was measly 1.2% of the annual total production of 
rice". 
Russian 
Federation  Unknown  Barley, Rye, Wheat  
 Notification   0 
CoA   
  JOB/AG/181  
 
- 11 - Member  Basis for 
eligible 
production 
figures used Product(s)  Information derived from notification or responses to  
Members ' questions in CoA AG IMS  
Saudi 
Arabia, 
Kingdom of  Total National 
Production 
Less a 
Specific 
Amount  Wheat  Notification  G/AG/N/SAU/8: The methodological note states eligible production for wheat excludes 5 % 
impurities and 5 % Zakat  (Zakat is determined according to Islamic Rules) from total production . 0 
CoA  
Switzerland  Total/Regional 
Production  Poultry  
Beef 
Soybeans / 
Sunflower seed  
Tobacco  Notification   2 
 
16166, 20081  CoA In ID 16166, Brazil asks Switzerland to provide information on the total amount of production for 
select commodities. Switzerland responds with "the quantities involved are shown in column 6 
'eligible production '", indicating eligible production is equal t o total production . 
Switzerland  Unknown  Swine, Cider apples, 
Cider pears, Fibre 
plants, Potatoes 
(seed, other)  
Pulses, Barley, 
Maize, Oats, Wheat, 
Milk, Oils, 
Rapeseed, Sugar  Notification   0 
CoA  
Tunisia  Procured 
Quantities  Barley  
Wheat  
(soft, durum)  
Milk 
Olive Oil  Notification   8 
 
22084, 26076, 
45051, 45064, 
62036, 81088, 
82049, 87041  CoA In response to ID 62036, Tunisia states "The quantities shown in the Supporting Table DS:5 
correspond to the quantities eligible for market price support. This eligibility applies to all of the 
production collected, which does not always correspond exactly to total production . The difference 
between the quantities shown and total production for the products under consideration stems 
from the fact that only the quantities that represent 'fair market value ' are collected by the 
intervention agencies and benefit from price support according to a pric e scale, while the rest is 
not marketed. A part of the production is not marketed either because it is consumed by the 
farming families themselves or because the quality of the product is not up to standard and it is 
used for animal feed. " 
In response to ID 45051, Tunisia states "…the quantities that were effectively collected by the 
[Grain Board] OC  are those that appear in Tunisia 's notification ". 
Ukraine  Pre-
Determined 
Target 
Quantities  Sugar  Notification  G/AG/N/UKR/26:  The footnote to STDS:5 states "during 2012 Government of Ukraine approved 
2 (two) amounts of the quota for sugar supply on the domestic market (quota 'A'): 1,860 thousand 
tonnes and 1,833 thousand tonnes. Eligible production is calculated from these two ap proved 
amounts and prorated per the days each quantity was in effect ". 0 
CoA  
United 
States  Total/Regional 
Production  Dairy    
(butter, non -fat 
dry milk powder, 
cheddar cheese ) 
Sugar  Notification  G/AG/N/USA/123: The footnote to ST:5 states that for sugar "Eligible production for market price 
support is the smaller of either actual production  or the Overall Allotment Quantity (OAQ), as 
provided for in the 2002 Farm Act (PL 107 -171) and continued und er the 2014 Farm Act (PL 110 -
246). The OAQ sets the amount of sugar that may be marketed during any year, thereby 
determining the maximum amount of production eligible for price support. Eligible production for 
2016 is actual sugar production ." 3 
 
16184, 6 1056, 
73061  
CoA In response to ID 73061 regarding dairy products, the United States states "Eligible production is 
the reported annual production quantity for each product  as provided by the US Department of 
Agriculture National Agricultural Statistics Service. " 
 JOB/AG/181  
 
- 12 - 
 
  2.2(b) Eligible Production:  Three Members have notified total production less a specified 
amount, one Member has clarified through CoA responses  
2.13.   Three Members, Canada,  Japan and the Kingdom of Saudi Arabia  have included a footnote in 
their notification that eligible production is equal to total production less a specific portion of tot al 
production that is not entitled or fit to receive the applied administered price for at least one product.  
One Member, Norway, clarified this in its response to a CoA question (Table 1 ). In each instance, 
the Member has identified some quantity of the total production that is not eligible to receive the 
administered price for various reasons.  For example, Canada does not include the sales of butter 
and skim milk powder for further processing, total exports, and skim milk powder for animal feed as 
eligible production, while the Kingdom of Saudi Arabia notifies eligible production for wheat as total 
production less 5% for impurities and 5% for Zakat.  
2.2(c) Eligible Production: Three Members have notified pre-determined targeted 
quantities, two Members  have clarified through CoA responses  
2.14.   Three Members, Israel, Pakistan and Ukraine have included a footnote in their notification 
that the government 's procurement policy is based on pre -determined targets or production quotas 
and that the commodities are s ubject to certain criteria, such as quality requirements for at least 
one product (Table 1) . Two Members, the European Union and Chinese Taipei clarified this in their 
responses to CoA questions.  In the case of the EU, for certain commodities subject to th e EU's public 
intervention, the quantity is set at zero and only increased if (1) market prices fall below a set 
reference threshold price, and (2) the EU decides to open a tender.  Israel, as another example, 
places production quotas on milk and applied ad ministered prices are only available for that set 
quota quantity.  
2.2(d) Eligible Production: Two Members have notified procured quantities, eight 
Members have clarified through CoA responses  
2.15.   Two Members, Japan and Indonesia (in 2000 only), have included a footnote in their 
notification that procured quantities were used for eligible production (Table 1) . Eight Members, 
Brazil;  China;  India;  Jordan;  Korea, Republic of; Lao PDR; Philippines and Tunisia clarified this in 
their responses to CoA quest ions. Each of these Members has noted that eligible production is the 
procured, purchased, subsidized, or collected quantity of the given commodity.  In response to 
questions about how these programs are implemented, Members provided several different 
expla nations.  For example, Brazil stated that its MPS program, Aquisições do Governo Federal, 
makes purchases at the applied administered price (AAP) according to available budgetary outlays.  
In the case of China, it noted that for its MPS programs, farmers in specified regions may sell all 
product that meets quality and other requirements at the AAP.  In contrast, India has explained that 
only the portion of the marketable surplus offered by farmers and meeting prescribed specifications 
is procured.  In the case of pulses, India stated that Minimum Support Price operations are carried 
out subject to prescribed specifications, budgetary allocations and applicable targets.  Procurement 
of wheat and barley by the government of Jordan is subject to certain specificatio ns to ensure better 
quality.  In the case of Indonesia stated that procurement of rice is limited to the amount stipulated 
in BULOG's annual budget.  
2.2(e) Eligible Production: Six Members have not notified any basis for data used for 
eligible production, nor clarified through CoA responses  
2.16.   Six Members have not included any information on what quantities are used in notifying 
eligible production either in a footnote in their notifications or in responses to questions in the CoA. 
In some cases, questions regarding eligible production have been  raised in the CoA, but the 
responses may not cover all products (e.g., Norway and Switzerland) or MPS measures where more 
than one exists (e.g., Israel).  
2.3  Changing the data used as a basis for eligible production figures  
2.17.   Five Members who notified MPS duri ng 2005 -2018 appear to have changed how they notify 
eligible production at some point since their WTO Membership date.  In each instance, the quantities 
notified appear to differ from the quantities either reported in the Member 's AGST documents and/or 
in previous notifications.  It should be noted that there are legitimate reasons for a Member to change JOB/AG/181  
 
