JOB/AG/199  
21 May 2021  
(21-4300 ) Page: 1/11 
Committee on Agriculture  
Special Session  Original:  English  
 
  
TOWARDS A  STRENGTHENED NEGOTIATION FRAMEWORK  
IN THE DOMESTIC SUPPORT PILLAR  
A METHODOLOGY FOR SUBSIDY ENTITLEMENT REDUCTIONS  
COMMUNICATION BY COSTA RICA  
The following communication, dated 18 May 2021, is being circulated at the request of the delegation 
of Costa Rica. 
 
_______________  
 
 
Background  
1.   Agriculture is the most distorted sector in global trade and the one that requires more substantial 
reforms in  WTO rules. It is urgent that Members continue the reform process as set out in the 
objective established in the preamble of the Agreement on Agriculture (AoA), and its Article 20, 
which clearly defines the scope of the negotiations, Members must achieve substantial progressive 
reductions in support and protection in agriculture. Success has been however, elusive, and new 
approaches are necessary to advance the reform in domestic support as agreed in 1995.  
2.   Recalling the conclusions from Room Docume nts RD/AG/75 and RD/AG/76, Costa Rica considers 
that ensuring a sustainable, balanced and fair result for the entire Membership will require, as a bare 
minimum,  (i) the need to address the trade -distorting potential of Members' domestic support; 
(ii) consi der all trade -distorting subsidies; (iii) avoid basing new reduction disciplines on the value 
of production; (iv) apply reductions that are proportional and have a rebalancing effect; and (v) give 
special consideration to specific needs and sensitivities o f all Members, in particular of the least 
developing ones.  
3.   Costa Rica 's analytical work shows that the current disciplines in the AoA do not provide the 
necessary level of granularity  to address the wide disparity in entitlements , both between groups 
and within groups of Members. Any discipline that attempts to move the refor m process by 
replicating the current architecture would not solve this issue. In our view, this situation could be 
addressed if Members put at the center of the discussion the potential to distort global markets at 
the individual and collective levels. In that line, indicators that estimate pragmatically the trade -
distorting potential can unveil new ways forward.  
4.   In this document, a new approach is explored based on the concepts of "Proportionality " in 
the reductions and "Progressivity " in the results. Costa Rica has developed a methodology  that 
effectively implements these principles, while accomplishing the objectives set out in the framework 
for negotiation on domestic support introduced in JOB/AG/177.  
I.  About the Principles and Concepts  
5.   Proportionality is the practical application of the principle of fairness in the reform process. 
Under proportionality, individual contributions are aligned with the trade -distorting potential of each 
Member. Following this principle, those that have more potential to distort global markets would 
contribute more to the reform process.  JOB/AG/199  
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  6.   Progressivity in the results implies a rebalancing effect in Members ' share in the global trade -
distorting potential. That is to say, the reductions must also narrow the gaps  between Members, 
level the playing field and lay the foundations for future reforms. Today, 10 Members concentrate 
79% of global entitlements and 88% of the total WTO actual annual support. In this context, proper 
implementation of the principle of progre ssivity in the individual contributions to the reductions 
would also decrease the concentration of the potential to distort global agricultural markets.  
7.   The trade -distorting potential expenditure (hereinafter  known as  TDPE ) of each Member 's 
domestic suppo rt is an estimate of the monetary amount that Members are entitl ed to spend under 
the current WTO rules. That is, trade -distorting domestic support covers all subsidies provided for 
under Article 6.2, Article 6.3, Article 6.4 and Article 6.5 of the AoA. Co sta Rica has proposed a 
measure of such indicator in RD/AG/76 and has used it extensively in its analytical work, some of 
which is included in this document (see Annex 1 for more details on the methodology).  
II.  About the Scope  
8.   According to Costa Rica 's estimates (Table 1 below), in aggregate the current annual potential 
expenditure in trade -distorting domestic support allowed under the AoA1 stands at a minimum of 
USD 905 billion, most of it under the so -called "Amber Box " entitlements. In comparison, total actual 
support notified in 2016 was comparatively low with US D 121.7 billion, while support encompassed 
under Article 6.2 and Article 6.5 accounts for  35% of that amount. Even though entitlements and 
actual  support amoun ts show such different structures, both share a common feature: their 
concentration among few Members. In fact, 10 Members concentrate almost 80% of the trade -
distorting potential expenditure of the entire WTO, while the same 10 Members concentrated more 
than 90% of total notified support in 2016.  
Table 1: An Estimate of Current and Potential Support Covered Under Article 6 of the 
AoA (in USD billion)  
 Notified support 
(2016)  Highest notified 
support* TDPE  Concentration 
(Top 10 TDPE)  
de minimis  44,0 74,3 683,8  76.5%  
AMS 34,3 52,4 174,3  90.8%  
Article 6.2 30,9 34,5 34,5 86.0%  
Article 6.5 12,5 12,8 12,8 94.3%  
Total TDDS  121,7  174,0  905,3  79.8%  
* Notified support estimated using the highest level of support given during the most recent three 
consecutive years (not identical for all Members) notified under each TDDS category  for each WTO 
Member.  
Source:  Costa Rica. Estimates based on information fr om JOB/AG/190 and the methodology described in 
Annex 1.  
9.   In Costa Rica 's view, the information shown above, along with the experience of the negotiation 
process in the domestic support pillar demonstrates that results based on the contribution of some 
Membe rs only, will not be politically viable. Likewise, the absence of any of the elements of domestic 
support would imply an imbalance in any agreement and uncertainty about the feasibility of future 
reforms. Thus, a feasible and sustainable result would need to include all forms of trade -distorting 
domestic support in the negotiation process. Costa Rica, along with the other co -sponsors of 
JOB/AG/177, recognizes this reality by proposing that negotiations take into consideration all forms 
of trade - and product ion-distorti ng domestic support under Article 6 of the AoA, while acknowledging 
at the same time that a negotiation will need to take place on the scope of the reform. In that line, 
careful consideration must be given to the treatment of each TDDS category  and its potential and 
actual use, as it will have a direct impact on the overall level of ambition and individual contributions 
to the reform process.  
  
