JOB/AG/197  
 
18 May 2021  
(21-4197) Page: 1/10 
Committee on Agriculture  
Special Session  Original: English  
 
SUBMISSION BY CANADA  
TRANSPAREN CY ISSUES IN DOMESTIC SUPPORT NOTIFICATIONS  
The following submission, dated 12 May 2021, is being circulated at the request of the delegation of 
Canada . 
 
_______________  
 
 
The objective of this paper is to illustrate how various transparency issues in notifications affect 
Members ' ability to analyze  and deepen  our understanding of the state of domestic support in 
agriculture. This paper identifies different types of transparency issues in domestic support 
notifications and uses an evidence -based approach to quantify their prevalence. The paper also 
presents the most recent trends in domestic support using Canada' s domestic support analytical tool 
(JOB/AG/190 ), and looks at the implications of d ata gaps in analyzing the total amount of domestic 
support provided by Members and the percentage of Members who are using certain categories of 
domestic support.  
1  METHODOLOGY  
1.1.  All data used to conduct this analysis were sourced from Canada' s domestic suppor t analytical 
tool ( JOB/AG/190 ). The analytical tool includes all DS:1 notifications submitted by Members as of 
17 November 2020 for the 2001 to 201 9 period, as well as additional third party data for exchange 
rates (International Financial Statistics (IFS)) and for unnotified value of production numbers (FAO). 
Full methodological details can be found in the Excel worksheet labelled Info in JOB/AG/190 . 
2  TRANSPARENCY ISSUES AND DATA GAPS  
2.1.  Notifications provide information on the domestic support practices of WTO Members. Having 
a large number of Members providing up to date notifications which cover all measures in favo ur of 
agricultural producers with quality information is vital to the Membership 's collective ability to 
undertake a thorough assessment of the state of play of domestic support in agriculture.  
2.1  Participation in the Notification Process  
2.2.  One of the transparency issues in domestic support can be attributed to Members that have 
never submitted an annual domestic support notification. Out of 135 Members in 20201, 34 Members 
have not subm itted a domestic support notification in the 2001 –2019 period. This means that 
assessments on domestic support practices are based on only 75% (or 101) of the Membership.  
 
1 The European Union and its member States are counted as one Member. The United Kingdom is not 
listed separately in the tables as it was an EU member State in the years covered in this document. 
Switzerland and Liechtenstein are also counted as one Member a s they submit a joint domestic support 
notification. The number of Members individually accounted for in any one year is thus smaller than the full 
number of Members.   JOB/AG/197  
 
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  Figure 1: Number of Members that submitted at least one notification since 2001, as of 
17 November 2020  
 
 
2.2  Timeliness of Notifications  
2.3.  The timeliness of notifications is a second type of transparency issue that impedes the analysis 
of domestic support. For the 101 Members who submitted at least one notification since 2001, t he 
median year of their most recent notification was 2016. As of 17 November 2020, 16 Members have 
submitted a notification for notification year 2019 and three Members have not submitted a 
notification later than notification year 2004.  
Figure 2: Distrib ution of the number of Members by most recent year of Domestic 
Support notification, as of 17 November 2020  
 
2.4.  The year selected to describe and assess trends in domestic support will have implications for 
the quality and completeness of information. As sho wn on figure 3, the number of DS:1 notifications 
submitted to the WTO, as of 17 November 2020, is relatively comparable for the 2001 to 2015 years, 
but the number of notifications submitted is lower for more recent years. For example, statistics 
extracted from the year 2016 (i.e., the median for the most recent notifications) will yield outcomes 
that reflect the notifications of only 63 Members2 (or 62% of the 101 Members having submitted at 
least one notification). Taking into account the 34 Members who h ave yet to submit a notification 
since 2001, these 63 Members represent only 47% of the 135 Members. The further back we go in 
time, the more comprehensive the results are, as they include a greater number of Members. 
However, there is a trade -off in respe ct of whether older notifications can be reflective of the current 
situation of a Member.  
 