- 13 - 
 
  the quantities used as the amount of eligible production based on how MPS measures are 
implemented.  Brazil notified eligible production as total production i n its AGST document, but notified 
for 1995 onwards procured quantities as eligible production.  Brazil has clarified in response to 
questions at the CoA that this change is due to changes in its MPS measures.  India notified eligible 
production as total prod uction in its AGST and in its first notification for 1995/96 then began notifying 
it as procured quantities in all subsequent notifications.  In response to CoA questions, India has only 
clarified its current notifications of procured quantities is used to be consistent with its notifications 
since 1996/97.  Other Members, including Japan,  Lao PDR and Pakistan have also made changes in 
their notification of eligible production over time – one of which appears to have changed their 
notification of eligible pro duction more than once.8, 9 
Table 2: Members using different data as basis for eligible production figures over time 
Member  EP data used for AGST / Initial notifications  EP data used for subsequent notification  
Brazil  Total production  
a) 1986-88 (G/AG/AGST/BRA)  Procured quantities  
a) 1995 - present (G/AG/N/BRA/6/Rev.1)  
In response to ID 66027, Brazil states "The nature of the Agricultural and Livestock Plan during the base -period 
(1986‑1988) was considerably different when compared to current programmes . During the 1980s, agriculture 
programmes did not have budget constraints. In addition, the only programme in place was the Minimum Price 
Support ( 'AGF'). Consequently, if the market price was below the minimum price, Government interven tion was 
unrestricted, benefiting all production. From the 1990s onwards, Brazil has faced severe budget constraints. 
Consequently, when the Government puts in place a programme, it is announced according to the budget limit, 
benefiting only part of the Br azilian production. " 
India Total production  
a) 1986/77 -88/89 (G/AG/AGST/IND)  
b) 1995/96 (G/AG/N/IND/1)  Procured quantities  
a) 1996/97 – present (G/AG/N/IND/2)  
In response to ID 63058, when asked why India switched the quantity for eligible production from total 
production to a lesser quantity, India states "Farmers approach government agencies for procurement only 
when the market price falls below the minimum su pport price. Therefore, actual quantities procured only 
actually receive support. Except for the year 1995 -1996, India has consistently filed its domestic support 
notifications taking actual quantities procured under PSS/MSP operations as eligible producti on. No specific 
policy change has been undertaken for the notifications filed for the year 1999 -2004. "  
Japan  Total production  
a) (sweet potato, potato, wheat, barley)  
1986/77 -88/89 (AGST/JPN)  
 
b) (wheat, barley)   
1995-1999 (G/AG/N/21)  Total production less specified amount  
a) (potato starch, sweet potato starch)  
1995 – present (G/AG/N/JPN/21)  
Procured quantities  
b) (wheat, barley)  
2000 – present (G/AG/N/JPN/98)  
In G/AG/AGST /JPN, the footnote to Supporting Table 6 states "production of potato and sweet potato ".  
In G/AG/N/JPN/21, the footnote to STDS:5 states "Production of potato and sweet potato for the manufacture 
of starch " and "Total volume of production " for wheat and b arley.  
In G/AG/N/JPN/98, the footnote to STDS:5 states "government purchase volume " for wheat and barley.  
Lao PDR Total production  
a) 2001-2003 (WT/ACC/SPEC/LAO/1/Rev.1)  Procured quantities  
a) 2016 (G/AG/N/LAO/2)  
b) In response to  ID 87032, Lao PDR states with regards to G/G/N/LAO/2  that "In Supporting 
Table  DS:5, Lao PDR determined the notified quantity of eligible production of 36,157 tonnes based 
on the actual subsidized amount of the rice production instead of the total amount of rice production 
to be eligible. This notified value differs in terms of defin ition from the values reported for 2001 -2003 
because the amount 1.5 million tonnes mentioned in Lao  PDR's AGST tables 
(WT/ACC/SPEC/LAO/1/Rev.1) was the total amount of rice production to be eligible, which was 
different from the amount to be subsidized. " 
 
8 In Indonesia 's first domestic support notification that included MPS (G/AG/N/IDN/26), Indonesia 's 
notification states that eligible production is based on procurement.  However, Indonesia 's response to AG IMS 
ID 29032 in reference to G/AG/N/IDN/26 states that "Eligible production is based on: Total production = area 
harvested x yield per hectare. " For purposes of this paper, the United States has assumed Indonesia 's 
notification as the basis for how Indonesia notified eligible production in 2000.  The United States also notes the 
eligible production quantity notified in 2000 is only a fraction of the quantity of total production reported by 
FAOSTAT.  
9 While not addressed in this analysis due to lack of clarity in Pakistan 's AGST document and no 
discussion in the CoA, it is noted that for select commodities reported in G/AG/AGST/PAK the quantity of 
eligible production appears to be equivalent or near equivalent to production quantities reported by FAOSTAT 
(e.g., seed cotton and soybeans), while other commodities appear to be only a percentage of production 
reported by FAOSTAT.  
 
 JOB/AG/181  
 
- 14 - 
 
  Member  EP data used for AGST / Initial notifications  EP data used for subsequent notification  
Pakistan  
(wheat)  Procured quantities  
a) 1997/98 – 1999/2000  
(G/AG/N/PAK/8)  
Total production  
a) 2000/01 -2006/07 (G/AG/N/PAK/10)  Pre-determined quantities  
a) 2007/08 - 2011/12  (G/AG/N/PAK/16)  
In G/AG/N/PAK/8, the footnote to STDS:5 states that eligible production is based on actual procurement  by 
public sector agencies.  
In G/AG/N/PAK/10, Pakistan notifies eligible production quantities for wheat that correspond with production 
statistics  report ed by FAOSTAT.   
In G/AG/N/PAK/16, the footnotes to STDS:5 states eligible production is based on "actual procurement by public 
sector agencies on pre-determined targets  from resource poor farmers defined in Article 6.2 ". 
2.4  Adjustments to Fixed External Reference Price (FERP)  
2.18.   Annex 3, paragraph 9 of the AoA states that:  
The fixed external reference price shall be based on the years 1986 to 1988 and shall generally 
be the average f.o.b. unit value for the basic agricultural product concerned in a net exporting 
country and the average c.i.f. unit value for the basic agricultural product concerned in a net 
import country in the base period.  The fixed reference price may be adjusted for quality 
differences as necessary.  
 
Accordingly, Members notify their MPS measures with corresponding FERP values in Table DS:1.   
 
2.19.   Approximately 15 % of the topics raised about MPS in the CoA concerned the FERP.  While 
questions regarding the FERP covered various topics, one of the main topics  of inquiry by Members 
was why a Member altered the FERP used in a notification from the FERP reported in an AGST 
document or in a prior notification.  Eight Members, who notified MPS during 2005 -2018, appear to 
have adjusted the FERP for one or more produc ts. In each instance, the values notified appear to 
differ from the values either reported in the Member 's AGST documents and/or previous 
notifications.  Four additional Members received questions regarding whether adjustments were 
made to their FERPs, but no adjustments were identified.  
2.20.   India, for example, reported in Indian Rupees (INR) in its AGST, but notifies the FERP (at 
1986-88 exchange rates) and the AAP (at current exchange rates) for all notified commodities in 
US dollars (USD).  In addition, India notified aggregated and averaged FERPs for groups of 
commodities, such as "pulses " and "coarse grains ". A second example is Japan, which adjusted the 
FERP for sugar cane from a refined basis to a raw basis, corresponding with a similar change in the 
applie d administered price that it said resulted from legislative amendments.  Tunisia has reported, 
for all notified commodities, FERPs that it adjusted for inflation and exchange rate movements.  
2.21.   Without further information, adjusted FERPs can leave it difficul t for Members to understand 
the significance of the difference between the reported FERP and the reported AAP.  Members face 
particular difficulty when basis for adjustments and conversion factors are not reported along with 
adjusted FERPs.   
Table 3: Member s adjusting FERP  
Member  FERP 
differs 
from AGST  Information derived from notification or responses to Members ' 
questions in CoA AG IMS  
China  Yes For the reporting period 2002 -2010 (G/AG/N/CHN /17), the footnote to 
STDS:5 states "The external reference price for rice is the weighted 
average of the prices of Japonica and Indica rice with the ration of 1:2. " 
This compared to two individual FERPs reported in WT/ACC/CHN/Rev.3 and 
for subsequent notifications (G/AG/N/CHN/42) since 2011.  
For the reporting period since 2011 (G/AG/N/CHN/42), China has notified 
a cotton FERP of RMB 19,800/tonne, while in WT/ACC/CHN/Rev.3, the 
cotton FERP is reported as RMB 4,435/ton.  1 
 
78067  JOB/AG/181  
 
- 15 - 
 
  Member  FERP 
differs 
from AGST  Information derived from notification or responses to Members ' 
questions in CoA AG IMS  
Iceland  Yes In response to ID 12091, Ice land states "The external reference price used 
in 1996 are based on document G/AG/AGST/ISL, adjusted in order to take 
account of the exchange rate evolution since the base period ." Iceland 
further explained in respon se to ID 86093 "…the measure of support is very 
dependent on currency fluctuation, as the external reference price used in 
the calculation of market price support, was expressed in Icelandic Krona 
in the AGST tables, rather than Special Drawing Rights, as had been the 
intention.  The Krona has over the years been highly volatile and the 
external reference price found in the AGST tables is presented in a much 
more valuable Koran than it is today ". 9 
 
12091, 16122, 
20043, 31038, 
45026, 45028, 
45058, 75079, 
86093 
India Yes In response to ID 16128, India states "The external reference price for 
various commodities for the base period 1986 -88 had been fixed in US 
dollar terms ."  
 
