RESTRICTED  
  
WT/ACC/COM/23/Rev. 3 
18 June 2021 
(21-5006) 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 17 June 2021, is being circulated at the request of the 
delegation of the Union of the Comoros . 
 
 
_______________  
 
  
 
1 Please note that the Comoros undertakes to complete t he 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 time -frame.  WT/ACC/COM/23/Rev. 3 
- 2 - 
  TABLE OF CONTENTS  
1. SPS-RELATED MEASURES  ................................ ................................ ............................  3 
2. TRIPS -RELATED MEASURES  ................................ ................................ ........................  8 
3. CUSTOMS FORMALITIES  ................................ ................................ .............................  9 
(a) Measures related to the Customs Valuation Agreement  ................................ ............  9 
(b) Fees and charges  ................................ ................................ ................................ ..... 10 
(c) Trade facilitation ................................ ................................ ................................ ...... 11 
4. TBT-RELATED MEASURES  ................................ ................................ ..........................  12 
5. MEASURES RELATED TO THE FOREIGN TRADE REGIME  ................................ ............  13   
  WT/ACC/COM/23/Rev. 3 
- 3 - 
 
1. SPS-RELATED MEASURES  
 A. Measures during the accession process  
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  1. June 2020 
2. 2020-2022 
Establishment of the National Pla nt Protection 
Organization (NPPO ) in accordance with IPPC 
requirements  Establishment of an office and appointment of the officials in charge  December  2021 
Establishment of technical libraries, for example,  a CODEX 
library  Establishment of a CODEX library  First half of  2021 
Establishment of a reference laboratory  1. Purchase of necessary testing equipment  
2. Establishment of laboratory  1. December  2021 
2. December  2022 
B.  Measures after accession  
Description  Action to be taken  Time -frame  
Establish ment 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    2020-2024 
 
 
 
 
 
 
 
 
Promo tion 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 
implement ing the SPS system  
2. Encourage all actors to take ownership of the regulations  
3. Support the entities involved in implement ing the SPS system as part 
of drafting  and implement ing a programme of action  
4. Define and put in place the consulta tion framework for all entities 
involved in implementing the SPS system  
5. Define the roles and responsibilities  of the stakeholders involved in 
implemen ting the SPS system to enhance co -management by further 
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. Promo te the use of legi slative, 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 : 2021/2024  
    
  WT/ACC/COM/23/Rev. 3 
- 4 - 
 
 B. Measures after accession  
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. Identif y 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 m anagement 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 S PS 
system and measures  
13. Study the possibility of involving farming, livestock farming and 
fishing communities in the implementation of the SPS system    
 
 
 
 
 
 
 
 
1-13 : 2020/2024  
 
 
 
 
 
   
  WT/ACC/COM/23/Rev. 3 
- 5 - 
 
 B. Measures after accession  
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 r oles and responsibilities of each key player in collecting 
information  
4. Promo te participatory research in the implementation of SPS 
measures  
5. Define  and implement effective information -sharing procedures and 
strengthen communication among all stakeholders i n the 
implementation of SPS measures  
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  appro priate 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: 2021/2024    
  WT/ACC/COM/23/Rev. 3 
- 6 - 
 
 B. Measures after accession  
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 system  
3. Restructure  and streaml ine 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 development and implementation of  a 
programme of activities  
6. Create a network of bodies at the island and national level s, and 
participate in existing SPS system networks at the regional and 
international level s  
7. Provide operational support to SPS system bodies  and mobilize 
programmes and projects to support the establishment and operation 
of those entities  
8. Organi ze an awareness -raising campaign for greater participation and 
representation of professionals and users in the implementation of the 
SPS system (poli cy, strategy, action plans, etc. at the local and 
national level s)  
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 of 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 oversee ing SPS measures  
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 thei r right to adequate service and able to 
demand it  
13. Disseminate regularly SPS -related laws and regulations in force   
 
 
 
 
 
 
 
 
 
 
 
 
1-13: 2020/2024    
  WT/ACC/COM/23/Rev. 3 
- 7 - 
 
 B. Measures after accession  
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. Organi ze a regular meeting to validate and/or revise the capacity -
building strategy of SPS system stakeholders  
2. Organi ze an annual meeting to take stock of implementation of the 
capacity -building strategy for stakeholders in the SPS system and 
identify possibili ties 
3. Organi ze 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: 2021/2024  
 
 
 
 
Implement the necessary accompanying measures  1. Develop and adopt the necessary regula tory 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 institutio ns, including the University of the 
Comoros  
5. Undertake studies on the marketing channels of processed products   
 
 
 