 
1 As Article 6.2 and Article 6.5 potential expenditure was estimated using historical notified expenditure, 
the total TDP E must be considered as a minimum. It must also be noted that several Members have expressed 
concerns regarding the non -distorting natur e of the so called "Green Box " subsidies, an issue that deserves 
further analysis.  JOB/AG/199  
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  III.  Defining the Objective  
10.   The AoA applies different disciplines to trade -distorting support policies and between Members. 
As shown in Figure 1 below, the differences between Members ' access and use of entitlements create 
a very complex scenario. For instance, among the 10 Members with the highest TDPE, three are 
users of the so -called "Blue Box " programs, while five have notified expenditure on programs 
covered by Article 6.2 and three of those rely heavily on it. Eight Members have notified AMS beyond 
de minimis , even though three of them do not have access to it. Finally, two Members actively use 
their AMS entitlements while only one relies almost exclusively on its de minimis . As each Member 
has a different set of entitlements, spending patterns and flexibilities under Article 6 of the AoA, the 
establishment of specific discip lines by type of subsidy has proven too difficult given the wide range 
of domestic support policies among Members.  
Figure  1: Members with Highest TDPE  
TDPE and Notified  Support* 
 
* Support estimated using the highest level of support given during the most recent three consecutive 
years notified under each TDDS box (no year consistency).  
Source:  Costa Rica, based on information from JOB/AG/190, RD/AG/74 and FAOSTAT . 
11.   Costa Rica 's analysis shows that in aggregate terms, the WTO Membership uses less than 1 5% 
of the allowed support under the AoA. In fact  – and even though some Members have notified 
support beyond their allowed entitlements  – support as a percentage of available entitlements 
among the 10 Members with the highest levels of TDPE is also relativ ely low (see Figure 2). This 
creates an opportunity to target  the aggregate levels of trade -distorting potential expenditure, both 
at the global and the individual level s. 
JOB/AG/199  
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  Figure  2: Members with Highest TDPE  
Highest Notified Support* and Available Water  
 
