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INFORMAL WORKING GRO UP ON MSMES  
TRADE FACILITATION A GREEMENT PROVISIONS,  MSMES' PAIN POINTS,  
RECOMMENDATIONS AND GOOD PRACTICES  
The following document has been prepared by the WTO Secretariat at the request of the delegation 
of Uruguay, coordinator of the Informal Working Group on MSMEs to provide a brief overview of the 
provisions and implementation of the WTO Trade Facilitation Agreement from MSMEs' perspective . 
It does not represent the official position of the WTO, nor of the  WTO secretariat.  
 
_______________  
 
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TRADE FACILITATION A GREEMENT PROVISIONS,  MSMES' PAIN POINTS,  RECOMMENDATIONS AND  GOOD PRACTICES  
TFA provisions  TFA measures  MSME pain points  Relevant recommendations from 
external studies or presentations to 
MSME IWG1 Good national/regional  
practices2 
INFORMATION AVAILABILITY  
Article 1.1 : Publication  
• §1.1 Each Member shall promptly 
publish the following information in a 
non-discriminatory and easily 
accessible manner  in order to enable 
governments, traders, and other 
interested parties to become 
acquainted with them (…)  
 
 
Article 1.2 : Information Available 
Through Internet  
• §2.1 Each Member shall make 
available, and update to the extent 
possible and as appropriate , the 
following through the internet (…) 
• §2.2 Whenever practicable, the 
description referred to in subparagraph 
2.1(a) shall also be made available in 
one of the official languages of the WTO  
 Publication and 
Availabil ity of 
Information  MSMEs often have difficulties in 
understanding official information 
because of delays, non -updates, 
incomplete context and/or complex legal 
language . MSMEs also tend to be more 
affected by sudden changes to rules and 
regulations than large enterprises . 
Further, some MSMEs have insufficient 
access to information because they lack 
the time and/or resources to conduct the 
necessary research. (ITC, 2018 – 
referred as "ITC toolkit" below)3 
 
Online information platforms have  been 
shown to provide significant savings for 
MSME  traders by improving information 
search and reducing regulatory 
compliance costs. (Ganne and 
Lundquist, 2019)4 ITC toolkit:  
• Create a government knowledge 
management policy at the national level.  
• Use ITC t ools to communicate changes to 
rules and regulations.  
• Develop user friendly and 
experience -based information platform for 
MSMEs.  
• Establish requests for information and 
responses service for MSME s as part of 
organizational  performance -measurement 
parameters . 
• Provide channels that address the needs of 
business generally and MSME s specifically.  
 
OECD 2004 Istanbul Ministerial Declaration 
on Fostering the Growth of Innovative and 
Internationally Competitive MSME s5:  
• Promoting access to and use of quality 
information and communication 
infrastructure and promoting enhanced 
security and trust in the digital economy.  
 1) Global Trade Helpdesk  
• A joint ITC -UNCTAD -WTO initiative 
that aims to improve the quality, 
transparency and accessibility of 
trade-related information by 
providing a unique entry point to 
existing trade -related information 
with specific ally target for MSME s. 
• The platform integrates 
comprehensive information from 
various sources on market 
requirements, including customs 
tariffs, taxes, rules of origin, 
non-tariff measures, and 
notifications of WTO Members ; 
export/import procedures, 
busine ss opportunities and policy 
outlook. ( June 2019 meeting)6 
 
2) EU Trade Helpdesk  
• An online platform that provides 
information on how to export to  
                                                
