RESTRICTEDWORLD TRADE
ORGANIZATIONG/IT/SPEC/Q2/12
1 May 2002
(02-2487)
Committee of Participants on the Expansion
of Trade in Information Technology ProductsOriginal:  English
SUBMISSION FOR THE NON-TARIFF MEASURES WORK PROGRAM
Communication from the United States
The following communication, dated 25 April 2002 has been received from the Permanent
Delegation of the United States.
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Redundant Testing and Certification Requirements
Worldwide, there has been an exponential increase in redundant testing and certification
requirements for IT products.  Such requirements delay entry of these products into the marketplace
and unnecessarily add cost.  They delay customer (government, industry and individuals) access to the
latest technology, discourage small and medium -sized enterprises (SME’s) from entering the
international marketplace, unnecessarily encumber the marketing and sale of IT products byestablished producers, and result in additional costs with no added value to either the purchaser, the
public or the government that imposes them.
International standards setting bodies have  succeeded in developing internationally
recognized safety and electromagnetic interference standards for many IT products.   Nearly all
governments that regulate in these areas have adopted these international standards and this global
harmonization has greatly facilitated global trade.  However, the proliferation of country specific
regulations in the areas of testing and certification is now seriously diminishing the benefits of these
global standards.  Many of these requirements cause repetition of tests that have already been
performed with no additional benefit to customers or to society.
While standards and conformance measures are not trade barriers per se, they can and often
are used in regulatory measures with the effect of delaying or impeding market access for IT products
and can be classified as NTMs.  Considering that the life cycle of some IT products is extremely
short, anywhere from six to sixteen months, a three-to-eight week delay caused by redundant testing
procedures or duplicative paperwork is significant.  The countries with the most burdensome barriers
to market entry have the most to gain from streamlining their regulations.
Burdensome regulatory procedures and the lack of portability of conformity assessment data
need to be addressed and eliminated.  Regulatory procedures, such as duplicate type approval regimes,
often  require administrative processes that result in excessive time and cost, slowing a product’s time
to market without any value-added to the safety or quality of the product.  The lack of portability ofconformity assessment data is an obstacle that often results in such duplicative and redundant testing
and certification.  Testing and certification that has been conducted in accordance with the recognized
internationally harmonized standards by reputable organizations should be recognized by the
regulations.  Additional testing and certification repeats that which has already been completed
without offering any additional value.  These NTMs need to be eliminated in order to promote tradeG/IT/SPEC/Q2/12
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and to continue development of all commerce (including e-commerce) to advance worldwide
economic growth.
For example in some countries an additional “mark” must be placed on IT products after
approval by an agency of that country to show conformance with its Electro Magnetic Conformity(EMC) requirements.  These countries will not accept foreign test reports but require in-country
testing -- in effect, mandating duplicative testing.   In addition, there are cases in which each separate
manufacturing location cited in a country’s certification application is subject to inspection in addition
to the original certifier.  This process results in redundant and duplicative factory inspections, wasting
the time and resources of the manufacturer as well as the regulators – again without any added value –
in the cases where the product is identical.
The portability of conformity assessment can reduce the redundant testing and certification of
products.  The global acceptance of existing marks of conformity once the products have been
certified to the internationally harmonized standard (including, in the case of safety, national
deviations for the interface to the national electrical infrastructure) would be of great benefit to the
customer and to manufacturers with no decrease in the level of safety.  Two examples of  
conformity
assessment are national treatment of either third party marks of conformity or suppliers declaration of
conformity.
Multiple testing to common requirements by third parties worldwide does not increase safety.
It imposes unnecessary burdens on IT manufacturers and customers in the form of additional costsand delays in product availability.  Worldwide redundant testing requirements often lengthen the
time-to-market for computers, computer peripher als and telecommunications equipment by eight
weeks or more.  The U.S. International Trade Commission (ITC) has estimated that duplication in
United States and European testing and certification for computers, telecommunications equipment
and other IT products costs U.S. companies and consumers more than $1.3 billion annually
1.
Furthermore, a comprehensive study by the Organization for Economic Cooperation and
Development (OECD) shows that OECD countries’ approval requirement for telecommunications
--which lead to testing redundancy similar to that for safety -- accounts for slightly over 2 percent of
the price of the exported products2.
In an industry marked by rapidly evolving technology and short product life cycles an
eight-week delay in getting products to market imposes substantial adverse effects on ITmanufacturers.
Certificate of Origin Mandates
The certificate of origin requirement is an additional, unnecessary documentation requirement
that appears to violate the ITA and that has become a significant NTM for trade in IT products.  The
certificate of origin requirement can be extremely burdensome in that it can take a full shipping day
(or longer if the shipment is scheduled for delivery on a weekend) to get the certificate of origin
approval from the exporter’s shipping country.  Even a one-day delay translates into millions of
dollars worth of products in inventory that cannot be shipped to the ultimate destination.
                                                     
1 U.S. International Trade Commission, Office of Industries, "Global Assessment of Standards Barriers
to Trade in the Information Technology Industry," November 1998, p. 4-8.
2 OECD:  "Product Standards, Conformity Assessment and Regulatory Reform." OECD Report on
Regulatory Reform. Paris: 1997 OECD.G/IT/SPEC/Q2/12
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The information submitted as part of the usual required customs documentation (i.e., a goods
declaration and/or invoice) is already sufficient for providing the information necessary to enter the
shipment and protect the revenue, commerce and customs laws of the importing country.
Furthermore, the certificate of origin requirement is very costly especially in the absence of an
explanation of the intent underpinning the requirement, making its utility in the import processdifficult to understand.
Conclusion
IT has played a pivotal role in worldwide ec onomic growth.  In order for this growth to
further expand to areas of the globe it has not yet reached, the elimination of non- tariff trade
measures such as redundant testing and  certification and mandated certificates of origin  are
imperative.  The ITA has made concrete progress in reducing tariffs on IT products to the benefit of
many.  More progress can be made in a similar fashion if non-tariff barriers to IT trade remain a
focused effort.
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