RESTRICTED  
  
WT/ACC/COM/23/Rev.4  
22 March  2022 
(22-2459) Page: 1/13 
Working Party on the Accession of  
the Union of the Comoros  Original:  French  
 
  
ACCESSION OF THE UNION OF THE COMOROS  
ACTION PLANS TO ENSURE THE WTO  CONSISTENCY OF NATIONAL LAWS1 
Revision  
The following communication, dated 22 March  2022, is being circulated at the request of the 
delegation of the Union of the Comoros . 
 
 
_______________  
 
  
 
1 Please note that the Comoros undertakes to complete the actions to be taken listed under sections A, 
"Measures during the accession process", prior to accession to the WTO. The actions to be taken listed under 
sections B, "Measures after accession", will be completed after accession to the WTO following the 
implementation ti me-frame.  WT/ACC/COM/23/Rev.4  
- 2 - 
  TABLES OF CONTENTS  
 
1. SPS-RELATED MEASURES  ................................ ................................ ...........................  3 
2. TRIPS -RELATED MEASURES  ................................ ................................ .......................  8 
3. CUSTO MS FORMALITIES  ................................ ................................ ............................  9 
(a) Measures related to the Customs Valuation Agreement  ................................ ....................  9 
(b) Fees and charges  ................................ ................................ ................................ ...... 10 
(c) Trade fa cilitation  ................................ ................................ ................................ ........  10 
4. TBT-RELATED MEASURES  ................................ ................................ .........................  12 
5. MEASURES RELATED TO THE FOREIGN TRADE REGIME  ................................ ............  13 
   
  WT/ACC/COM/23/Rev.4  
- 3 - 
 
1. SPS-RELATED MEASURES  
Description  Action to be taken  Time -frame  
Adoption of the principles of equivalence, transparency, 
zoning and compartmentalization  1. Preparation of provisions on equivalence  
2. Infrastructure development and human resource capacity building  2020-2023 
2023-2024 
Establishment of the National Plant Prote ction 
Organization (NPPO) in accordance with IPPC 
requirements  Establishment of an office and appointment of the officials in charge  Fourth quarter  of 2023  
Establishment of technical libraries, for example, a CODEX 
library  Establishment of a CODEX library  2022-2023 
Establishment of a multisectoral laboratory  1. Establishment of laboratory  
2. Purchase of necessary testing equipment  Fourth quarter  of 2022  
2022-2023 
Establishment of a medium - and long -term training plan 
for PVS tool application  Preparation of a five -year training plan for:  
• First year: three veterinary surgeons  
• Six veterinary inspectors  
• Six veterinary nurses   2022-2025 
Promotion of good local governance for SPS measures  1. Define and adopt clear governance procedures for the SPS system 
entities, and their dissemination to all entities involved in implementing 
the SPS system  
2. Encourage all actors to take ownership of the regulations  
3. Support the entities involved in implementing the SPS system as part 
of drafting and implementing a p rogramme of action  
4. Define and put in place the consultation framework for all entities 
involved in implementing the SPS system  
5. Define the roles and responsibilities of the stakeholders involved in 
implementing the SPS system to enhance co -management by fur ther 
empowering actors  
6. Study how all the entities that comprise the SPS system work with a 
view to identifying the opportunities of connecting to local and national 
systems and adapting them to users' needs  
7. Establish a network of all the entities involved in implementing the SPS 
system  
8. Promote the use of legislative, regulatory and technical texts in the 
management of the SPS system  
9. Establish a cross -cutting management and/or consultation structure at 
the island and national levels of the SPS system   1-9: 2022-2025   
  WT/ACC/COM/23/Rev.4  
- 4 - 
 