1 These references include MSME -related studies from international organizations, as well as previous presentations from Members or guest speakers to the WTO  Informal Working 
Group on MSMEs.  
2 These examples are taken from relevant external studies (see col umn 4) or were discussed at meetings and workshops organized by the WTO Informal Working Group on MSMEs.  
3 International Trade Centre (2018), Supporting SMEs through  trade facilitation reforms: Toolkit for policymakers. ITC, Geneva. See: http://www.intracen.org/publication/supporting -
SMEs -through -trade-facilitation -reforms/ . 
4 Ganne, E. and Lundquist, K. (2019), "The digital economy, GVCs and SMEs", Global Value Chain Development Report (2019), Chapt er 6. See: 
https://www.wto.org/english/re s_e/booksp_e/gvc_dev_report_2019_e_ch6.pdf . 
5 OECD, Istanbul Ministerial Declaration on Fostering the Growth of Innovative and Internationally Competitive SMEs, OECD/LEGAL /0328. See: 
https://legalinstruments.oecd.org/public/doc/155/155.en.pdf . 
6 https://www.wto.org/english/tratop_e/msmes_e/global_trade_helpdesk_presentation.pdf .   INF/MSME/W/8  
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TFA provisions  TFA measures  MSME pain points  Relevant recommendations from 
external studies or presentations to 
MSME IWG1 Good national/regional  
practices2 
  The UK Federation of Small Businesses 
(FSB) also stressed the importance of 
making information accessible to 
MSMEs, and recommended policy 
makers to reduce the administrative 
burden and improve customs capacity 
for MSME s. (Oct. 2017 workshop)7  
the EU, inc luding EU import duties, 
product requirements, rules of  
origin, internal taxes and trade 
statistics.  
• It also includes a database on trade 
in goods, the usage is free of charge 
and it is available in English, 
French, Spanish and Portuguese. 
(Oct. 2017 workshop)8 
 
3) Switzerland Online Customs 
Database  
• A foreign trade portal for 
country -specific information  on 
tariff and non -tariff trade 
measures, including import 
formalities of over 100 countries. 
(Oct. 2017 workshop)9 
 
4) Russia "one -stop shop" service for 
MSMEs  
• Provides easy access for all ; 
includes both paid and free 
services ; provides both financial 
and non -financial services ; has a 
call-centre and other related 
support available to users. 
(June 2018 meeting)10 
 
                                                
7 https://www.wto.org/english/tratop_e/msmes_e/fsb_presentation.pdf . 
8 https://www.wto.org/english/forums_e/business_e/session4_1paolo_garzotti_eu_presentation.pdf . 
9 https://www.wto.org/english/forums_e/business_e/session4_4silini_s_ge.pdf . 
10 https://www.wto.org/english/tratop_e/msmes_e/2018_06_08_rus_presentation_support_of_msmes.pdf .   INF/MSME/W/8  
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TFA provisions  TFA measures  MSME pain points  Relevant recommendations from 
external studies or presentations to 
MSME IWG1 Good national/regional  
practices2 
Article 1.3: Enquiry points  
• §3.1 Each Member shall, within its 
available resources, establish or 
maintain one or more enquiry points to 
answer reasonable enquiries of   
governments, traders, and other 
interested parties  on matters covered 
by paragraph 1.1 and to provide the  
required forms and documents  referred 
to in subparagraph  1.1(a).  
• §3.2 Members of a customs union or 
involved in regional integration may 
establish or maintain common enquiry 
points at the regional level to satisfy 
the requirement of paragraph 3.1 for 
comm on procedures.  
• §3.3 Members are encouraged not to 
require the payment of a fee for 
answering enquiries and providing 
required forms and documents . If any, 
Members shall limit the amount of their 
fees and charges to the approximate 
cost of services rendered . 
• §3.4 The enquiry points shall answer 
enquiries and provide the forms and 
documents within a reasonable time 
period  set by each Member, which may 
vary depending on the nature or 
complexity of the request.  
 Enquiry Points  Enquiry points improve small 
busin esses' compliance level by 
providing the paperwork they need to 
trade which helps them more than large 
enterprises. (WTO, 2016)11 
 
This further improves compliance by 
addressing concerns and increasing 
MSME understanding before 
transactions occur. (UNCTAD, 2011)12 ITC toolkit:  
• Choose the appropriate model for enquiry 
points, preferably a single national enquiry 
point to which businesses could direct all 
trade inquiries.  
• Provide channels that address the needs of 
business generally and MSME s specifically.  
 