In the case of aggregated commodities, such as pulses, India responded to 
ID 87114, India stating it "has been consistently notifying product specific 
support for pulses at aggregate level since 1995 -96. Tur, urad, moong, 
gram, lentils are different variet ies of pulses and therefore, it is reasonable 
to calculate product specific support for aggregated pulses. The ERP is 
calculated based on simple average of external reference price of various 
pulses given in AGST and used to calculate product specific supp ort for 
pulses (including lentils )". 21 
 
16128, 32039, 
63020, 63021,  
63054, 65058 
65059, 67027, 
75017, 75093, 
77083, 78035, 
79015, 80044, 
85092, 86015, 
86095,87130, 
88112, 91175, 
91177  
Israel  No  7 
 
17048, 17049, 
26057, 60017, 
60018, 60020, 
80103  
Japan  Yes In response to ID 39034, Japan states "Before 1999, the applied 
administered price for sugar cane was presented on the basis of refined 
sugar, while the external reference price was presented on the basis of 
refined sugar by converting the c.i.f.  price of raw sugar . In October 2000, 
Japan introduced legislative amendments and the applied administered 
price based on refined sugar is no longer used.  Instead, Japan uses both 
the applied administered price and the external reference price based on 
raw sugar ." 2 
 
39034, 63063  
Jordan  Yes In G/AG/N/JOR/16, the footnote to the inflation adjusted FERP in STDS:5 
states "Note: Member shall give due consideration to the influence of 
excessive rates of inflation  on the ability of any Member to abide by its 
domestic support commitments (Article 18.4). The inflation rate was 68% 
based on average consumer price from 1997 -2009. " 9 
 
33019, 73022,  
75064, 83059, 
83088, 83128,  
86022, 86077, 
86097  
Korea, 
Republic of  No  1 
 
31045  
Pakistan  Yes In response to ID 14100 where a Member asked why Pakistan has not used 
the in its AGST tables (including for the FERP) , Pakistan states "Pakistan 
has experienced a high rate of inflation since early 1990s and at the same 
time the Pakistan rupee has undergone substantial depreciation.  Therefore, 
an AMS calculation in Pakistan rupee would have presented a distorted 
picture of the domestic support.  To exclude the possible effect of these 
factors, Pakistan chose to calculate the AMS in US dollars  – a cur rency 
which remained stable in value terms during the period under reference. " 6 
 
14100, 20057, 
77015, 77038, 
77094, 78046  
Switzerland  No  1 
 
12124  
Tunisia  Yes In G/AG/N/TUN/12, the footnote to STDS:5 states "Tunisia used the 
external reference price for the reference period and adjusted them to take 
account of inflation and the evolution of the exchange rates. " 
In response to ID 80092, Tunisia states "For the ca lculation of its AMS 
Tunisia uses the fixed external reference price, which is the average c.i.f. 
unit value in the base period (1986 ‑1988)…  The adjustment takes into 
account  excessive changes in the exchange rate and the rate of inflation . 
Tunisia conside rs the rates of inflation recorded between 1988 and 2014 to 
be excessive, which justifies an adjustment of the fixed external reference 
prices ." 25 
 
12128, 18077,  
22082, 26075,  
30064, 30065,  
30066, 41019,  
45050, 45064,  
50009, 62036,  
78030, 78031,  
79064, 80022,  
80047, 80092,  
81086, 81087,  
82022, 82048,  
87040, 91105,  
91190  JOB/AG/181  
 
- 16 - 
 
  Member  FERP 
differs 
from AGST  Information derived from notification or responses to Members ' 
questions in CoA AG IMS  
Ukraine  Yes In response to ID 63067, Ukraine "converted the fixed ERP for sugar in 
UAH using an exchange rate in the period 2004 -2006. In this period the 
average official exchange rate was 5 UAH per USD 1. But in the year of first 
Ukrainian notification on domestic support, in 2009, devaluation of the  
national currency against US dollar took place.  The exchange rate in 2008 
was already 7.8 UAH per USD 1. Thus, UAH depreciated 1.5 times.  In 
addition, there was high inflation in Ukraine after the base period.  The 
consumer price index (CPI) was 116.6 % in 2007, 122.3 % in 2008, and 
112.3 % in 2009.  Taking into account the above, Ukraine adjusted the fixed 
ERP for sugar by the rate of inflation, using a consumer price index in each 
year after the base period ."  10 
 
62037, 62038,  
63067, 68014,  
68036, 68065,  
69019, 69083,  
70038, 73024, 
84085  
United 
States10 No  1 
 
60055, 76048  
Note:  The following Members do not appear to notify an adjustment to the FERP  for any commodity nor 
were questions raised with regards to FERP adjustments:  Bangladesh;  Brazil;  Canada;  China;  
Chinese Taipei ; Costa Rica;  European Union;  Indonesia;  Lao PDR; Norway;  Philippines;  Russian 
Federation and  Saudi Arabia, Kingdom of . 
2.5  Product basis for notifying domestic support  
2.22.   Annex 3, paragraph 7 of the AoA states that:  
The AMS shall be calculated as close as practicable to the point of first sale of the basic 
agricultural product concerned.  
 
Accordingly, Members notify which commodities rec eive domestic support on a product specific 
basis.   
 
2.23.   Approximately 7 % of topics raised regarding MPS in the CoA related to product basis.  
Members ' questions focused primarily on ensuring notified support is being calculated at the same 
product level – whether that be the same level of processing or the aggregated level of product(s) 
– and that notified product is consistent with the product being su pported.11 While product basis is 
not an issue unique to MPS, the focus of this submission is on circumstances where Members have 
raised questions regarding the methodology Members used to calculate MPS – specifically the 
product basis used for AAP, FERP, a nd eligible production.   
2.24.   Based on notifications and responses to CoA questions, five Members appear to have notified 
data on a different product basis.  One type of product basis issue can arise when the FERP and AAP 
are notified on a different product basi s. Three Members - China, India and Israel - clarified in their 
responses to CoA questions that, in at least some notifications, the AAP for certain products had 
been notified on a different product basis than the FERP.  For example, from 2002 through 2010,  
China notified rice support with the AAP for unmilled rice and the FERP for milled rice; however, 
since that time it has notified both on milled basis.  In the case of Israel, since 2011 the AAP for milk 
has been adjusted annually to an equivalent quality level of milk produced in 1986 -88.  
2.25.   Three Members - India, Japan and Norway - clarified in their responses to CoA questions that 
product specific support (MPS or otherwise) had been calculated based on support provided to an 
aggregated group of commodities  while support was in fact being provided to specific commodities.  
In the case of India, India 's AGST documents and minimum support prices provided in web link in 
response to a CoA question indicate different AAPs for different pulses and coarse grains.  India has 
explained it has consistently notified support for these aggregate product groups.  
 
10 Due to the establishment of a new Dairy Product Price Support Program in 2008, the United States 
discontinued supporting all dairy and hence stopped reporting a dairy FERP. The new program established 
applied administered prices for non -fat dry milk, butt er, and cheddar cheese and 1986 -88 FERPs were 
calculated for each of these products. See response to AG IMS ID 76048.  
11 While questions did focus on whether the notified product is consistent with the product being 
supported, this submission does not addre ss this due to lack of sufficient information in available WTO 
documents.  For illustrative purposes see AG IMS ID 87035, in which a Member asks a notifying Member to 
explain why support is notified for milled rice when the announced applied administered pr ice is for paddy rice.  JOB/AG/181  
 
- 17 - 
 
  Table 4: Members notifying on different product basis 
Member  Notified 
AAP Notified 
FERP  Most relevant responses from CoA AG 
IMS 
China  Unmilled 
paddy  
(2002 -
2010)  
 
Milled rice 
(2010 – 
present)  Milled 
rice1 In G/AG/N/CHN/47, footnote (b) states "Administered price and Eligible production of 
indica and japonica rice (unmilled  paddy) were converted to those of milled rice, using 
the conversion rate 0f 70%. " 
In response to ID 78067, China states "the reason for China to use the price for 
unmilled  paddy rice, instead of the milled rice, is that, the actual object of the 
procurement concerned was unmilled paddy rice, since milled rice is not suitable for 
long-term storage ". 
In response to ID 65048, China states "…the applied administered prices  in Supporting 
Table DS:5 are on a paddy basis , not on a rough rice basis.  As to whether the fixed 
external reference price is on a milled basis, China thinks it is a very good question  
which allows China to study other Members ' methods of collecting data ". 3 
 