Description  Action to be taken  Time -frame  
Strengthen and operationalize the implementing entities 
of the SPS system, for example, the National Fishery 
Product Quality Control and Certification Office  1. Involve all relevant areas in the definition and implementation of the 
SPS system  
2. Adopt and implement the ecosystemic approach and support scientific 
management in the implementation of the SPS system  
3. Strengthen the links among the different entities by d efining 
sustainable management approaches and methods  
4. Define and promote the different stages of the process for 
implementing the SPS system with the stakeholders  
5. Define in detail the different stages in the process of implementing the 
SPS system for each  stakeholder  
6. Identify and assess the resources needed for each stage of the 
implementation process, from development to implementation and 
monitoring/evaluation  
7. Define the action plans on the basis of data characterizing each area of 
the SPS system  
8. Define the role and structure of each entity involved in implementing 
the SPS system  
9. Put in place a system to implement SPS measures that is clear, 
coherent and adapted to local realities, and define roles and 
responsibilities   
10. Define the action plan and manage ment at the level of each entity 
involved in the SPS system  
11. Put in place a system to monitor activities to implement the SPS 
system and management measures at the entity and global levels  
12. Develop outreach activities to support implementation of the SPS 
system and measures  
13. Study the possibility of involving farming, livestock farming and fishing 
communities in the implementation of the SPS system   1-13 : 2022 -2024   
  WT/ACC/COM/23/Rev.4  
- 5 - 
 
Description  Action to be taken  Time -frame  
Establish an SPS information system and strengthen 
communication among the actors  1. Involve all stakeholders implicated in implementing SPS measures in 
establishing the information system  
2. Involve and promote the participation of the research community in 
the process of implementing SPS measures  
3. Define the roles and responsibilities of eac h key player in collecting 
information  
4. Promote participatory research in the implementation of SPS measures  
5. Define and implement effective information -sharing procedures and 
strengthen communication among all stakeholders in the 
implementation of SPS measu res 
6. Identify and mobilize resources needed for the regular and efficient 
operation of the information system  
7. Collect the data needed for the characterization of each entity, 
including the relevant procedures  
8. Define appropriate indicators for monitoring the  entities involved in the 
SPS system  
9. Develop and implement an effective communication plan to support 
the capacity -building strategy of SPS system stakeholders  1-9: 2022 -2024   
  WT/ACC/COM/23/Rev.4  
- 6 - 
 
Description  Action to be taken  Time -frame  
Render operational the SPS system's implementation 
structures and strengthen their capacities  1. Improve the organization of the various entities involved in the 
SPS system by setting up an executive committee made up of 
stakeholders  
2. Promote fair representation of all users from the various entities 
involved in the SPS syst em 
3. Restructure and streamline the respective entities and adapt 
accordingly where necessary  
4. Ensure the regular rotation of members of the governing bodies of 
entities established for better engagement and good governance  
5. Support the bodies in the developme nt and implementation of a 
programme of activities  
6. Create a network of bodies at the island and national levels, and 
participate in existing SPS system networks at the regional and 
international levels  
7. Provide operational support to SPS system bodies and m obilize 
programmes and projects to support the establishment and operation 
of those entities  
8. Organize an awareness -raising campaign for greater participation and 
representation of professionals and users in the implementation of the 
SPS system (policy, str ategy, action plans, etc. at the local and 
national levels)  
9. Strengthen the capacities of actors at all levels to play an active role in 
the implementation of SPS measures  
10. Train specialists in all SPS areas so they can lend their skills to the 
development o f measures and techniques to promote the 
implementation of the SPS system  
11. Provide the relevant entities (customs, research centre…) with 
adequate and necessary tools and equipment to be able to carry out 
fully their role of monitoring and overseeing SPS me asures  
12. Train and strengthen the capacities of the autonomous partners of 
State institutions (civil society…) in order to implement measures to 
acquire recognized NGO status and capacities for specialist SPS areas, 
and to make them aware of their right to a dequate service and able to 
demand it  
13. Disseminate regularly SPS -related laws and regulations in force  1-13: 2022 -2024   
  WT/ACC/COM/23/Rev.4  
- 7 - 
 