2 This number excludes four Members compared to figure 2, as they have submitted earlie r notifications, 
but did not provide a notification for 2016.  
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  Figure 3: Number of Members that have submitted a DS:1 notification, 2001 -2019  
 
2.3  Omitted support from DS:1 Notifications  
2.5.  Transparency issues can also be found in the domestic support notifications submitted by the 
WTO Membership. The WTO Trade Policy Review mechanism highlights the differences between the 
agricultural policies applied by Members and the agricultural policies reported in the domestic 
support notific ations. Notifications of most WTO Members typically underreport domestic support 
when compared against the agricultural programs identified in the trade policy reviews or a search 
of a Member 's website. Many programs and measures are also omitted in the do mestic support 
notifications. This issue is also discussed regularly in the Committee on Agriculture (COA).3 Some 
domestic support notifications notably omit some Green Box general services (paragraph 2, 
Annex  2), such as expenditures related to inspectio n services, pest and disease control services, or 
infrastructural services. Other notifications exclude more trade and production related forms of 
domestic support, including product and non -product specific Amber Box programs, and market 
price support pol icies. 
2.6.  Perhaps the best indication that Members exclude certain elements of their domestic support 
policies from notifications is the number of Members that have reported having no support over the 
years (in both the Green Box and Article 6). This is in co ntrast to information about agricultural 
programs that can be found on a Member 's governmental web site. Between 2001 and 2019, on 
average 11 Members notified no support in any given year with a high of 17 Members notifying no 
support in 2002. In total, 20  Members reported no support in at least one year, and a total of 
12 Members reported no domestic support in all their notifications between 2001 and 2019.4  
 
3 In JOB/AG/181 , it was identified that Members posed market price support -related quest ions to at 
least seven notifying Members regarding the potential omission of market price support measures in their 
notifications.  
4 Yearly differences in the number of Members that have reported no support varies for a variety of 
reasons, which for the 20  Members includes inconsistencies in submission of notifications, no recent submission 
of DS:1 notifications, date of accession, measures reported in some years but not others and least -developed 
status ( G/AG/2  only requires least -developed Members to submit Supporting Tables DS:1 to DS:3 every two 
years).  
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  Figure 4: Number of Members that notified having no Domestic Support, 2001 -2019  
 
2.4  Quality of Notifications  
2.7.  A significant number of transparency issues are also related to the quality of domestic support 
notifications notified by Members. A review of notifications and questions posed in the WTO 
Committee on Agriculture ( JOB/AG/181 ) identified many transparency issues related to quality of 
notifications. This notably includes incomplete descriptions of programs, classification and non-
notification issues, data manipulation related to inflation and changes in notified currency, and 
inconsistencies in how Members notify similar programs. A more accurate and detailed 
representation of programs in notifications would help to better moni tor and analyze the total 
amount of domestic support provided by Members and the percentage of Members who are using 
certain categories of domestic support.  
2.5  Relative -Based Analysis: The Importance of Value of Production  
2.8.  To compare the level of agricultural  support of Members with an agriculture sector of varying 
size, it is necessary to have a common basis for comparison. The total agriculture value of production 
(VOP) remains a generally accessible and standardized source of data to use as a basis for scal ing 
Members domestic support levels against the size of their respective agriculture sector.  
Figure 5: Number of Member that have reported total Value of Production, 2001 -2019  
 
 
2.9.  According to the analysis conducted, 57 Members have never reported to the S ecretariat or in 
a notification total value of production for any year since 2001; 28 Members have reported this 
information for all years; and 16 Members did not consistently reported this information for all 
years.5, 6 The inclusion of total value of p roduction data in Members ' notifications was also analyzed 
 