1-5 :2020/2024  
    
  WT/ACC/COM/23/Rev. 3 
- 8 - 
 
2. TRIPS -RELATED MEASURES  
A.  Measures during the accession process  
Description  Action  to be taken  Time -frame  
Law on ratification of the 
2015 Bangui Agreement  Effective implementation  2020-2022 
Capacity building  Training of personnel, including customs officials, police officers, and officials responsible for 
protecting registered trademarks  Beginning  2015-2021 
Creation of a registered trademarks database  2021 
Computerization of the Comorian Intellectual Property Office  (OCPI) Second  quarter  of 2021 
    
  WT/ACC/COM/23/Rev. 3 
- 9 - 
 
3. CUSTOMS FORMALITIES  
(a) Measures related  to the Customs Valuation Agreement  
 A. Measures during the accession process  
Description  Action to be taken  Time -frame  
Adoption of implementing texts 
for the new 2015 Customs Code  1. Signing of implementing texts for the 2015 Code providing for the use of the transaction 
value  1. Second quarter of 2021  
 
 
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/targeted 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: 2019/2022  
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  As of 2020  
 
    
  WT/ACC/COM/23/Rev. 3 
- 10 - 
 
(b) Fees and charges  
 A. Measures during the accession process  
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 RCI and the RCCI in the 20 20 Finance Law  
2. Provision to be made for the e limination of the AI in the 2022 Finance Law  
 1. October  2021 
2. October  2022 
 
 
 
 
 
Establishment of the VAT regime  1. Creation of a Directorate for Large Corporations  by the General Tax and Property Administration 
(AGID)  
2. Impact study on the implementation of VAT  
3. Consultations with large enterprises  
4. Communication campaign  
5. Preparation of a draft law in this respect, to be validated  at a national workshop  
6. Training of  accountants  
7. Creation of a control body  
8. Adoption of draft law by Parliament, and enactment  2020-2022 
 B. Measures after accession  
 
Description  Action to be taken  Time -frame  
Elimination of the PI at the customs  cordon  Provision to be made for the elimination of the PI in the 2023 Finance Law  October  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 Law   October 2024 
 
    
  WT/ACC/COM/23/Rev. 3 
- 11 - 
 
(c) Trade facilitation  
 A. Measures during the accession process  
Subject  Action  to be taken  Timetable  
Publication  Publication, as expeditiously as possible, of trade -related information in a manner that is non -discriminatory and easily 
accessible to the public  2021 
Information available on the 
Internet  Making information available on ITC media, particularly the Internet, in order to improve access 24 hours a day and 365  days 
a year at a low operating cost  2021 
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  2022 
Consultations  Provide for regular consultations between border agencies and traders or other stakeholders locate d within its territory 
(Article  2.2) 2021 
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 o perations and reducing and simplifying 
requirements (Article 10.1)  2021 
Appeal or review  Establish a legal system of administrative or judicial appeal or review so that any person subject to an administrative decis ion 
is entitled to a revision and correct ion, on an impartial and independent basis, with regard to decisions handed down by the 
customs authority (Article 4)  2021 
Processing before arrival  Adopt or maintain a mechanism enabling the trader to submit important documentation prior to the arrival o f goods 
(Article  7.1) 2022 
Electronic payment  Establishment of a mechanism allowing traders the option of electronic payment for duties, taxes, fees and charges 
(Article  7.2) 2021 
Authorized operator  Create a fair system that rewards respect for the rules and establish additional trade facilitation measures for selected 
operators (Article  7.7) 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)  2021 
 B. Measures after accession  
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  2023 
Penalties  Ensure that 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 
establis hing them  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) 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 an d 
charges (Article 7.3)  2023 
 
    
  WT/ACC/COM/23/Rev. 3 
- 12 - 
 
4. TBT-RELATED MEASURES  
 A. Measures during the accession process  
Desc ription  Action  to be taken  Timetable  
Introduction of the National Quality Policy (PNQ)  Entry into force  2021 
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  2021 
 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. 3 
- 13 - 
 
5. MEASURES RELATED TO THE FOREIGN TRADE REGIME  
 A. Measures during the accession process  
Description  Action  to be taken  Timetable  
Introduce a law on foreign trade consistent 
with the provisions of the WTO Agreements  1. Preparation of the law  
2. Circulation of  the law to all national stakeholders  
3. Technical v alidation of  the law at a national workshop  
4. Submission to Council of Ministers  
5. Adoption by Parliament  
6. Enactment of the law  
7. Preparation of implementing texts  
8. Training of personnel and organization of services concerned  
9. Implementation of the law by the relevant services  
10. Notification of the law and its implementing texts to the WTO  2018-2023 
 
__________