Description  Action to be taken  Time -frame  
Strengthen synergy and promote cooperation among all 
stakeholders with a view to consolidating the 
implementation of the SPS system  1. Organize a regular meeting to validate and/or revise the 
capacity -building strategy of SPS system stakeholders  
2. Organize an annual meeting to take stock of implementation of the 
capacity -building strategy for stakeholders in the SPS system and 
identify possibilities  
3. Organize an annual meeting of services, programmes and projects 
involved in the SPS system with a view to sharing  progress made, and 
capitalizing on and developing synergies  1-3: 2022 -2024 
Implement the necessary accompanying measures  1. Develop and adopt the necessary regulatory provisions to support the 
implementation of UGD  
2. Conduct the review of the operation of the SPS system with a view to 
defining and implementing the necessary adjustments to meet users' 
needs  
3. Conduct the feasibility  study of decentralized actors' involvement in 
the implementation of the SPS system  
4. Carry out appropriate research and studies on the implementation of 
the SPS system in collaboration with national, regional and 
international research institutions, includi ng the University of the 
Comoros  
5. Undertake studies on the marketing channels of processed products   1-5: 2022 -2024 
 
    
  WT/ACC/COM/23/Rev.4  
- 8 - 
 
2. TRIPS -RELATED MEASURES  
Description  Action  to be taken  Time -frame  
Law on ratification of the 
2015 Bangui Agreement  Effective implementation  2022-2024 
Capacity building  Training of personnel, including customs officials, police officers, and officials responsible for 
protecting registered trademarks  2022-2024 
Creation of a registered trademarks database  Fourth quarter of 2022 
Computerization of the Comorian Intellectual Property Office ( OCPI) Fourth  quarter  of 2022 
    
  WT/ACC/COM/23/Rev.4  
- 9 - 
 
3. CUSTOMS FORMALITIES  
(a) Measures related to the Customs Valuation Agreement  
Description  Action to be taken  Time -frame  
Revision of the  2015 Customs 
Code to take into account 
Articles 1 -9 of the WTO Customs 
Valuation Agreement  Integration of Articles 1 -9 of the Customs Valuation Agreement into the Customs Code  Second quarter of 202 3 
Adaptation and implementation 
of the WTO valuation system  1. Implementation of valuation system in full conformity with WTO rules  
2. Adoption of a capacity -building programme identifying profiles and targets  
3. Workshops, seminars, and study and training visits for personnel/targ eted training for the 
actors concerned : customs, freight forwarders  
4. Preparation of manuals and operating procedures  
5. Preparation and printing of forms, brochures, etc.  
6. Mobilization of necessary resources  
7. Provision of tools needed to implement the Agreement  
8. Training for personnel on the Customs Valuation Agreement  1-8: Second quarter of 2022 
Creation of a technological 
information base including a 
database on risk assessment  1. Analysis of mirror data for statistical needs  
2. Risk assessment training ; workshops/seminars led by "risk assessment" specialists  Fourth quarter  of 202 2 
 
    
  WT/ACC/COM/23/Rev.4  
- 10 - 
 
(b) Fees and charges  
Description  Action  to be taken  Time -frame  
Elimination of other duties and charges (ODCs) – 
RCI (international cooperation fee ), RCCI 
(Chamber of Commerce and Industry fee) tax, 
AI (advance tax payment) and PI  
(import trade tax) – at the customs cordon  in 
the Comoros  1. Provision  to be made  for the e limination of the RCCI in the 2022 Finance Law  
2. Provision to be made for the e limination of the AI and RCI  in the 2023 Finance Law  
3. Provision to be made for the elimination of the PI in the 2024 Finance Law  1. First quarter of  2023 
2. First quarter of  2024 
3. First quarter of 2025  
Establishment of the VAT regime  1. Impact study on the implementation of VAT  
2. Consultations with large enterprises  
3. Communication campaign  
4. Preparation of a draft law in this respect, to be validated  at a national workshop  
5. Training of  accountants  
6. Creation of a control body  
7. Adoption of draft law by Parliament, and enactment  2022-2023 
Elimination of the Single Administrative Charge  
(RAU) a t the customs  cordon  Provision to be made for the elimination of the RAU in the 2024 Finance La w  First quarter of  2025 
 