5 A Member was classified in "VOP Reported for All Years " if for each year a DS:1 notification was 
notified, the total value of production was reported to the Secretariat (as part of CoA -SS transparency 
exercise) or in the notification itself.  
6 This compilation of data does not differentiate whether a Member had to report total value of 
production to calcu late non -product AMS de minimis or not.  
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  in JOB/AG/181 . Although total value of production is only required to determine de minimis when 
Members notify non -product specific AMS, the WTO would benefit from more Members reporting 
their total value of production data (even for the Members that do not report non -product specific 
AMS) in order to avoid having to rely on third -party sources (e.g., the FAO) to compare data on a 
relative basis.  
2.10.   At the very least, Members who are notifying non -product specific AMS and product -specific 
AMS should be required to notify total value of production and value of production for each product. 
This requi rement would not create an additional burden since Members would need this data in order 
to determine de minimis .  
3  TOTAL DOMESTIC  SUPPORT  
3.1  Effects of Transparency Issues on Total Domestic Support  
3.1.  Our ability to monitor total domestic support (i.e. the sum o f all domestic support notified by 
Members) of the WTO Membership is affected by the transparency issues identified in the first 
section:  
a. the number of Members participating in the notification exercise;  
b. the delay in notifications;  
c. omitted support in noti fications, and;  
d. the quality of the information . 
3.2.  These issues impair our collective ability to quantify the overall amount and nature of the 
domestic support Members have provided. The calculated total amounts based on Members ' 
notifications should therefor e be seen as the minimum quantifiable value at a specific time and not 
as fixed and immutable data.  
3.3.  Despite transparency issues limiting the full picture of total domestic support, there are findings 
that reinforce the reliability of domestic support amoun ts to identify certain trends.  
3.4.  First, domestic support notified by the ten largest users of domestic support represents over 
90%7 of all support notified by Members and these Members ' notifications are generally more up -
to-date than those of many other M embers.8 Given the size of the support provided by the largest 
users, the relative weight of the missing notifications or omitted support from smaller Members 
(transparency item a., b., c.) is likely to be too low to have a decisive impact on the overall trend. 
On the other hand, this means that this metric is reflective of the behavio ur of the largest Members 
more than smaller Members. Furthermore this also means that the quality of information and omitted 
support (transparency item c., d.) provided by th e largest users of domestic support would have a 
large impact on this metric.  
3.5.  Second, as it will be demonstrated in section 4, it is rare to observe a change in the type of 
support reported by a Member. Measures that have already been notified once in a notification tend 
to be notified in subsequent notifications. This seems to indicate that although there are "gaps" in 
Members ' data, the overall amounts are comparable over time, because they tend to capture 
evolutions in the same programs over time. Comp arability over time remains however sensitive to 
the quality of information reported by Members.  
 
7 Between 2012 and 2016, the 10 largest domestic support users reported between 90% and 94% of all 
domestic support.  
8 As of 17 November 2020 only one of the 10 largest users of domestic support most recent notification 
was below the median year of 2016. For that Member, the most recent year was 2015.  JOB/AG/197  
 
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  3.2  Trends in Total Domestic Support  
Figure 6: Total Support in all Domestic Support categories, 2001 -2019  
 
 
3.6.  Figure 6 – Total domestic support has been increasing year after year, but the growth has 
slowed in recent years. Green Box continues to account for the majority of support reported by 
Members. As shown above, support under the Green Box as a percentage of total dom estic support 
increases year after year.  
Figure 7: Total Article 6 support, 2001 -2019  
 
 
3.7.  Figure 7 – Support under Article 6 has grown at a slower pace than the Green Box since 2001. 
Since 2008, notified support in Blue Box and under Article 6.2 has been re latively stable. Support 
notified under the Amber Box (support under Article s 6.3 and 6.4) has also stabilized in recent years, 
but has sharply declined in 2016.  
JOB/A G/197  
 
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  Figure 8: Total Amber Box, CTAMS and de minimis , 2001 -2019  
 