* Notified support estimated using the highest level of support notified during the most recent three 
consecutive years under each TDDS box (no year consistency).  
Source:  Costa Rica, based on information from JOB/AG/190, RD/AG/74 and FAOSTAT.  
12.   In light of the above, Costa Rica is of the view that an objective where Members commit to cap 
and reduce the sum of current global agricultural trade - and production -distorting  domestic support 
entitlements by at least half by 2030 as set out in JOB/AG/177 g ives Members enough space to 
pursue their development agendas in the agricultural sector, while creating a path for ambitious 
reforms  in effectively cutting trade -distorting domestic support . 
IV.  Building Resilience Through Ambition: A Fixed Cap Approach  
13.   For Costa Rica, a fixed monetized global limit is the only mechanism that would guarantee a 
real reduction of trade -distorting support in the long term, it would  allow to  address the existing 
inequities in the current Agreement and fulfill the refo rm mandate while creating a more resilient 
AoA. The preference for a fixed cap approach is grounded on several reasons.  
a. First, from a systemic point of view, current de minimis  entitlements represent a trade -
distorting potential close to USD 683 billion a nd this amount will continue to grow as the 
global Value of Production ( VoP) grows .2  
b. Second, from a negotiating perspective, trade -distorting programs that result in an increase 
in production will also increase de minimis  entitlements, granting an expone ntial advantage 
to those Members that have more  resources, while also removing any remaining incentive 
to change the status quo.  
c. Third, while some Members have witnessed a steady increase in their VoP since the launch 
of the WTO, many others have been sub ject to strong fluctuations in the price and volume 
of their agricultural production in the last 10 years. For example, 59 out of 1383 WTO 
Members had a lower VoP in 2015 compared to 2014 (see Figure 3) and 71 out of 92 had a 
lower VoP in 2019 compared to 2018. While short term volatility might be expected, the fact 
that in 2012, 42 WTO Members had a higher VoP than the one estimated fiv e years later in 
2016, should suffice  to raise awareness on the impact that the current disciplines will have 
in future policy space and to realize the inconvenience of  a mobile cap approach.  
 
2 In JOB/AG/171 Australia and New Zealand estimate USD 2 trillion in Amber Box entitlements by 2030.  
3 Information extracted from FAOSTAT (VoP gross production value in Stan dard Local Currency).  
JOB/AG/199  
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  Figure  3: VOP G rowth  
Number of WTO M embers with Negative Growth Rates  
 
Source:  Costa Rica, based on information from FAOSTAT (VoP gross production value in Standard Local 
Currency) . 
14.   Natural disasters – such as hurricanes and droughts  – are already challenging the resilience of 
many countries and according to FAO, this situation will only worsen in the next 30 years as "climate 
change is expected to result in declines in agricultural production in large parts of Africa, the Middle 
East an d South and Southeast Asia ".4 Such scenario is compounded by unforeseen events such as 
the 2008 financial crisis, and more recently the COVID -19 pandemic.  
15.   Current disciplines in the AoA do not consider the impact of climate change and other 
exogenous even ts in future access and use of necessary domestic support policies, especially for 
small economies with increased vulnerability. In fact, any VoP volatility is translated directly into 
those disciplines based on the concept of de minimis . Indeed,  moving to wards a  monetiz ed global 
limit would create a more resilient regulatory framework for domestic support policies.  
V.  Choosing the Most Coherent Variable for a Proportional Reduction  
16.   The simplest approach to reduction modalities would only require the application of a reduction 
commitment based on variables like the size of entitlements in absolute terms, or as percentage of 
VoP. However, the implementation of this approach  would proba bly not address properly  the 
principle of proportionality.  
17.   This is the case of mobile caps based on the VoP. In practice , any effort to harmonizing the 
VoP towards current de minimis  limits would require very dissimilar reduction efforts from WTO 
Members. An analysis of the situation of the 10 Members with the highest TDPE levels (see Figures  4 
and 5 below), shows that depending on the level of ambition, the VoP approach may lead to 
situations where relatively lar ger Members may not need to contribute much – if at all – to the 
reform process if their VoP equivalents are already close to or at the new VoP limit. In contrast, 
relatively smaller Members may be required to significantly re duce their current policy space if their 
VoP equivalents are above the new limits.  
 