(c) Trade facilitation  
Subject  Action  to be taken  Timetable  
Comments before entry into 
force Possibility for stakeholders to make comments on the planned introduction or amendment of trade regulations 
concerning the movement, release and clearance of goods  Second quarter of 2022 
Consultations  Provide for regular consultations between border agencies and traders or other stakeholders locate d within its 
territory (Article  2.2) Second quarter of 2022  
Formalities and 
documentation requirements  In consultation with the stakeholders, examine the formalities connected with importation, exportation and transit, 
and the documentation requirements, with a view to minimizing the effects/ complexity of operations and reducing 
and simplifying requirements  (Article 10.1)  Second quarter of 2022  
Appeal or review  Establish a legal system of administrative or judicial appeal or review so that any person subject to an 
administrative decision is entitled to a revision and correction, on an impartial and independ ent basis, with regard to 
decisions handed down by the customs authority (Article 4)  Second quarter of 2022  
Processing before arrival  Adopt or maintain a mechanism enabling the trader to submit important documentation prior to the arrival of goods 
(Articl e 7.1) Second quarter of 2022  
Electronic payment  Establishment of a mechanism allowing traders the option of electronic payment for duties, taxes, fees and charges 
(Article  7.2) Second quarter of 2022  
Authorized operator  Create a fair system that rewards respect for the rules and establish additional trade facilitation measures for 
selected operators (Article  7.7) Second quarter of 2022  
Average time necessary for 
release  Measure and publish, on a periodic basis and in a consistent manner, the average time it takes to release goods 
(Article  7.6) Second quarter of 2022    
  WT/ACC/COM/23/Rev.4  
- 11 - 
 
Subject  Action  to be taken  Timetable  
Disciplines concerning fees 
and charges  Implement disciplines covering fees and charges imposed on or in connection with importation or exportation, and 
limit them to the approximate cost of the services provided . This also includes a requirement for compulsory 
periodic publication and review of such fees and charges with a view to reducing their number and diversity  Second quarter of 2023 
Penalties  Ensure t hat penalty measures are applied to persons responsible for infringing a law, a regulation or a customs 
procedure . Such penalties shall be proportional to the degree and gravity of the offence, and conflicts of interest 
shall be avoided in establishing the m Second quarter of 2023 
Decision expected  On request, issue a reasoned decision within a specific time -limit, providing reliable and binding information on 
several customs issues prior to import/export (Article  4) Second quarter of 2023 
Separation of release from 
final determination  Adopt or maintain procedures allowing the release of goods prior to the final determination of customs duties, taxes, 
fees and charges (Article 7.3)  Second quarter of 2023 
 
    
  WT/ACC/COM/23/Rev.4  
- 12 - 
 
4. TBT-RELATED MEASURES  
A. Measures  during the accession process  
Desc ription  Action  to be taken  Timetable  
Establishment of the standardization and quality service  1. Submission of a memorandum to the Council of Ministers for approval  
2. Preparation of a draft decree of establishment  1-2: Second quarter of 2022  
B. Measures after accession  
Description  Action to be taken  Timetable  
Capacity building for quality infrastructure  Training on : 
− Metrology  
− Standardization  
− English language  2024 
 
    
  WT/ACC/COM/23/Rev.4  
- 13 - 
 
5. MEASURES RELATED TO THE FOREIGN TRADE REGIME  
A. Measures during the accession process  
Description  Action  to be taken  Timetable  
Implementation of the  Law on foreign trade  1. Preparation of implementing texts  
2. Training of personnel and organization of services concerned  
3. Implementation of the law by the relevant services  
4. Notification of the law and its implementing texts to the WTO  2022-2023 
 
__________