World Customs Organization Revised Kyoto 
Convention guidelines13: 
• This TFA requirement is closely tied to the 
concept of 'helpdesks' as recommended by 
the WCO in its RKC guidelines. These 
guidelines include detailed information on 
setting up helpdesks and require customs 
units to provide detailed information or 
make decisions quickly.  [N/A]  
Article 10.4: Single Window  
• §4.1 Members shall endeavour to 
establish or maintain a single window, 
enabling traders to submit 
documentation and /or data 
requirements for importation,  Single Window  Studies showed that reform of slow or 
cumbersome border procedures can cut 
costs of trading by 12% -18%, 
depending on a country's development 
level, and domestic whole -of 
government approaches could grea tly  
 ITC toolkit:  
• Consult MSME s and address their needs 
when designing single window.  
• Prioritize solutions for problems MSME s 
face in the existing system.  
 1) Singapore National Trade Platform 
(NTP)  
• A one -stop trade information 
management system that enables 
electronic data sharing among 
businesses and government.  
 
                                                
11 World Trade Organization (2016), World Trade Report 2016 – Levelling the trading field for SMEs. See: https://www.wto.org/english/res_e/booksp_e/world_trade_report16_e.pdf . 
12 United Nations Conference on Trade and Development (2011), Technical Notes on Trade Facilitation Measures, Geneva: United Nat ions. 
13 World Customs Organization (December 2010), Revised Kyoto Convention, General Annex, Guidelines.    INF/MSME/W/8  
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exportation, or transit of goods through 
a single entry point  to the participating 
authorities or agencies. After the 
examination by the participating 
authorities or agencies of the 
documentation and/or data, the results 
shall be notified to the applicants 
through the single window in a timely 
manner . 
• §4.2 In cases where documentation 
and/or data requirements have already  
been received through the single 
window, the same documentation 
and/or data requirements shall not be 
requested by participating authorities 
or agencies except in urgent 
circumstances and other limited 
exceptions which are made public.  
• §4.3 Members shall notify the 
Committee of the details of operation of 
the single window.  
• §4.4 Members shall, to the extent 
possible and practicable, use 
information technology to support the 
single window .  
help MSMEs to participate international 
trade. (OECD, 2019)14 
 
In practical terms, MSME s have specific 
concerns and are disadvantaged when 
dealing with border processes, and 
single windows can ease MSME s' burden 
if the platforms transform traditional 
administrative systems into a coherent 
and coordinated arrangement with 
prioritized address of MSME s' pain 
points and challenges. (ITC toolkit)  
 
Single windows that are not developed 
with automated decision -making and 
integrated risk management mean that 
approval process is convoluted and 
submitted documents can be 
unnecessarily delayed. Complexity of 
design can prevent MSMEs from finding 
necessary information or submitting all 
required documentation. (ITC toolkit)  The International Federation of Freight 
Forwarders Associations (FIATA) 
presentation15: 
• Advise member states on the creation of 
Single Windows that would ensure reduced 
costs and facilitated clearance which could 
increase the likelihood of MSMEs to trade.  
• Encourage states to implement Single 
Window solutions promoting filing systems 
that minimise th e frequency of data 
transfers, thus creating a large, transparent 
and secure eCommerce community. (FIATA 
presentation, June  2018 workshop – refer 
as "FIATA presentation" below)  • Firms only have to provide trade 
information once and to authorize 
its use by l ogistics providers, 
business partners, customs and 
other trade regulatory approvals, 
which will be especially helpful for 
MSME s to cut costs and streamline 
processes. (Oct. 2017 workshop)  
 
Some single window initiatives go 
beyond B2G and include a number o f 
B2B services, such as:  
 
2) Morocco's PORNET IT system  
• Facilitate collaboration between 
agencies such as between Poste 
Maroc and Morocco's customs 
authority which helps to ensure 
MSMEs comply with trade 
regulations.  
• Relevant agencies should be made 
stakeh olders in the initiative to 
incentivize involvement.  
• A Single Window should seek to 
streamline processes through 
consolidation of trade events, such 
as sequential inspections and 
paperwork or necessary fee 
payments. (June  2019 workshop)16 
 
3) Integrated Ser vices for MSMEs in 
International Trade (ISMIT)17 
• An integrated, end -to-end 
e-commerce trade services 
platform for MSMEs advocated  by 
UN/CEFACT.  
 