4 Source: FAO State of Agricultural Commodity Markets 2018, page 19.  
JOB/AG/199  
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  Figures  4 and 5: Members with Highest  TDPE  
 
 
 
* Members with US D 10 Billion or more in TDPE. 
Source:  Costa Rica based on information from JOB/AG/190 . 
18.   In an ambitious scenario , where Members would commit  to reduce all entitlement levels to a 
limit of 10% of the VoP, Member E 's TDPE limit would go from 55% to 10% of its VoP, with a 
reduction of 63%. On the other hand, Member D 's TDPE would go from 15% to 10% of  its VoP and 
contribute with a reduction of 33%. Under such scenario, Member E, which concentrates 5% of the 
global TDPE, would contribute comparatively more of its policy space than Member D, even though 
Member D concentrates 6.3% of the global TDPE. Unde r a less ambitious scenario with a 20% VoP 
limit, Members A, D, F, G, J, K, and L would be required to reduce less and if only the so -called 
"Amber Box " entitlements were consider ed some Members would not be required to do anything. 
On the contrary, Members B, E and H would face the highest cuts. In all scenarios, Members E and 
H would be required to reduce their policy space the most in relative terms.  
19.   Solutions based on a percentage of the VoP may worsen the situation by further restrictin g 
available policy space of relatively  smaller  Members. New limits should be monetized and not be 
linked to any variable that could lead to uneven sharp decreases in available policy space or unduly 
target those Members with lower levels of trade -distortin g potential.  
JOB/AG/199  
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  20.   Monetizing and capping current entitlements may appear more restrictive than necessary to 
some Members that are still facing demographic challenges. In JOB/AG/177 the co -sponsors 
proposed a gradual approach to reductions with a 10-year term goal. During this transitional period, 
exogenous variables such as population growth could be explored as adjustment criteria  for the final 
reduction commitment.  
VI.  A Formula Approach to Individual Reductions Consistent with the Principle of 
Proportionalit y 
21.   The principle of proportionality implies that those Members entitled to spend more in trade -
distorting domestic support should contribute more to the reform process. Equivalently, those with 
lower entitlements would contribute with relatively smaller red uctions to their current entitlements. 
In practice, determining whether Members have higher or lower levels of entitlements relative to 
each other, requires the estimation of the relative share of each Member in the global amount of 
current entitlements.  
First Step: Monetizing the Trade-Distorting Potential Expenditure  
22.   Under the current AoA architecture, Members can grant trade -distorting domestic agricultural  
subsidies for an amount  equivalent to 5% of their value of agricultural production under de minimis , 
both to product -specific and non  product -specific subsidies, while for developing Members such 
threshold increases to  10% for each type .5 Also, a group of Members has access to an additional 
fixed amount, known as the Aggregat e Measure of Support beyond de minimis  (hereinafter FBTAMS). 
Limits are determined by the VoP (de minimis ) and the FBTAMS (Part IV of Schedule). Unbound 
support (Article 6.2 and Article 6.5) is unlimited in monetary terms and only subject to Member -
specifi c constraints that are beyond  the current scope of the AoA, such as national budgets.6 As each 
category  is treated differently and proportionality requires a common monetary value, Costa Rica 
developed a simple methodology in RD/AG/76 that successfully estimates and aggregates the trade -
distorting potential expenditure for all 164 WTO Members and that can be found in Annex 1. For the 
purposes of this document, this indicator will serve as the basis for the second step.  
Second Step: Fixing th e Base 
23.   Fixing the estimate obtained in the first step anchors the reform process to current 
entitlements. This prevents the inclusion of any future growth or decline that would lead to 
unintended misalignments between the individual base caps and the sum o f all of them, a situation 
that could in turn distort the results of the formula. This base cap shall be used in the third step.  
Third Step: Applying the Formula  
24.   Members would reduce their base cap  according to their relative participation in the total bas e 
cap as a measure for reductions. The  total base cap being the aggregate of all the base caps 
estimated in the previous steps. For greater certainty, the following formula could be used when 
estimating individual reductions:  
NCi = BC i*(1-Ai), where:  
NCi is the new cap after reductions for Member "i"; 
BCi is the base cap  for Member "i"; 
Ai is the share of Member "i", in the total base cap , so 𝐴𝑖=𝐵𝐶𝑖
∑𝐵𝐶164
𝑖=1 
25.   From  a theoretical perspective, the impact of the one -time application of this formula coul d be 
visualized using a fictitious world comprising  only five WTO Members (see Table 2 below). In this 
scenario , Member A would reduce 30% of its initial base cap as it concentrates 30% of the global 
amount. Proportionality is respected as Member E would r educe 10%, mirroring its share in the total. 
The one -time application of the formula also has an immediate impact in the rebalancing of 
entitlements, as Member A goes from 30% to 27.1% and Member E goes from a relative share of 
10% to 11.6% under the new c ap. 
 