 
3.8.  Figure 8 - The share of Amber Bo x support (CTAMS + de minimis ) notified under the current 
total AMS (CTAMS) has significantly decreased since 2001. On the other hand, support notified under 
de minimis  now represents the majority of Amber Box support.  
Figure 9: Share of Amber Box – non product -specific AMS vs. product -specific AMS (%), 
2001 -2019  
 
 
3.9.  Figure 9 – The share of Amber Box support reported under product specific AMS has declined 
since 2001. Th e product -specific AMS to non  product -specific AMS ratio has been relatively stable 
since 2008.  
4  PERCENTAGE OF MEMBERS USING CERTAIN CATEGORIES OF DOMESTIC  SUPPORT  
4.1  Effects of Transparency Issues on the Ability to Monitor the Types of Domestic 
Support Used b y Members  
4.1.  The numbers and percentages of Members reporting support under the different categories of 
support provide a better understanding of the types of support used by Members. The percentage 
of Members reporting a specific type of support is calculate d as the number of Members that have 
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  notified support under that category of support, divided by the number of Members that have 
submitted a notification for that year. This metric is very sensitive to the data gaps identified in this 
paper, but reveals de tails on the practices of all Members that have notified information, regardless 
of their size. Unlike total support data, the percentage of Members using each type of support can 
be more impacted by missing notifications, however the direction of this eff ect is not predetermined 
(could be positive or negative).  
4.2  Trends in the Percentages of Members Reporting Support in each Category  
4.2.  This section presents a data series on the percentage of Members that reported using certain 
types of support over the years. The denominator (number of Members) to calculate the percentage 
of Members reporting support varies every year depending on the number of notifications submitted 
for that specific year.  
Table 1: Percentage of Members reporting support by main categories of 
Domestic  Support, 2001 –2019  
 Amber Box  Article 6.2*  Green Box  Blue Box  
2001 41% 45% 76% 4% 
2002 43% 45% 75% 4% 
2003 44% 44% 82% 4% 
2004 43% 49% 80% 4% 
2005 42% 49% 81% 4% 
2006 43% 63% 81% 5% 
2007 44% 52% 84% 5% 
2008 44% 51% 84% 5% 
2009 44% 48% 81% 5% 
2010 42% 46% 84% 5% 
2011 42% 46% 82% 5% 
2012 44% 52% 83% 5% 
2013 47% 47% 81% 5% 
2014 45% 51% 81% 5% 
2015 44% 49% 79% 5% 
2016 48% 51% 83% 8% 
2017 46% 43% 83% 7% 
2018 40% 48% 83% 3% 
2019 38% 36% 94% 6% 
* Relative to the number of Members that may exempt support under Article 6.2.  
4.3.  Table 1 – The percentage of Members reporting support in the main categories of domestic 
support has been stable over time and has only experienced small variations between 2001 and 
2016. Green B ox is the type of support with the highest proportion of users (81% on average), 
followed by Article 6.2 (48% of developing Members that may exempt support under Article 6.2), 
the Amber Box (43%), and the Blue Box (5%).  
Table 2: Percentage of Members repo rting support in Green Box sub-categories, 
2001 -2019  
 General Services  Direct Payments  Domestic Food Aid  Public Stockholding for 
Food Security Purposes  
 Para.2  Paras. 5 -13 Para. 4  Para. 3  
2001 76% 44% 20% 20% 
2002 75% 47% 20% 19% 
2003 82% 52% 21% 19% 
2004 80% 51% 22% 19% 
2005 81% 53% 22% 22% 
2006 81% 51% 22% 23% JOB/A G/197  
 
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   General Services  Direct Payments  Domestic Food Aid  Public Stockholding for 
Food Security Purposes  
2007 84% 56% 25% 26% 
2008 82% 55% 21% 26% 
2009 81% 53% 23% 26% 
2010 83% 57% 21% 24% 
2011 80% 54% 21% 21% 
2012 82% 53% 22% 23% 
2013 79% 50% 22% 18% 
2014 79% 50% 22% 18% 
2015 78% 48% 19% 18% 
2016 83% 57% 21% 17% 
2017 83% 54% 24% 17% 
2018 83% 63% 23% 23% 
2019 88% 63% 6% 19% 
 