                                                
14 OECD (2019), Strengthening SMEs and Entrepreneurship for Productivity and Inclusive Growth: OECD 2018 Ministerial Conference on SMEs, OECD Studies on SMEs a nd 
Entrepreneurship, OECD Publishing, Paris. See: https://www.oecd -ilibrary.org/docserver/c19b6f97 -
en.pdf?expires=1569336511&id=id&accname=ocid195767&checksum=E8F851E9E22657A0E38FBAC374844FC7 . 
15 https://www.wto.org/english/tratop_e/msmes_e/kersten_importance_of_facilitated_trade_for_msmes_growth_msme_june_27th_presentaito n_fiata.pdf . 
16 https://www.wto.org/english/tr atop_e/msmes_e/portnet_presentation.pdf . 
17 http://www.unece.org/fileadmin/DAM/cefact/cf_forums/2018_China/eCommerce_Bio -PPT/PPT_05_CramMa rtos.pdf .   INF/MSME/W/8  
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    • Trade -related information can 
either be coordinated through 
connectivity to a National Single 
Window or directly to customs for 
export and import declarations and 
to other relevant government 
websites.  
Article 2.1: Opportunity to Comment and 
Information before Entry into Force  
• §1.1 Each Member shall, to the extent 
practicable and in a manner consistent 
with its domestic law and legal system, 
provide opportunities and an 
appropriate time period to traders and 
other interested parties to comment  on 
the proposed introduction or 
amendmen t of laws and regulations of 
general application related to the 
movement, release, and clearance of 
goods, including goods in transit.   Consultation and 
Business 
Participation  
 Regulatory changes and cumbersome 
administrative procedures can be major 
hurdle s for MSMEs. However, they are 
typically not consulted concerning the 
potential impact of proposed regulation 
and the current inefficiencies of existing 
requirements. Further, when they are 
given the opportunity, MSMEs may lack 
the capacity to articulate t heir views 
about regulatory changes. (ITC toolkit)  ITC toolkit:  
• Ensure adequate MSME representation in 
national trade facilitation 
committees/consultative processes.  
• Take MSMEs needs and concerns into 
account when major 
amendments/information dissemination 
plans are developed.  
• Provide schedules and agendas of 
stakeholder discussions so MSMEs can 
share their viewpoints.  
• Conduct regular studies to capture MSME 
concerns.   1) Canada "Think small" principle  
• Requires consultati on with MSME s 
and analysis of potential impacts. 
(Feb 2019 IWG meeting)18 
2) EU "Think small first " principle and 
MSME  test 
• The regulatory initiative targets to 
take the interests of MSME s into 
account when designing and 
evaluating polices; provide lighter 
regimes for MSME s and exemptions 
for micro -businesses to be 
envisaged; and develop Single 
Digital Gateway platforms.  
Article 2.2: Consultations  
• Each Member shall, as appropriate, 
provide for regular consultations 
between its border agencies and 
traders or other stakeholders located 
within its territory.  
   2018 OECD Declaration  on Strengthening 
MSME s and Entrepreneurship for Productivity 
and Inclusive Growth19: 
• Continuing multi -stakeholder dialogue on 
effective policies to support development, 
growth and competitiveness of MSME s in a 
global and digitalised economy.  
 • Since 2009, the MSME  test 
mandates stakeholders' 
consultation and an impact 
assessment analysis that should be 
proportionate to the expected 
impact on MSME s. (June  2019 IWG 
meeting)20 
 
                                                
18 https://www.wto.org/english/tratop_e/msmes_e/2018_06_08_rus_presentation_support_of_msmes.pdf . 
19 OECD, Declaration on Strengthening SM Es and Entrepreneurship for Productivity and Inclusive Growth. See: https://www.oecd.org/cfe/smes/ministerial/SME -Ministerial -Declaration -
ENG.pdf . 
20 https://www.wto.org/english/tratop_e/msmes_e/european_commission_think_small_first_presentation.pdf .   INF/MSME/W/8  
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2016 APEC MSME  Ministerial Statement21: 
• We would also like to express our 
appreciation for the participation of 
representatives from the private sector, 
academia and international organizations. 
Their views and contribution helped in our 
understanding of existing opportunities and 
challenges MSMEs need to address so that 
they can successfully integrate into the 
global economy.  
 3) Russia Regulatory Impact 
Assessment  
• Requires regulators to complete a 
consolidated report in which an 
MSME  test is integrated; a standard 
cost calculator is also develo ped to 
measure the information and 
substantial costs to MSME s when a 
new policy is designed. (June  2019 
IWG meeting)22 
 