5 Some Members bound a de minimis  of 8.5% for product specific support and a de minimis  of 8.5% for 
non-product specific support.  
6 In order to accomplish this task,  Costa Rica has developed a methodology based on the concept of 
trade -distorting potential that presented in RD/AG/76 and that can be found in Annex 1. JOB/AG/199  
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  Table 2: One-time  Application of the Formula  (in Monetary Units ) 
Member  Base Cap  
(1) Share  
(2) Reduction  New Cap  New share  
Member A  30 30% -30% 21.0 27,1%  
Member B  25 25% -25% 18.8 24,2%  
Member C  20 20% -20% 16.0 20,6%  
Member D  15 15% -15% 12.8 16,5%  
Member E  10 10% -10% 9.0 11,6%  
Total  100 100%  -22.5%  77.5 100,0%  
Source:  Costa Rica.  
Fourth Step: Implementing Progressivity Through an Iterative Approach  
26.   While the formula is consistent with the principles of proportionality and progressivity, it is 
unlikely to  fully achieve the desired global objectives of the reform process with just a one -time 
application. For instance, in JOB/AG/177, co -sponsors are pro posing a global reduction of at least 
50% of the sum of current global agricultural trade - and production -distorting domestic support 
entitlements by 2030 . However, according to Costa Rica 's estimates, a one -time application of the 
formula would fall short  of that goal (see Table 3). An iterative approach where the formula is applied 
several times and recalculated using the new shares and the new total as a basis for the next 
iteration, can effectively address  this issue.  
27.   The iterative approach would also reinforce the redistributive effect on Members ' share in global 
entitlements, narrowing the dispersion of the trade -distorting potential between Members. The 
theoretical example in Figure 6 below, shows that those Members with the highest shares contribute  
more in the early stages  of the process , but also as the iterations continue and their relative shares 
drop, the other Members begin to contribute more as their own relative shares increase. These 
changes in the marginal reductions create a rebalancing ef fect, leveling the playing field between 
Member 's entitlements, both in absolute and relative terms.  
Figure  6: Effect of  Progressivity in the Distribution of Entitlements Among Members - A 
Theoretical Example  
 
Source:  Costa Rica.  
28.   Costa Rica estimates tha t achieving at least a 50% global reduction in the global amount of 
entitlements would require at least eight iterations of the formula (see Table 3). Under this scenario, 
global entitlements would be reduced from US D 905.3 billion to US D 458.4 billion by 2030. This 
would also reduce the TDPE concentration from 80% to 63%. As a negotiation tool, the iterative 
approach can be used to achieve the global reduction objective, but its intermediate results can also 
be consid ered for establishing annual reduction commitments.  
JOB/AG/199  
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  Table 3: Iterative Application of the  Formula  – An Estimate  
 Global base cap  
(Billion US D) Global new Cap  
(Billion US D) Accumulated 
Reduction  
(Billion US D) Reduction (%)  
Starting point  905.3  - - - 
Iteration 1  905.3  786.4  -119.0  -13.1%  
Iteration 2  786.4  703.8  -201.6  -22.3%  
Iteration 3  703.8  641.1  -264.3  -29.2%  
Iteration 4  641.1  591.0  -314.4  -34.7%  
Iteration 5  591.0  549.6  -355.7  -39.3%  
Iteration 6  549.6  514.7  -390.6  -43.1%  
Iteration 7  514.7  484.7  -420.7  -46.5%  
Iteration 8  484.7  458.4  -446.9  -49.4%  
Iteration 9  458.4  435.3  -470.1  -51.9%  
Iteration 10  435.3  414.6  -490.7  -54.2%  
Source:  Costa Rica. Global base cap  estimated using  the methodology described in Annex 1. 
29.   As shown in Figure 7, a 50% reduction in the global amount of entitlements  would lead to a 
narrowing of the "water " of those  Members that have the highest levels of entitlements and that 
concentrate most of the trade -distorting expenditure. Nevertheless, a ll WTO Members would retain 
meaningful policy space for use of domestic support in agriculture . 
Figure  7: Distance Between Global Limits and Notified Support Before and After 
Reductions under the Formula Approach* 
 
* New cap based on results after eight iterations of the formula.  
Source:  Costa Rica based on data from JOB/AG/190 and RD/AG/76.  
 