64052, 
65048,  
78067  
India Seed Cotton  
 
Milled Rice  Lint 
Cotton  
 
Milled 
Rice In response to ID 75017, India states "Though the administered price is for paddy , 
the external reference price is  only available for rice which is traded internationally 
and not for paddy ." 
In response to ID 75115, India states "The calculations in Supporting Table DS:5 
reflect the minimum support price for paddy converted into rice  by application of a 
coefficient of  1.5." 
In response to ID 85088, India states "India announces Minimum Support Price (MSP) 
for paddy and raw cotton while the external reference price is for rice and cotton lint.  
This conversion is done using standard co -efficient and methodology adopted b y 
Ministry of Agriculture, Government of India. " 
In response to ID 63052, India states, "Administered prices have been worked out by 
taking average MSPs  of two varieties (separate MSP is declared for two varieties - one 
is F-414/H -777/J -34 and another is H -4) of seed cotton  (kapas) for one tonne. " 7 
 
34033, 
63052, 
65059, 
67027, 
75017, 
75115, 
85088  
n/a 
(Aggregation)  Pulses vs Tur, Moong, Urad, Gram, and Lentil  
Coarse Cereals vs Bajra, Jawa, Maize, and Barley  
In response to ID 87130, India states "India has been consistently notifying product 
specific support for pulses at aggregate level  since 1995 -1996.  Pulses are a major 
source of protein and form an integral part of the Indian diet. Tur, urad, moong, gram, 
lentils are different varieties of pulses and therefore, it is reasonable to calculate 
product specific support for aggregated puls es." 
In response to ID 34033, India states "…coarse cereals taken into account are bajra, 
jowar, maize and barley. This has been duly clarified in Supporting Table DS:5 ". 
In G/AG/AGST/IND, India reported MPS measures for bajra, barley, maize, gram, 
urad, m oong, and tur individually.  9 
 
32039, 
34033, 
85021, 
86014, 
86015, 
86095, 
87114, 
87130, 
88111  
Israel  Milk (not 
adjusted)  
(prior to 
2011)  
Milk (quality 
adjusted)  
(2011 – 
present)  Milk In response to ID 80064, Israel states "The adjustment of the administered price for 
milk was calculated based on the changes in the quality of milk  produced in Israel, as 
manifested in the protein and fat contents. In consultation with the Milk Board, the  
quality improvement was calculated using the following coefficients, protein: 58.5%, 
fat: 31.5%, and water: 10.0%. " 3 
 
80064, 
85023, 
90066  
Japan  n/a 
(Aggregation)  In G/AG/N /JPN/124, Japan notified product -specific support for vegetables and fruits , 
which were notified as de minims in STDS:7 based on the VoP data for vegetables and 
fruits.  
In response to ID 48055, Japan states "These  payments are made to producers of 
specific fruit or vegetables . Eligible products and their corresponding gross valu es of 
production in 2003 are as follows: Oranges  (Unshu -mikan): 137.2 billion yen; 
Apples : 129.5; Tomatoes : 178.2; Cucumbers : 143.3; Welsh onions and leeks : 133.2; 
Spinach : 101.7; Radish : 100.9; Eggplants : 90.6; Cabbage : 84.5; Onions : 72.2; 
Carrots : 55.6; etc. " 2 
 
48055, 
52018  
Norway  n/a 
(Aggregation)  In G/AG/N/NOR/94 Norway notifies in STDS:5 a single target price (MPS measure) for 
wheat . 
In response to ID87152, Norway states "Norway would like to underline that wheat 
not fulfilling the criteria for human consumption is indeed included in the calculation 
of market price support for wheat, but is subject to a lower price than wheat for human 
consumption . The variation in market price support for wheat from one year  to the 
next is thus a result of variations in both the total amount of eligible production and 
the applied administrative price, based on the portion of wheat for human consumption 
and animal feed , respectively. " 2 
 
86098, 
87152  
1 See paragraph 7.319 and  Table 8 of WT/DS511/R.  
Note:  The following Members either (1) do not appear to provide sufficient information in their notification 
to assess the product basis, (2) did not get questioned on  product basis, and/or (3) the questions 
that were raised,  in parentheses, with regards to product basis clarified that suppo rt was provided 
on the same product basis:  Bangladesh; Brazil (ID 66028) ; Canada;  Costa Rica;  European Union;  
Iceland;  Indonesia;  Jordan (ID 83089) ; Korea, Republic of; Lao PDR; Pakistan;  Philippines 
(ID 87035) ; Russian Federation;  Saudi Arabia, Kingdom of ; Switzerland;  Chinese Taipei ; Tunisia;  
Ukraine and the  United States (ID 83112).  JOB/AG/181  
 
- 18 - 
 
  3  OTHER DOMESTIC SUPPO RT NOTIFICATION AREA S 
3.1.  As noted earlier in this paper, the United States has identified several areas within the domestic 
support pillar where CoA discuss ions are driven by inquiries about how measures are implemented 
and notified.  The previous section focused on several notification issues that are primarily relevant 
only to MPS, the following sections will focus on several other variables that are relevan t to domestic 
support notifications more broadly, but may be applicable to MPS as well.12  
3.1  Classification and non-notification of domestic support measures  
3.2.  Discussions on domestic support in the CoA are not limited only to measures that have been 
notified.  Members may be aware of measures that other Members implement that are not notified 
and question why they are not notified.  Further Members have also raised questions about how 
measures are classified in a notification.  While non -notification and classific ation issues are not 
unique to MPS, the focus of this submission is on circumstances where Members have raised 
questions on these topics with regards to MPS.   
3.3.  In the process of reviewing MPS -related questions and Members ' notifications, seven Members 
were identified where questions were raised with regards to the classification or non -notification of 
measures that appeared to the questioning Members to be MPS -related measures.  As an illustrative 
example, Members raised que stions and submitted a counter -notification regarding MPS measures 
for sugar in Pakistan and India.  Both Members responded to questions in the CoA stating that the 
central or state governments had not undertaken any procurement of sugar and that the prices  
identified as AAPs by some Members were only announced to protect small producers against 
distress sales.  In another example, Costa Rica terminated its official MPS for rice, and introduced 
reference prices.  While Members raised questions about reference prices keeping domestic prices in 
Costa Rica significantly above market prices, Costa Rica noted that these prices were non -
compulsory and served only as a basis for bargaining between producers and processors.  
Table 5: Classification and non-notification by Members questions  
Member  Most relevant responses from CoA Most relevant concerns raised from CoA 
Costa Rica  In response to ID 82039, Costa Rica states "The reason why no 
eligible production and no market price support is reported 
from March 2015 onwards is because, since that date, the 
administered producer price is no longer in effect, to the extent 
it has been replaced by a reference price that serves o nly as a 
basis for the bargaining process between rice producers and 
processors . The reference price is calculated based on rice 
producers ' average costs of production, and differs from the 
administered producer price in its non -compulsory nature . 
Indeed, effectively paid prices to rice producers are scattered 
around the reference price, but are not equal to it. " In ID 85016, a Member states "Costa Rica reported the 
abolishment of its market price support for rice… However, 
Costa Rica goes on to state that effective prices paid to 
producers are scattered around the reference price ." The 
Member goes on to say "…the annual average producer 
price was slightly lower in 2015 and 2016 compared to 
previous years, but remained nearly constant  in both 
years. However,  these prices remain more than twice as 
high as the border price . Further, it is reported that the 
reference price continues to function as a de facto 
reference price according to the OECD and others ." 
India In response to ID 88042, India states "Government of India 
announces changes in FRP  taking into account various cost 
parameters. In India, cane producers are mostly marginal 
farmers having very small land holdings. In order to protect 
them from resorting t o distress sales, Central Government fixes 
Fair and Remunerative Price  (FRP) of cane which is an 
indicative price to be paid by the sugar mills against purchase 
of their cane for production of sugar . Sugarcane is not included 
in the DS notifications since the government has not procured 
sugarcane from the farmers ." In a counter notification made by a Member 
(G/AG/W/189) regarding MPS for sugar, the Member 
states "The FRP is an administered price that effectively 
acts as a floor price for sugar mills to pay farmers for 
sugarcane . In addition, farmers are paid premiums for 
increased production efficiency  and are eligible for 
additional payments by sugar mills under specific State -
level support ." 
In response to ID 78041, India states "For every marketing 
season, Government of India announces the MSP for various 
commodities covered under the price support scheme. 
Government of India has taken a decision not to procure from 
States paying bonuses to f armers ." 
In response 8814, India states "Market price support for each 
product is calculated based on the administered price 
announced by the govt. including the bonus. In India, 
procurement of agricultural products is mainly done at 
minimum support price ." In a counter notification made by a Mem ber 
(G/AG/W/174) regarding MPS for rice and wheat, the 
Member states "Various states give an additional bonus 
over and above the announced wheat and rice MSP. " 
 