Article 23.2: National Committee on 
Trade Facilitation  
• Each Member shall establish and/or 
maintain a national committee on trade 
facilitation or designate an existing 
mechanism to facilitate both domestic 
coordination and implementation of 
the provisions  of this Agreement.  
 National Trade 
Facilitation 
Committee  MSME s are often less well -coordinated 
and usually have the smallest voic e 
when it comes to advocating for 
favourable laws and regulations. Ideally, 
MSME s should be well represented on 
National Committees on Trade 
Facilitation. (FIATA presentation)23 ITC toolkit:  
• Ensure adequate MSME  representation in 
national trade facilitation 
committees/consultative processes.  
• Take MSME s' needs and concerns into 
account when major 
amendments/information dissemination 
plans are developed.  
• Provide schedules and agendas of 
stakeholder discussions so MSMEs can 
share their viewpoints.  
• Conduct regular studies to capture MSME  
concerns.  
 
FIATA presentation:  
• Policies should be crafted to ensure that 
MSME  associations are appropriately 
organized, informed [or educated] and 
represented and able to participate in public 
fora for customs issues.  
 [N/A]  
                                                
21 APEC, 2016 APEC SME Ministerial Stateme nt: "SMEs as engines of quality growth and prosperity”. See: https://www.apec.org/Meeting -Papers/Sectoral -Ministerial -Meetings/Small -
and-Medium -Enterprise/2016_sme.aspx . 
22 https://www.wto.org/english/tratop_e/msmes_e/russia_regulatory_impact_assessment_presentation.pdf . 
23 https://www.wto.org/english/tratop_e/msmes_e/kersten_importance_of_facilitated_trade_for_msmes_growth _msme_june_27th_presentaiton_fiata.pdf .   INF/MSME/W/8  
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CUSTOMS COMPLIANCES  
Article 3: Advance Rulings  
• §1 Each Member shall issue an advance 
ruling in a reasonable, time -bound 
manner to the applicant that has 
submitted a written request containing 
all necessary information . If a Member 
declines to issue an advance ruling, it 
shall promptly notify the applicant in 
writing, setting out the relevant facts 
and the basis for its decision.  
• §9(d) A Member may require that the 
applicant have legal representation or 
registration in its territory. To the 
extent possible, such requirements 
shall not restrict the categories of 
persons eligible to apply for advance 
rulings, with particular consideration 
for the specific needs of small and 
medium -sized enterprises. These 
requirements shall be clear and 
transparent and not constitute a means 
of arbitrary or unjustifiable 
discrimination.  
 Advanced Rulings  MSMEs are more sen sitive to changes in 
fees and trade costs than larger 
businesses. According to an OECD 
study, advance ruling s would help small 
businesses to increase regulatory 
predictability, eliminate inconsistent 
classification and origin decisions on the 
borders, whic h helps to create a more 
enabling trading environment for 
MSME s. (Moïsé et al., 2011 )24 ITC toolkit:  
• The procedures to file applications for 
rulings, and the supporting information, 
should not be so costly and cumbersome 
that MSME s cannot complete them.  
• Making past rulings available would enable 
MSME s to search information or ask service 
desks or enquiry points before they prepare 
a new request.  
• Provide well -organized, easily searchable 
and understandable information without 
request.  
• Respond to ruling requests efficiently using 
good knowledge management practices.  1) EU public rulings database on 
"Binding Tariff Information" (BTI)  
• An online platform that allows 
traders to obtain a decision on BTI 
issued by national customs 
authorities so to have legal 
certainty about the correct 
classification of their goods. (ITC 
toolkit)  
Article 4: Procedures fo r Appeal or 
Review  
• §3 Each Member shall ensure that its  
procedures for appeal or review are 
carried out in a non -discriminatory 
manner . 
• §5 Each Member shall ensure that the 
person referred to in paragraph  1 is 
provided with the reasons for the 
administrative decision so as to enable 
such a person to have recourse to 
procedures for appeal or review where 
necessary.  
• §6 Each Member is encoura ged to make 
the provisions of this Article applicable 
to an administrative decision issued by Customs Disputes 
and Penalties  MSME s and other businesses are usually 
affected during the clearance process by 
the lack of a redressal mechanism to 
deal with delays in decisions and by the 
range of securities, across different 
client categories, demanded in case of 
disputes.  
 
