G/TBT/W/798/Rev.1  
 
28 March 2024  
(24-2756) 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  
Revision  
The following submission, dated 27 March  2024, is being circulated at the request of the delegation 
of the European Union . 
 
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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 fo r 
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 that their off icials 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/Rev.1  
 
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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 mechanism to either  share or to inform 
other Members of the availability of such translation.2 It is therefore important to enhance 
cooperation between Members through sharing reliable translations of measures into the official 
WTO languages between the Members.  
1.7.  Given that machine translations may contain important errors which could lead to 
misinterpretations of the notified measures, it is important to correctly identify such translations as 
being machine generated.  
1.8.  Technical regulations and conformity assessment procedure s are complex and often cover 
technical issues. Correct translation is key in allowing 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 tex t 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 yet tangible results of the exploration of the use of available IT tools, such 
as translation software, in order to prov ide unofficial reliable translations of notified 
documents into the three official WTO languages through TBT online tools;  
• 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 fol lowing steps to increase the transparency and 
to reinforce the cooperation on sharing of verified translations:  
a. to ask the Secretariat to continue exploring the use of IT tools in order to provide unofficial 
reliable translations of notified documents, and  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 the measures they 
notify into one of the WTO's official l anguages, 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 measure s of common interest, or in verifying the reliability of machine 
translations, by pooling resources and avoiding the duplication of work.  
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2 The ePing  "outreach" module is already used by some Members to upload translations. However, the 
ePing platform is not systematically used and the quality of translations could benefit from potential synergies 
between both traditional and new AI tool, to facilitate  the assessment of notified measures for the preparation 
of official 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.