12 Due to the large quantities of data available for review, the United States has primarily focused the 
following discussion on the 24 Members that had notified MPS during the 2005 -2018 period.  However, where 
time and resources permi tted, additional information on other Members has also been included.  Nothing should 
be inferred from the inclusion or exclusion of information from any Member that did not notify MPS in the 
2005-2018 period.  JOB/AG/181  
 
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  Member  Most relevant responses from CoA Most relevant concerns raised from CoA 
Indonesia  In G/AG/N/IDN30 and G/AG/N/IDN/34 for 2001 -2011, 
Indonesia notified no MPS.  In G/AG/N /IDN/26 for 2000 and G/AG/N/IDN/52 -57 for 
2012-2017, Indonesia notified MPS for rice.  
In response to AG IMS ID 70026, Indonesia states "The 
stocks are procured at administered price taking into 
account the market price " regarding the period of 2008 to 
2011.  
In response to AG IMS ID 73052 regarding 2001 -2004, 
"For the last 3 years, the administered price has been set 
at IDR 6,600 and has not changed since then and it is 
always below the market price  of rice. This administered 
price is only applied to very l imited volumes, around 5% -
10% of total domestic consumption for rice . Concerning 
the notification on Supporting table DS:4 and DS:5, the 
capital is still preparing the notification. Indonesia expects 
to notify Supporting table DS:4 and DS:4 as soon as 
possible." 
Malaysia  In response to ID 75094 Malaysia states, "Malaysia's paddy rice 
farmers are among the poorest of the poor in the country. 
Therefore, this programme is an instrument to provide income 
support for resource -poor farmers to ensure they receive 
reasonable income . The eligibility of the payment is deter mined 
by a clearly defined criteria based on the status of the recipient 
as low -income and resource -poor paddy farmers. Malaysia 
would also like to highlight that it is a net -importer of rice. " 
In response to ID 10046, Malaysia states "The programme is a 
'poverty redressal scheme ' for paddy farmers. With an average 
farm size of 1.2 hectare, the annual income of paddy farmer 
per hectare, including price support and guaranteed minimum 
price, ranges from RM 518 to RM 1,584, depending on its 
location and yield.  The programme has no trade effect because 
Malaysia has to import 20 -30% of its requirement for rice. 
Malaysia considered therefore that the programme is in 
conformity with the general 'green box ' criteria set out in Annex 
2 of the AoA." In ID 91186, a Mem ber states "Malaysia appears to have 
two price -related policies for rice. The first is a Guaranteed 
Minimum Price established under the Control of Padi and 
Rice Act of 1994. The United States understands the 
minimum price in 2014 was RM 750 per tonne . Acco rding 
to BERNAS, the entity enforces the Guaranteed Minimum 
Price and is a buyer of last resort, which  'buys all paddy 
delivered, even if it is operating at full capacity '. In 
addition, producers receive a direct payment subsidy for 
each tonne of rice produced, which was RM 248.1 per 
tonne in 2014 ." 
Pakistan  In response to ID 88033, 88124, and 88125, Pakistan states, 
"The minimum price is an indicative fair price announced for 
sugar cane by the provincial governments only to protect 
livelihood concerns  of the poor and small farmers  in order to 
avoid the exploitation by the sugar cane millers. However, 
Government neither make any procurement nor intervene 
financially to offset sales below the minimum price . This 
measure does not constitute 'domestic supp ort' for the reasons 
outlined above. Hence it is not required to be notified. " In ID 88033, 88124 and 88125, three Members state 
"Australia notes that Pakistan at the provincial level 
provides market price support for sugar cane through 
minimum support pri ces (MPS) set by the provincial 
governments of Punjab (180 Rs. per 40 kg in 2017/18), 
Sindh (182 Rs. per 40 kg in 2017/18), and Khyber 
Pakhtunkhwa (KPK) (180 Rs. per 40 kg in 2017/18 ). The 
MPS for sugarcane are long running measures , which we 
note have inc reased 200% during the period from 
2007/08 to 2015 -16." 
Thailand  In response to ID 74050, Thailand states "the previous paddy 
pledging scheme was operated mainly with revolving funds in 
the procurement. The government expenditures accordingly 
will cover t he payment of different rates of interests, 
administrative cost, and other fixed operation costs in ". In ID 74050, a Member notes "that the administered price 
under the Paddy Pledging Scheme was B 14,400 per tonne  
for the main crop , but since the programme  was 
discontinued market prices in Thailand have fallen 
dramatically to approximately B 7,000 per tonne ". 
In ID 70017, a Member notes "…a new marketing year 
2012/2013 Off -Season Paddy Pledging Program. This new 
programme, though not yet finalized, is said to cost 
approximately US D 6 billion for a pledging target of about 
11 million metric tons of paddy rice ". 
In ID 68010, a Member notes "Since Thailand's policy 
returned in October 2011 to a paddy pledging scheme and 
set intervention prices well above market prices (by some 
estimates as much as 40 % higher ), Thailand's budgetary 
outlays for the rice support appear to have increased 
significa ntly." 
In ID 61054, a Member notes "For many years, Thailand 
has set a minimum intervention price for rice under which 
the government supports domestic prices ; acquires stocks 
if producers choose not to redeem their loans; and makes 
direct sales to compani es for use in the domestic market 
or for export. Thai Government interventions (such as the 
Paddy Pledging Scheme, the Direct Purchase Programme 
(of the PWO), and others) were intended to increase farm 
income by increasing the value of rice; that is, by 
increasing the effective price farmers received. " JOB/AG/181  
 
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  Member  Most relevant responses from CoA Most relevant concerns raised from CoA 
Turkey  In response to 8005290009, Turkey states "The Turkish Grain 
Board is conducting independent activities  taking into account 
principles of profitability and productivity . In cases when the 
Turkish Grain  Board announces a purchasing price, this is 
determined by its Board of Directors in line with its own policies 
and not by the Government . Therefore, the paddy purchasing 
prices of the Turkish Grain Board do not constitute 
administrative prices but market based prices  and Turkey does 
not intend to include the purchasing prices of the Turkish Grain 
Board in the calculation of its domestic supports. "  
For notified years since 2002 (starting with G/G/N/TUR/15), 
Turkey no longer notifies MPS and states in respo nse to 
ID 85068 "a more market -oriented policy was implemented, in 
which the production decisions and price setting has been 
administered by market itself without public intervention ". In ID 85031, a Member notes "state-owned Turkish Grain 
Board (TMO) cont inues to implement and publish applied 
administered prices for certain commodities. Further, it is 
the United States understanding that TMO receives 
government funds for various activities it carries out ". 
3.2  Notifying negative support in the calculation of AMS  
3.4.  Annex 3 of the AoA provides that a Member may deduct from AMS "specific agricultural levies 
or fees paid by producers ". Notifying negative support values implies that there is a negative benefit 
to or tax on producers, and this tax on pro ducers would offset any positive budgetary outlays.  There 
have, however, been a number of instances where Members have notified negative market price 
support when there were no such levies or fees noted in DS ST:5.  For example, China notified 
negative MPS for rice and wheat, and proposed that a technical discussion on the issue be held at 
the regular meeting so it can understand how to notify negative MPS in future notifications.  India 
notifies negative MPS for several commodities. Tunisia stat ed it would provide a corrigendum to 
amend the value in column 7 of its DS ST:5 to zero but to date has not yet notified a corrigendum.   
3.5.  Questions regarding the notification of negative support have been raised numerous times in 
the CoA. 
Table 6: Members  notifying negative domestic support values, 2005 -2018  
Member  Notified information or most relevant responses from CoA AG IMS  
Brazil  In G/AG/N/BRA/23, Brazil notified negative MPS in STDS:5, which was notified as equivalent 
to zero in STDS:7 and did not offset other product specific support notified. ( The negative 
MPS notified is a result of the AAP being below the FERP and as a result of associated 
fees/levies. ) 3 
 
49038, 44020,  
70062  
Canada  In G/AG/N/CAN/35, Canada notified negative non -product specifi c support for several 
measures that appear to offset a portion of the positive non -product specific support.  
In response to ID 23084, Canada states "Positive and negative amounts arising from 
different policy measures applying to a product (or as non -produ ct-specific support) may 
partially offset one another in calculating the product -specific AMS (or the non -product -
specific AMS). " 1 
 