VII.  Considering Members ' Special Needs  
30.   For Costa Rica, a sustainable negotiation framework requires flexibilities that remain in line 
with the reform objectives and do not jeopardize at all future agreements. Along these lines , any 
flexibility should be designed taking into account the distorti ng potential of each Member and the 
embedded flexibilities already present in the formula approach. Also, over the years, Members have 
explored negotiation tools that could effectively accommodate the Members ' special needs ( such as 
LDC Members ) in the est ablishment of new disciplines and that could be of use in the reform process.  
31.   For example, and in the context of a  monetized approach, additional flexibilities can be explored 
for Members that are facing demographic challenges . The proposal offers a gradua l approach to 
JOB/AG/199  
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  reductions with a 10-year goal that could include an adjustment mechanism for the final cap based 
on exogenous variables such as population growth.  
32.   Costa Rica is of the view that exemptions to the cap and reduction approach could be granted 
to LDC Members given their specific circumstances. For the issue  of graduating Members, a phase -
out mechanism that creates an additional transitional period for further adjustments would allow for 
a single, unified, and coherent regulatory framework for all  WTO Members in the long term.  
VIII.   Final Remarks and the Way Forward  
33.   Costa Rica proposes a global reduction objective through a monetized global cap, with an 
implementation period of 10 years for individual reductions. This approach offers an ambitious and 
balanced way forward in the reform of the domestic support pillar  in agriculture . The formula for 
reductions, along with its embedded proportionality and progressivity, limits the global growth of 
trade -distorting domestic support, while ensuring that Members retain a high degree of flexibility at 
the individual level. Cos ta Rica is also exploring several solutions to address the specific needs and 
sensitivities of all Members, in particular LDC Members . 
34.   On the way forward, Costa Rica considers that the principles, objectives, and suggested 
modalities as presented in this p roposal should be the basis for negotiations in the domestic support 
pillar. Achieving more robust rules in the domestic support pillar would be an important contribution 
to addressing global inequality, providing sustainable economic development opportuni ties, 
addressing overall global food security needs and building an inclusive and effective global trading 
system . Therefore,  Costa Rica cordially and respectfully invites  all Members to work together towards 
these goals  based on this proposal . 
 
__________ _____  
 JOB/AG/199  
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  ANNEX 1  
METHODOLOGICAL NOTES ON THE ESTIMATION OF THE TRADE -DISTORTING  
POTENTIAL EXPENDITURE (TDPE) OF EACH WTO MEMBER  
• A Member's trade -distorting potential  expenditure  is computed as the sum of:  
i) Twice the Member's de minimis  percentage1 of its average value of total agricultural 
production for the last three years available.  
ii) Final Bound Total AMS as specified in Part IV of the Member's Schedule.  
iii) The highest level of support given during the most recent three consecutive years 
notified u nder Article 6.2 of the Agreement on Agriculture.  
iv) The highest level of support given during the most recent three consecutive years 
notified under Article 6.5 of the Agreement on Agriculture.  
• Data was taken from FAOSTAT; the "Analytical tool for domestic s upport negotiations" 
(hereinafter " the Analytical tool" , circulated in February 2019 and updated in JOB/AG/190) and 
the information provided in " an estimate of domestic support entitlements in Articles 6.3 and 
6.4 of the Agreement on Agriculture for all WT O Members" (RD/AG/74) both prepared by 
Canada. Some information was adjusted following comments by WTO Members.  
• It includes an estimate of the value of total agricultural production and the Final Bound Total 
AMS (FBTAMS) for all 164 WTO Members.  
• Informatio n on expenditure provided under Article 6.2 and Article 6.5 was extracted from the 
Analytical tool and includes data from all Members who have submitted a DS:1 notification 
between 2001 and November 2020.  
• Data limitations are consistent with those under th e Analytical tool : not all Members have 
submitted recent domestic support notifications; many modifications were made to correct data 
entry errors and given the large amount of data points, aggregated levels should be considered 
preliminary and subject to further review. Also, estimates are sensitive to exchange rates.  
• Given the wide array of time periods used for each component of the TDPE indicator, the 
estimate may not provide a picture for a specific moment in time.   
 
__________  
 
1 I.e. the de minimis percentage for product -specific domestic support (pursuant to paragraph 4(a)(i) of 
Article 6 of AoA), and the de minimis percentage for non -product -specific domestic support (pursuant to 
paragraph 4(a)(ii) of Article 6 of AoA).  De minimis  percentages were estimated according to Paragraph 4(b) 
and specific Accession Protocols when relevant.