4.4.  Table 2 – The percentage of Members reporting support in all Green Box subcategories has 
also been stable since 2001. The general service subcategory is the most used Green Box category 
(80% on average), followed by direct payments (52%), domestic food aid (21.4%) and public 
stockholding for food security purposes (21.2%).  
Table 3: Percentage of Members – product -specific AMS, non product -specific AMS, and 
CTAMS, 2001 -2019  
 Product Specific AMS  Non-Product Specific AMS  CTAMS  
2001 37% 27% 21% 
2002 37% 29% 24% 
2003 40% 30% 25% 
2004 39% 29% 24% 
2005 38% 30% 26% 
2006 38% 32% 27% 
2007 40% 31% 27% 
2008 39% 31% 23% 
2009 37% 31% 24% 
2010 36% 32% 25% 
2011 38% 32% 22% 
2012 39% 32% 25% 
2013 41% 33% 23% 
2014 38% 32% 23% 
2015 36% 32% 26% 
2016 40% 38% 25% 
2017 37% 39% 22% 
2018 31% 31% 20% 
2019 25% 25% 19% 
 
Table 3 – Regarding Amber Box, the percentage of Members that notified product -specific AMS and 
non-product specific AMS did not change significantly over the years.9 On average, more Members 
reported product specific AMS (38%) than non -product specific AMS (31%). The number of Members 
who reported a positive current total AMS (CTAMS) was also relatively stable, at 24% of Members 
on average.  
 
9 Product -specific AMS and non  product -specific AMS refers to support above and below de minimis  
(Articles 6.3 and 6.4) . JOB/AG/197  
 
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  Figure 10: Number of Member s that notified CTAMS over FBTAMS at least once over five 
years increment, 2001 -2019  
 
4.5.  Figure 10 – A total of nine different Members have reported a current total AMS (CTAMS) 
support greater than their final bound total AMS (FBTAMS) at least once since 2001.10 Eight of the 
nine Members reported CTAMS over FBTAMS for consecutive years, and one Member reported 
CTAMS ove r FBTAMS for 14 consecutive years. Five Members reported CTAMS over FBTAMS in their 
last DS:1 notification year.  
5  CONCLUSION  
5.1.  Transparency issues related to the rate of participation in the notification process, the 
timeliness of notification, the omission o f measures and the quality of information contained therein 
are all elements that contribute to obscuring our understanding of the worldwide state of domestic 
support in agriculture. Despite these data limitations, an analysis of total support and the perc entage 
of Members using various domestic support categories can provide useful insights into trends in 
domestic support practices of Members. While undertaking this analysis, it is important to keep in 
mind the potential bias and limitations stemming from these transparency issues.  
5.2.  Improving transparency can help facilitate the negotiation of new rules on domestic support 
that address the current situation and practices of WTO Members. Taking steps to increase the 
participation rate, the frequency of notifi cations and timeliness of notifications, the completeness 
and the quality of the information are elements that can be addressed in the short -term.  
5.3.  In addition, additional data on total value of agriculture production and values of production 
for each product is also needed in order to be able to better compare Members in relative terms. 
Members that have not notified or have inconsistently reported t otal value of production should be 
invited to supplement these submissions by the Membership in support of increased transparency. 
Members should also reflect on the merits of requiring DS:1 notifications to include total value of 
production data, even for  Members that have not provided non -product specific AMS.  
5.4.  These adjustments are needed to address the current limitations and to improve our 
understanding of the state of play in the domestic support pillar.  
__________  
 
10 For ease of understanding, Members wi th no FBTAMS in their Schedules were assumed to have an 
FBTAMS of 0.