23084  
China  In G/AG/N/CHN /28, China notified negative MPS in STDS:5, which was notified as negative 
support in STDS:7 and offset other product specific support notified. (The negative MPS 
notified is a result of the AAP being below the FERP.)   
In response to ID 80041, China states  it "does not have the intention to circumvent the 
obligation by including negative support in the summation of product specific AMS. Since 
2012, the minimum procurement prices for rice and wheat have been higher than the 
administered price, which means th at the problem of negative support will not happen again. 
China notes that questions regarding negative support have been raised in the meeting for 
several times, although with different reasons. Up till now, it seems that no consensus has 
been reached on this issue ". 7 
 
64049, 65048, 
66052, 77026, 
77079, 79014, 
80041  
European 
Union  In G/AG/N/EU/34, the EU notified negative MPS in STDS:5, which was notified as negative 
support in STDS:7 and offset other product specific support. ( The negative MPS notified is a 
result of the APP being below the FERP.)  
In response to ID 84098, the EU states "The EU has never taken the view in its Domestic 
Support notifications that negative Market Price Support is a negative benefit, tax or cost for 
farmers, as it has consistently been excluded from the overall AMS calculation. This would 
in the EU's view be an inappropriate conclusion to draw from the presentation of a negative 
amount related to Market Price Support in Table DS:4. " 6 
 
15064, 27038  
40016, 66066  
83083, 84098  
India In G/AG/N/IND/7, India notified negative MPS in STDS:5, which was notified as negative 
support STDS:7 and in STDS:4.  India provided no other product specific support. ( The 
negative MPS notified is a result of the AAP being be low the FERP. ) 
In response to ID 66070, India states "The negative figures reflect the result of the 
methodology for calculating product ‑specific or non ‑product -specific AMS since 
G/AG/AGST /IND. India is also aware that some Members offset positive AMS amounts with 
negative AMS in their calculations of product ‑specific as well as non ‑product -specific AMS. " 3 
 
63050, 65062  
66070  JOB/AG/181  
 
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  Member  Notified information or most relevant responses from CoA AG IMS  
Norway  In G/AG/N/NOR/47, Norway notified negative non-product specific support (NPS) in STDS:9.  
This negative value for total NPS was notified in STDS:4 and subtracted from the total 
Product Specific AMS, reducing Norway 's notified Total AMS value.  
In response to ID 51011, Norway states "The negative non -product -specific AMS constitutes 
such an agricultural levy, namely taxes on pesticides, which we are unable to divide precisely 
between the relevant AMS supports. As there is very little other support currently qualifying 
as non -product -specific AMS, the n et result is negative. Our understanding of Annex 3 is 
that it does not preclude us from having a negative non -product -specific AMS.  As for the de 
minimis  provisions [...] Our understanding of the Agreement is that the language 'shall not 
be required ' does not imply a prohibition against counting a given AMS figure against the 
Current Total AMS, but merely states that a Member is not required to include it in the 
calculation. Furthermore, nothing in the above -mentioned language precludes Members from 
using the de minimis  provisions for one AMS support and not for another. " 4 
 
19121, 23101  
27047, 51011  
Pakistan  In G/AG/N/PAK/3 and G/AG/N/PAK/5, Pakistan notified negative MPS in STDS:5, which was 
notified as negative STDS:7 and in STDS:4.  Pakistan provided no  other product specific 
support.  (The negative MPS notified is a result of the AAP being below the FERP. ) 
In response to ID 11094 referencing G/AG/N/PAK/3, Pakistan agreed that negative values 
should be zeroed out the calculation of Total AMS.  In reference to G/AG/N/PAK/5, Pakistan 
states in response to ID 14101, that it "believes that the negative value of AMS is an implicit 
tax on producers and hence would need to be subtracted from the current total AMS ". 6 
 
11094, 14101  
14104, 15092  
20058, 2 8042 
Switzerland  In G/AG/N/CHE/67, Switzerland notified negative MPS in STDS:5, which was notified as 
negative in STDS:7 and offset other product specific support. ( The negative MPS notified is 
a result of the AAP being below the FERP.)  0 
Tunisia  In G/AG/N/TUN/7 and G/AG/N/TUN/30, Tunisia notified negative MPS in STDS:5, which was 
notified as negative in STDS:4.  Tunisia provided no other product specific support. ( The 
negative MPS notified is a result of the AAP being below the FERP.)  
In response to I D 11103, Tunisia states "The negative AMS values for sugar and olive oil 
reflect duties paid by producers through producers' collection organizations and should be 
considered as zero. As regards olive oil, the duties are designed to fulfil phytosanitary 
obligations. Duties paid by sugar beet  producers are allocated to processing factories for 
harvesting and transporting production. Tunisia will provide a corrigendum to the notification 
in order to put these amended figures in column 7 of Supporting Table DS :5." No 
corrigendum has been submitted.   
In response to ID 41018, Tunisia states "negative support is reported in column 2 of ST/DS:4 
to carry over the product support in ST/DS:5. This support was equated to zero in column 4 
of ST/DS:4.  Accordingly, the ca lculations were made by equating the negative support to 
zero; the AMS calculation does not need to be amended ". 2 
 
11103, 41018  
Note:  The following Members did not notify negative support nor were questions raised with regards to 
negative support: Bangladesh;  Costa Rica;  Iceland;  Indonesia;  Israel;  Japan;  Jordan;  Korea,  
Republic of;  Lao PDR;  Philippines;  Russian Federation;  Saudi Arabia,  Kingdom of; Chinese Taipei ; 
Ukraine and the  United States.  
3.3  Currency and inflation adjustments  
3.6.  The currency in which measures have been reported and adjustments made by Members 
seeking to account for excessive rates of inflation – two often interrelated t opics – have been a 
regular part of CoA discussions.  Issues of currency and inflation were each raised in approximately 
10% of CoA questions on MPS during the 2005 -2018 timeframe.  This section 's review of these topics 
covers 27 Members – the 24 Members pro viding MPS during 2005 -2018, as well as Argentina, 
Hungary, and Turkey which were identified in RD/AG/18 and RD/AG/18/Add.1/Rev.1, with regards 
to the topic of excessive inflation.  
3.3(a) Currency  
3.7.  Domestic support is notified in monetary values, often in a  Members ' own currency, but 
sometimes in a different currency.13 Notified currency is not a topic specific to MPS, but rather 
applicable more broadly to Members ' commitments.  In the case of domestic support, notified 
monetary values are used as a basis for comparison against Members ' commitments, which are 
established in either their Uruguay Round Goods Schedule or Accession Goods Schedule and are 
based on the constituent data and methodology found in the AGST Supporting Tables.  Of the 
27 Members whose notif ications were reviewed for this section, 17 notified the monetary value of 
domestic support in their domestic currency, while eight notified in a different currency. Two notified 
 
13 Note: One Member 's Bound Total AMS and notifi ed Current Total AMS are scheduled and notified in 
Special Drawing Rights.  JOB/AG/181  
 
- 22 - 
 
  in both the domestic currency and a different currency14 and a third reported in its AGST in two 
currencies. 15  
3.8.  Three Members – India, Pakistan and Turkey – notify domestic support in a currency different 
than what is found in their Goods Schedule and AGST Supporting Tables ( see Table 7).  In all three 
instances, the Members have switched from their domestic currency to a different currency.   
3.9.  In one instance, the Member stated the use of US dollars was to provide a consistent approach 
in notifying, another Member noted the use of US dollars was to address inflation, and the third 
Member noted high inflation rates resulted in misleading results and t herefore notified in US dollars 
instead.16  
Table 7: Members using different currencies  
Member  Scheduled 
commitment/ 
AGST currency  Notifying 
currency  Basis in notification or responses to Members ' 
questions in CoA Questions to 
Member  
India INR USD Notification   22 
 
16128, 34031,  
63019, 63020  
63022, 63054, 
65058, 65060,   
75017, 75045, 
75093, 76018, 
77083, 76018, 
77114, 78035, 
78041, 85107, 
87024, 87078, 
87155, 88112  CoA India's AGST document provides India 's 
domestic support commitments in Indian 
rupees.  This issue has been raised in the 
CoA, including in IDs 76018, 75017, 75045, 
75093, 75117, but India has not explained 
the basis for making this change in currency 
beyond stating it has remained consistent 
in its notifications .  
Pakistan  PKR USD Notification   8 
 
14100, 20057  
28041, 77015  
77038, 77094  
78046, 15090  CoA In response to ID 14100, 20057, 77094, 
77015 and 78046, Pakistan cites a high rate 
of inflation and depreciation of their local 
currency  and states that it "believes that 
any calculation of the AMS using the 
national currency would have presented a 
distorted picture. The US dollar, a currency 
which remained stable in value terms, was 
chosen ". 
Turkey  TL USD Notification   3 
 
15093, 23103, 
27052  CoA In response to ID 23103, Turkey states 
"Inflation rates fluctuated between 88 and 
53% between 1995 and 1999. However, 
the rate of inflation has dropped during the 
course of the year 2000. Turkey will 
therefore submit the calculations in Turkish 
Lira in next year's domestic support 
notification " and in response to ID 15093 
"Turkey confirmed that i nflation was still a 
problem, and that this was the reason for 
using the US D. The calculations were made 
by the Statistics Institute. The exchange 
rate used was calculated by the Central 
Bank. In this specific case, the exchange 
rate was the one calculated for October 
1997. " 
Note:  The following Members scheduled commitments, report in AGST documents, and notify in the same 
currency and no questions were raised (except as noted): Argentina;  Bangladesh;  Brazil (AG IMS ID 
44014) ; Canada;  China;  Costa Rica;  European Union;  Indonesia;  Israel; Japan;  Jordan;  Korea,  
Republic of;  Lao PDR;  Norway;  Philippines;  Russian Federation;  Saudi Arabia, Kingdom of; 
Switzerland;  Chinese Taipei ; Tunisia;  Ukraine and the  United States.  
 