MSME s are more likely to be required to 
pay in cash or provide bank guarantees 
instead of simple undertakings.  
 
Also, MSME s are very sensitive to fees, 
charges and penalties, and the cost of 
trading and payment processes could be 
burdensome to them. (ITC toolkit)  ITC toolkit:  
• Apply objective and efficient administrative 
review procedures.  
• Ensur e fair, easy and transparent 
procedures for requesting appointments 
hearings.  
• Set time limits to process transactions and 
resolve disputes. Measure performance 
from this perspective and publish results to 
build public trust and set reasonable 
expectations.  
• Improve the transparency and quality of 
decisions at the operational level.  
• Provide mechanisms that enable traders to 
escalate such occurrences to senior 
management.  [N/A]  
                                                
24 Moïsé, E., T. Orliac and P. Minor (2011), "Trade Facilitation Indicators: The Impact on Trade Costs", OECD Trade Policy Paper s, No. 118, OECD Publishing, Paris. See: 
https://www.oecd -ilibrary.org/docserver/5kg6nk654hmr -en.pdf?expires=1569837135&id=id&accname=guest&checksum=73594811A13698D2C2507C2DF7E8BC08 .   INF/MSME/W/8  
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a relevant border agency other than 
customs.  
Article 6.2: Special disciplines on Fees 
and Charges for Customs Processing 
Imposed on or in Connection with 
Importat ion and Exportation  
• Fees and charges for customs 
processing: (i) shall be limited in 
amount to the approximate cost of the 
services rendered  on or in connection 
with the specific import or export 
operation in question; and (ii) are not 
required to be linke d to a specific 
import or export operation provided 
they are levied for services that are 
closely connected to the customs 
processing of goods.  
 • Provide simplified and streamlined fees and 
charges with simple and facilita tive 
clearance and payment processes for 
MSME s. 
Article 6: Disciplines on Fees and Charges 
Imposed on or in connection with 
Importation and Exportation  
• §1.2 Information on fees and charges 
shall be published in accordance with 
Article 1. This information shall include 
the fees and charges that will be 
applied, the reason for such fees and 
charges, the responsible authority and 
when and how payment is to b e made . 
• §1.3 An adequate time period  shall be 
accorded between the publication of 
new or amended fees and charges and 
their entry into force, except in urgent 
circumstances. Such fees and charges 
shall not be applied until information on 
them has been published . 
• §1.4 Each Member shall periodi cally 
review its fees and charges with a view 
to reducing their number and diversity, 
where practicable . 
 Discipline on Fees 
and Charges  Fees and charges are a burden for 
MSME s and other businesses. While 
some of them are inevitable, MSME s 
would benefit fr om simplified, 
streamlined fees and charges. (ITC 
toolkit)  ITC toolkit:  
• Review payment processes.  
• Justify the level of fees and charges.  
• Ensure that information about payments is 
clear and complete.  
• Notify business in advance about changes.  
 [N/A]    INF/MSME/W/8  
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Article 10.6: Use of Customs Brokers  
• §6.1 Without prejudice to the important 
policy concerns of some Members that 
currently maintain a special role for 
customs brokers, from the entry into 
force of this Agreement Members shall 
not introduce the mandatory u se of 
customs brokers . 
 Use of Customs 
Brokers  Many MSME s have to engage a broker 
because of complex border procedures. 
MSME s may opt to save money on 
brokerage fees and handle the 
transaction directly with customs. (ITC 
toolkit)  
 ITC toolkit:  
• Develop ICT -based processes where 
traders have direct online access to the 
customs system.  
• Provide self -filing options through a simple 
and standard procedure.  
• Develop a simple process and user -centric 
design.  [N/A]  
RISK MANAGEMENT  
Article 7.4: Risk Management  
• §4.2 Each Member shall design and 
apply risk management in a manner as 
to avoid arbitrary or unjustifiable 
discrimination, or a disguised 
restriction on international trade . 
• §4.3 Each Member shall concentrate 
customs control and, to the extent 
possible other relevant border controls, 
on high -risk consignments and 
expedite the release of low -risk 
consignments . A Member also may 
select, on a random basis, 
consignments for such controls as part 
of its risk management.  
• §4.4 Each Member shall base ris k 
management on an assessment of risk 
through appropriate selectivity criteria . 
Such selectivity criteria may include, 
inter alia, the Harmonized System 
code, nature and description of the 
goods, country of origin, country from 
which the goods were shipped , value of 
the goods, compliance record of 
traders , and type of means of 
transport.  
 Risk Management 
in Border 
Processes  MSME s are generally perceived as 
high-risk operators. Administrations 
that base risk calculations solely on the 
regularity and frequenc y of transactions 
are more likely to inspect small traders. 
MSME s may also be asked to provide 
cash or cash -equivalent securities when 
there are disagreements with customs, 
which again disadvantages them.  
 
