. /.WORLD TRADE
ORGANIZATIONG/TBT/W/222
1 July 2003
(03-3486)
Committee on Technical Barriers to Trade Original:  English
THIRD TRIENNIAL REVIEW OF THE TBT AGREEMENT
Submission by Japan
I. INTRODUCTION
1. The Second Triennial Review of the TBT Agreement could not complete exhaustive
discussions in the area of conformity assessment, as indicated by the fact that the TBT Committee wasunable to agree on the adoption of best practices or principles governing conformity assessment.  For
the Third Triennial Review of the TBT Agreement, Japan considers that one of the focuses should be
on the area of conformity assessment.
2. In this regard, it would be beneficial for Me mbers to further examine the following issues in
the area of conformity assessment:
(i) use of appropriate accreditation scheme as a complement to or as a basis for
Mutual Recognition Agreement (MRA), and
(ii) possibility of the use of “suppliers’ declaration of conformity (SDoC)”
scheme which would be more transparent and objective with the use of
international standards (including drafts) for SDoC.
II. ACCREDITATION
3. As is indicated in the paper from Canada (G/TBT/W/210), Canada points out that
accreditation system utilizing internationally harmonized standards, guides and recommendations that
have been developed on the basis of consensus would provide the confidence of accreditation-based
conformity assessment services.  It also points out that international and regional conformity systemssuch as those of ILAC, IAF, etc, provide the framework based on the principle “one accreditation,
accepted everywhere”, and have the potential to reduce or eliminate duplicative costs of conformity
assessment and reduce delays in the delivery of products to market.  Japan echoes these suggestion.
4. Documents developed by these fora, in addition to the international standards and guides
developed by ISO are utilized in Mutual Recognition Arrangements among the accreditation bodies or
in actual accreditation procedures.  However, we should be mindful about some facts associated with
these fora.  For example, ILAC, IAF etc. do not accept the Code of Good Practices which is described
in the Annex III of the TBT Agreement.  In addition, participants involved in the development of the
documents are in many cases from accreditation bodies, and therefore opinions from variousinterested parties are not necessarily considered.
5. In our view, it would be desirable for these international systems to improve the procedural
transparency and openness in the development of their guidance to acquire confidence of
governments, industry and consumers.  For this purpose, Japan considers it is necessary for Membersto observe the “seven principles for the development of international standards” that was agreed upon
at the Second Triennial Review of the TBT Agreemen t.  Furthermore, Japan considers it is necessaryG/TBT/W/222
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to make sure that the documents developed by these international systems do not add any further
requirements to existing ISO documents, but merely provide interpretative guidance to them.
6. While many documents related to conformity  assessment developed by ISO/CASCO are used
by regulatory authorities of each Member as basis for conformity assessment procedures, we shouldbe aware that the opinions from regulatory authorities may not always be adequately reflected in the
process of developing such ISO/CASCO documents.  It is necessary that TBT Members encourage
ISO member to participate in the process of development of guides/recommendations for conformity
assessment.  To cope with such a circumstance, Japanese Industrial Standards Committee (JISC), on
behalf of Japan, proposed CASCO to set up a group, namely “Regulators Interface Group”, which
aims at improving mutual understanding between ISO/CASCO and regulatory authorities.  Japan
currently holds the convenorship of this group.
7. Strengthening the interrelation between mandatory regulations and voluntary conformity
assessment system would be important in terms of reducing duplicative costs or in the light of the
trend of de-regulation.  At the same time, in order for the regulatory authorities to utilize such
voluntary conformity assessment system, high leve l of moral standards and ethics, which would be
similar to those applied to government officials, should be applied to all the managers and staffs
working at the conformity assessment bodies as well  as the conformity assessment bodies themselves.
For this reason, we expect that the “Code of good practice for conformity assessment” which is
currently under development at the ISO/CASCO WG22 will include some guidance on ethics code
which would be similar to those applied to government officials.
III. SUPPLIERS’ DECLARATION OF CONFORMITY (SDOC) AND OTHER
INSTRUMENTS
8. Suppliers’ declaration of conformity (SDoC) is one of the important tools to realize efficient
and effective conformity assessment systems. However, acceptance of SDoC would require thatSDoC is carried out based on scientific basis and on appropriate procedures.  In this regard, Japan
considers the following two factors are important to enhance the wide use of SDoC.  Firstly, the
suppliers should use test/inspection report from a competent third party or in house testing/inspecting
laboratory whose ability and fairness are confirmed by accreditation in accordance with
ISO/IEC 17025.  Secondly, the suppliers may use a draft international standard (ISO/IEC DIS 17050)
to secure transparency and accountability of their procedures.
9. Furthermore, Japan shares Canada’s view that the IECEE CB scheme is now being expanded
to non-IEC members, and manufacturers in developing countries are the primary beneficiaries of the
expansion.  Japan considers that supporting the effort of conformity assessment bodies in developing
countries to participate in the CB scheme is important in terms of capacity building to developing
countries.  In this regard, Japan is engaged in technical cooperation in these areas.
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