14 Iceland notifies and calculates support in the Supporting Tables in Icelandic Krona, but notifies Total 
AMS in Special Drawing rights in Table DS:1 – similar to its AGST document in Krona and Scheduled 
Commitments in Special Drawing Rights.  Lao PDR notifies Supporting Tables DS:1, DS:2, and DS:9 in both 
US dollars and Laotian Kip, while Supporting Table DS:4, DS:5, and DS:7 are notified only in US dollars.  The 
Lao PDR's AGST docume nt for domestic support is listed as "nil" with no currency.  
15 Russian Federation reported in Russian rubles and US dollars in its AGST  document, but its Scheduled 
Commitments and notifications are only in US dollars.  
16 See AG IMS ID 20057, 27052, and 87155.  JOB/AG/181  
 
- 23 - 
 
  3.3(b) Inflation  
3.10.   Article 18.4 of the WTO AoA states, "In the review process Members shall give due 
consideration to the influence of excessive rates of inflation on the ability of any Member to abide 
by its domestic support commitments. "  
3.11.   There have been instances of Members stating, in notifications or in responses to CoA 
questions, that adjustments have been made to their reported figures to reflect inflation or excessive 
rates of inflation.  In some instances, Members have notified domestic support levels both with and 
without the adjustments made.  In other instances, Mem bers have notified only the adjusted 
domestic support levels.  Any unilateral adjustments may lack sufficient transparency to understand 
how adjustments were made.  In addition, if unadjusted figures are not provided, it can be difficult 
for Members to asses s notified domestic support levels against Members ' commitments.   
3.12.   As noted above in the "Adjustments to the Fixed External Reference Price " section, a number 
of Members notify a FERP differently as compared to the FERP in their AGST documents.  The chart 
below identifies Members who have made inflation adjustments in their reported figures.  Four of 
seven on the chart below provided both inflation -adjusted and non -inflation adjusted figures.  
Iceland, Jordan, Tunisia and Ukraine all make this adjustment to the ir FERP to address the issue of 
excessive inflation (see Table 8) . Pakistan and Turkey both notify in US dollars rather than the 
currency under which commitments were made in order to address inflation, while Hungary adjusted 
its Bound Total AMS commitment  level for the same reason.  Only, Hungary, Iceland, Jordan and 
Ukraine notify domestic support levels with and without adjustments for inflation.  
3.13.   The use of adjustments for inflation resulted in lower levels of notified trade -distorting support 
by Members.  In some instances, the adjustment resulted in the Member reporting trade -distorting 
domestic support within commitment levels when it otherwise would have reported support in excess 
of those levels.  In other instances, the inflation adjustment created add itional space between the 
level of notified support and the Member 's commitment level.  
Table 8: Members notifying adjustments for inflation and related Q&A  
Member  Notifies inflation -
adjusted data? Most relevant responses from CoA Questions to 
Member  
Hungary  Bound Total AMS 
commitment level 
adjusted for effects of 
excessive rates of 
inflation.  
Notifies DS with and 
without inflation 
adjustments.  In response to ID 31034, Hungary states "Article 18.4 is silent on 
the way an inflationary adjustment  should be made. Hungary does 
not see any major difference in legal or methodological terms in 
whether AMS commitment levels or current AMS levels are 
adjusted . Perhaps Hungary's approach is more practical and logical 
from the point of view of planning domestic support expenditures. 
But Hungary would have no problems in using the second approach 
in future notifications. As to the three notifications on the agenda, 
the Current Total AMS if adjusted for inflation is HUF 3.5 billion, 3.1 
billion an d 22.9 billion for 1996, 1997 and 1998, respectively. " 2 
 
31034, 40018  
Iceland  FERP is adjusted from 
base year currency to 
current year currency.  
Notifies DS with and 
without inflation 
adjustments.  In response to ID 75079, Iceland states "… The mistake in the AGST 
tables is that the world market price was converted from SDR into 
ISK at the base period exchange rate. Without adjustment, the 
market price support is calculated using the external referen ce price 
found in the AGST tables, which is presented in a more valuable 
Krona than it is today. The adjustment consists in converting the 
base year Krona into a Krona today (or a Krona in a given year), in 
order to use comparable amounts. The simple conve rsion of the 
current total AMS in Krona into SDR does not address this imbalance 
in the market price support calculations . Therefore, given the 
currency development since the base year period, leaving the 
reference price unadjusted distorts the market pric e calculations 
and renders them more or less meaningless . It is this imbalance in 
the calculations that have been sought to redress by issuing a dual 
notification, presenting both the adjusted and unadjusted scenarios. 
Iceland understands that there may be  different opinions with 
respect to how this particular problem should be dealt with. For this 
reason, Iceland submits a dual DS notification ." 11 
 
12091, 16122  
20044, 31038  
45026, 45027  
45028, 45058  
46020, 75079  
86093  
Jordan  FERP is adjusted from 
base year currency to 
current year currency.  
Notifies DS with and 
without inflation 
adjustments.  In a footnote in its notifications, Jordan cites "Article  18.4: Member 
shall give due consideration to the influence of excessive rates of 
inflation on the ability of any Member to abide by its domestic 
support commitments, the inflation rate in 2013, was 77% based 
on average consumer price from 1997 -2013 (Jordan Central Bank, 
Statistics Department). " 
In response to ID 86022, Jordan states "the external fixed reference 
price depends on the interval period (94 -96) therefore a huge gap 
existed between actual world market price and external fixed price. 
The use of inflation rate, average consumer price shall give a 
Member the ability to abide by it s domestic support commitment ". 11 
 
72027, 72028  
73022, 75064  
83059, 83088  
83128, 85026  
86022, 86077  
86097  JOB/AG/181  
 
- 24 - 
 
  Member  Notifies inflation -
adjusted data? Most relevant responses from CoA Questions to 
Member  
Pakistan  Notifies DS in US dollars 
rather than local currency 
to address inflation and 
depreciation of local 
currency.  
Notifies DS with inflation 
adjustments.  In response to ID 14100, 20057, 77094, 77015 and 78046, Pakistan 
cites a high rate of inflation and depreciation of their l ocal currency  
and states that it "believes that any calculation of the AMS using 
the national currency would have presented a distorted picture. The 
US dollar, a currency which remained stable in value terms, was 
chosen ". 8 
 
14100, 20057  
28041, 77015  
77038, 77094  
78046, 15090  
Tunisia  FERP adjusted to take 
account of inflation and 
exchange rate 
movements.  
Notifies DS with inflation 
adjustments  In response to ID 80092, Tunisia states "… In Tunisia's view the 
Article [18.4] alludes to a level of inflatio n, among other things, 
which if not taken into account in the calculation of the AMS could 
cause a Member to exceed its domestic support commitment.  
Tunisia considers that its level of agricultural domestic support is 
consistent with the provisions of the AoA and its WTO 
commitments….  
The adjustment takes into account excessive changes in the 
exchange rate and the rate of inflation. Tunisia considers the rates 
of inflation recorded between 1988 and 2014 to be excessive, which 
justifies an adjustment of the fixed external reference prices . 
Indeed, Article 18.4 of the AoA stipulates that  'in the review process 
Members shall give due consideration to the influence of excessive 
rates of inflation on the ability of any Member to abide by its 
domestic support commitments'.  
Tunisia's understanding is that the term  'Members', as employed in 
Article 18.4, also includes Tunisia. " 24 
 
