G/TBT/W/798  
 
11 March 2024  
(24-2208) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
PROPOSAL ON PROVISION OF TRANSLATION INTO WTO 'S OFFICIAL LANGUAGES  
TENTH TRIENNIAL REVIEW  
Proposal from the European Union  
The following submission, dated 11 March  2024, is being circulated at the request of the delegation 
of the European Union . 
 
_______________  
 
 
1  BACKGROUND  
1.1.  Transparency obligations remain at the core of the TBT Agreement. Their fulfilment is necessary  
for the  attainment of the objectives of the Agreement. One of key transparency obligations is  
embedded in the obligation to notify measures at the draft stage, when making comments is  
possible.  
1.2.  The Members can comment effectively only if they are able to understa nd the notified measure  
and to correctly assess its potential impact. This cannot be achieved without access to a reliable  
translation of the draft measure. Article 10.5 of the TBT Agreement facilitates this objective when  it 
provides that "developed count ry Members shall, if requested by other Members, provide, in  English, 
French or Spanish, translations of the documents covered by a specific notification or, in  case of 
voluminous documents, of summaries of such documents ". However, this is not the case  for 
measures adopted and notified by developing country Members thus making it difficult to  submit 
comments within the 60 days commenting period.  
1.3.  During the Ninth Triennial Review the lack of translations of notified measures into one of the  
official WTO languages was named as one of the main challenges in the process of preparing  
comments on notifications by several Members.  
1.4.  Available statistical information demonstrates that during the period covered by the present  
Triennial Review numerous notifications submitted by developing country Members were not  made 
available in any of the official languages of the WTO .1 
1.5.  Most of WTO Members, including developing country Members do not have the capacity to  
translate all incoming notified measures so t hat their officials and domestic stakeholders can  easily 
assess the content of the draft measures.  
 
1 During the period of 2021 -2023, China notified 263 measures (including 248 new notifications), 
Indonesia notified 60 measures (including 37 new notifications), the Kingdom of Saudi Arabia notified 
180 measures (including 140 new notifications). This gives  a total of 503 measures (including 425 new 
notifications) from these three Members, none of which could have been assessed without a reliable 
translation. These three Members were selected as example only, based on the number of notifications they 
submit and on the frequency of requests from EU stakeholders for translations of the measures notified by 
them.  G/TBT/W/798  
 
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  1.6.  Even when some Members translate the full text of another Member 's notified measure(s) into  
any of the official WTO languages, there is no widely used mechan ism to either share or to inform  
other Members of the availability of such translation .2 
1.7.  Given that machine translations may contain important errors which could lead to  
misinterpretations of the notified measures, it is important to enhance cooperation b etween  
Members through sharing reliable translations of measures into the official WTO languages  
between  the Members.  
1.8.  Technical regulations and conformity assessment procedures are complex and often cover  
technical issues. Correct translation is key in all owing the Members to assess the measure  properly.  
1.9.  In the Ninth Triennial Review the Secretariat was asked to explore the use of available AI tools  
such as translation software to enable the provision of unofficial translations for all notified  measures 
in the WTO 's three official languages.  
1.10.  Additionally, the Members were encouraged to announce, through ePing, the availability of  
the translation of either partial or the full text of another Member 's notified measure into any of  the 
official WTO languages.  
2  PROPOSAL  
2.1.  Taking into account the fact that:  
• There are no tangible results of the exploration of the use of available IT tools, such as  
translation software, in order to provide unofficial translations of notified documents into 
the three official WTO languag es through TBT online tools;   
• the use of AI technology for translation of notified measures cannot be accepted by all  
Members;  
• the use of AI technology for translations would generate substantial additional costs to be  
covered by already stretched ePing bu dget;  
• the ePing is not widely used by the Members as a platform to share available translations,  
and when shared through ePing "outreach " functionality, these translations are not 
labelled  as "translator " or "machine " which does not allow for quick reliability check of 
these  translations for the preparation of official comments by the Members.  
2.2.  The European Union would like to propose the following steps to increase the transparency and  
to reinforce the cooperation on s haring of verified translations:  
a. to ask the Secretariat to develop in ePing an easily accessible functionality of "verified  
translation "3, to be made available for the Enquiry Points;  
b. to encourage all Members to strive towards providing translations of th e measures they  
notify into one of the WTO 's official languages, upon request, within the limits of their  
capacities;  
c. to encourage the Enquiry Points of interested Members to establish a "translations  
cooperation network " to share best practices, seek ways  for burden sharing in translating  
the notified measures of common interest by pooling resources and avoiding the  
duplication of work.  
__________  
 
2 Although ePing "outreach " module is used by some Members to upload translations, it is not always 
clear what kind of translations they are (machine, translator). It is therefore not always a fully reliable source 
for the assessment of notified measures for the preparation of offic ial comments.  
3 "verified translation " meaning:  
- Translation prepared by a professional translator or  
- Translation prepared by a government official who understands the original language of the measure or 
- Machine translation, reviewed by a professional  translator or a qualified government official.