18077, 22082, 
22083, 26075, 
30064, 30065,  
41019, 43022, 
45050, 45064, 
50009, 62036,  
78030, 78031,  
79064, 80022  
80047,  80072, 
80092, 81087, 
82048, 87040,  
91105, 91190  
Turkey  Notifies DS in US dollars 
rather than local currency 
to address inflation and 
depreciation of local 
currency.  
Notifies DS with inflation 
adjustments.  In response to ID 23103, Turkey states "Inflation rates fluctuated 
between 88 and 53 % between 1995 and 1999. However, the rate 
of inflation has dropped during the course of the year 2000. Turkey 
will therefore submit the calculations in Turkish Lira in next year's 
domestic support notification " and in response to ID 15093 "Turkey 
confirmed that i nflation was still a problem, and that this was the 
reason for using the US D. The calculations were made by the 
Statistics Institute. The exchange rate used was calculated by the 
Central Bank. In this specific case, the exchange rate was the one 
calculated for October  1997. " 15093, 23103, 
27052  
Ukraine  FERP adjusted to account 
for inflation.  
Notifies DS with and 
without inflation 
adjustments  In response to ID 840 32, Ukraine states "Ukraine attentively 
reviewed WTO Members ' points regarding the use of inflation 
adjustment. Our interest is fair and uniformly applied rules across 
WTO Members ' domestic support. Therefore, in response to earlier 
questions Ukraine elect ed to notify both adjusted and unadjusted 
AMS values in G/AG/N/UKR/26. Ukraine 's initial reaction to re -
submitting previous years ' domestic support with both adjusted and 
unadjusted values tends to be favourable. A further review will be 
considered in capi tal. We consider that the application of the fixed 
external reference price without adjustment for inflation will not 
reflect the actual level of product support , because the 
administrative sugar price (applied administered price) increases 
annually due to  an excessive inflation and a corresponding increase 
of the cost of inputs for sugar production . So we expect that WTO 
Members can give due consideration to influence of such rate of 
inflation on Ukraine's ability to abide its domestic support 
commitments.  Together with that, Ukraine has been actively 
reviewing its domestic support regarding the sugar production. " 11 
 
62037, 62038  
68014, 68036, 
68065, 68073, 
69019, 69083, 
70038, 73024, 
84085  
3.4  VoP data 
3.14.   Data on the VoP is crucial to ascertaining whether each Member is staying within its domestic 
support commitments.  However, not all Members provide this information with their notifications.  
3.15.   Of the 24 Members that notified MPS during 2005 -2018, 21 Members notified VoP data. Three 
of the 21 did so via a method other than a column in Supporting Table DS:4 ( see Table 9).17 Two 
Members – Lao PDR and Pakistan – provided data in a footnote or Annex to STDS:4, and one – 
Kingdom of Saudi  Arabia – provided it in STDS:5 footnotes.  Two Members, Iceland and India notified 
support in STDS:4, but did not notify VoP data.  India, however, has provided VoP data upon request 
in its response to CoA questions.  Data was also requested of several other Members in response to 
CoA questions.  In addition to requests for VoP values, Members on several occasions sought through 
CoA questions to clarify information related to VoP, such as how VoP values were calculated.  
 
17 Several Members provided only PS or NPS VoP data due to not providing any PS or NPS support.  
Several other Members provided VoP da ta only in circumstances where de minims was claimed while excluding 
VoP data where support exceeded the de minimis  value.  JOB/AG/181  
 
- 25 - 
 
  3.16.   VoP is relevant not just to MPS but to all domestic support that is non -exempt from a Members ' 
Final Bound Total AMS or de minimis  commitments.  While 21 of 24 Members notifying MPS also 
notified VoP data, a submission by Canada to the 2019 CoA Special Session found that only 34 of 
the 99 Members studied (including the EU as a single Membe r) notified total agricultural VoP 
(i.e., non-product specific VoP) data.18  
3.17.   Notification of VoP values provides increased transparency, including the relative level of 
support for a given commodity or for the agricultural sector more broadly.  VoP informati on is key to 
allowing Members to assess whether a Member is within its permitted levels of non -exempt support.  
VoP data is useful both on a product specific basis and non -product specific basis.   
Table 9: Notification of VoP  
Member  Notified 
product -
specific VoP  Notified non-
product specific 
VoP Questions to Members:  
requesting VoP data Questions to 
Members: requesting 
VoP information  
Bangladesh  STDS:4  STDS:4    
Brazil  STDS:4  STDS:4  1 
9027 (no data provided)  1 
59027  
Canada  STDS:4  STDS:4   1 
47020  
China  STDS:4  STDS:4   1 
46014  
Costa Rica  n/a n/a   
European Union  STDS:4  STDS:4  1 
15065   
Iceland  No n/a   
India No No 5 
87024 (asked for future), 88130 
(no data provided), 88068,  
88014, 88042 (no data provided)  1 
75017  
Indonesia  STDS:4  n/a 1 
29032   
Israel  STDS:4  STDS:4    
Japan  STDS:4  STDS:4  2 
48055, 52018 (no data provided)  1 
52021  
Jordan  STDS:4  STDS:4   1 
83089  
Korea, Republic 
of STDS:4  STDS:4    
Lao PDR  STDS:4 footnote  STDS:4 footnote    
Norway  STDS:4  STDS:4    
Pakistan  STDS:5 footnote  STDS:9 footnote    
Philippines  STDS:4  n/a   
Russia n 
Federation  STDS:4  STDS:4    
Saudi Arabia, 
Kingdom of  Annex to 
STDS:4  Annex to STDS:4    
Switzerland  STDS:4  STDS:4    
Chinese Taipei  STDS:4  STDS:4    
Tunisia  STDS:4  STDS:4    
Ukraine  STDS:4  STDS:4    
United States  STDS:4  STDS:4   1 
60051  
Note:  Determination of notification of VoP data based on most recent DS:1 notification on 13 August 2019.  
"n/a" indicates no support was provided and hence VoP data is not applicable.  
 
 
 
18 The Canada submission was made without a document number and does not distinguish between 
where VoP data was not notified but was n ecessary to determine de minis levels and where no support was 
provided.   
  JOB/AG/181  
 
- 26 - APPENDIX  
Table A1: WTO Members with notified market price support by commodity group, 2005 -2018  
 Animal 
products  Beverages 
& tobacco  Cereals & preparations  Coffee 
& tea Cotton  Dairy  Fruits, vegetables & 
plants  Oilseeds, fats & 
oils Sugars & 
confectionary  Other 
agricultural 
products  
Bangladesh    Wheat, rice         
Brazil    Maize, wheat, rice  Coffee  Cotton   Edible beans    Sisal 
Canada       Butter, 
SMP     
China    Maize, wheat, rice  Cotton    Soybeans, rapeseed  Sugar   
Costa Rica    Rice        
European Union  Beef  Maize, Durum wheat, 
Common wheat, rice, barley, 
sorghum, oats, triticale    Butter, 
SMP  Olive oil  Sugar   
Iceland       Milk     
India   Maize, wheat, rice, coarse 
cereals (maize, barley, bajra, 
jowar)   Cotton   Pulses (gram, arhar, urad, 
moong and lentils)  Soybeans, mustard, 
sunflower, groundnut    
Indonesia    Rice        
Israel    Eggs   Milk     
Japan  Beef and veal, 
meat of swine   Wheat, barley, starch     Vegetables   Sugar  Silkworm 
cocoons  
Jordan    Wheat, barley         
Korea, Republic 
of   Maize, Naked barley, 
unhulled barley      Soybeans    
Lao PDR    Rice        
Norway  Beef, poultry, 
pork, sheep   Eggs, wheat, barley, oats, 
rye   Milk, 
goat milk  Oilseeds    
Pakistan    Wheat         
Philippines    Maize, rice         
Russian 
Federation    Wheat, barley, rye         
Saudi Arabia, 
Kingdom of    Wheat         
Switzerland  Beef, poultry, 
swine  Tobacco  Maize, wheat, rice, barley, 
oats   Milk Cider apples, cider pears, 
fibre plants, potatoes, pulses  Soybeans / 
sunflower seed, 
rapeseed  Sugar   
Chinese Taipei   Tobacco 
leaves  Rice      Sugar   
Tunisia    Wheat, barley    Milk  Olive oil    
Ukraine          Sugar   
United States       Diary    Sugar   
Note:  Individual commodities listed may be aggregated based on product totals notified by the Member . 
Source:  Member Notifications and Product Groupings as provided in the 2017 WTO World Tariff Profiles (page 32).  
__________