Also, MSME s generally know little about 
keeping re cords, do not follow internal 
accounting guidelines and often cannot 
afford to hire professional accountants, 
which might lead to more interventions, 
delays and costs in audit -based customs 
control. (ITC toolkit)  
 ITC toolkit:  
• Develop digital systems and tools to 
process applications and maintain records 
for risk management.  
• Develop combined multiple indicators to 
evaluate traders on the basis of past 
compliance, not just the value and 
frequency of transactions.  
• Optimize border processes and al low 
pre-arrival filing to accelerate the release of 
goods for MSME s. 
• Check regularly to verify the efficiency and 
effectiveness of border processing.  [N/A]    INF/MSME/W/8  
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TFA provisions  TFA measures  MSME pain points  Relevant recommendations from 
external studies or presentations to 
MSME IWG1 Good national/regional  
practices2 
Article 7.7: Trade Facilitation Measures 
for Authorized Operators  
• §7.2 The specified criteria to qualify as 
an authorized operator shall be related 
to compliance, or the risk of 
non-compliance, with requirements 
specified in a Member's laws, 
regulations or procedures (…) (b) Such 
criteria shall not: (ii) to the extent 
possible, restrict th e participation of 
small and medium -sized enterprises.  
• §7.3 The trade facilitation measures 
provided pursuant to paragraph 7.1 
shall include at least three of the 
following measures:  
(a) low documentary and data 
requirements, as appropriate;  
(b) low rate o f physical inspections and 
examinations, as appropriate;  
(c) rapid release time, as appropriate;  
(d) deferred payment of duties, taxes, 
fees, and charges;  
(e) use of comprehensive guarantees or 
reduced guarantees;  
(f) a single customs declaration for all 
imports or exports in a given period; 
and 
(g) clearance of goods at the premises 
of the authorized operator or another 
place authorized by customs . 
 Authorized 
Operators (AEO)  MSME s are often excluded from trusted 
party schemes, such as  authorized 
economic operator (AEO) arrangements 
because of inadequate records and 
accounting practices and are unable to 
meet security and guarantee 
requirements. (ITC toolkit)  
 
In practice, many AEO schemes do not 
work properly for MSMEs according to 
UK FSB. (June  2019 workshop)25 
 
 ITC toolkit:  
• Take MSME  needs on board when setting 
criteria and build criteria on measurable 
and reasonable requirements.  
• Offer MSME s cost -effective, alternative 
security requirements to achieve 
authorized status and explain the benefits.  
• Design capacity -development programmes 
for MSME s as part of proactive and 
informed compliance management plans, 
including specific accounting guidelines and 
training for MSME s. 
 
FIATA presentation:  
• Government can create special AEO 
Programmes for MSME s that require less 
stringent criteria for MSME s to qualify for 
AEO status, or access to at least some AEO 
capabilities.  
• FIATA and its members could help with the 
burden of identifying those MSME s which 
could fit the profile of an AEO spec ial 
services applicant in order to reduce costs 
and help facilitate customs clearance.  
 1) Hong Kong, China Customs AEO 
programme:  
• HKC formulated a two -tier free and 
voluntary accreditation programme 
open to local companies engaging 
in business principally  related to the 
international supply chain. 
Companies applying for a lower tier 
must meet certain basic criteria, 
and additional criteria are required 
for a higher tier.  
• The AEOs recognized so far, 
including MSME s, could meet the 
accreditation criteria without 
making major changes or 
investments. Recognizing that the 
extent of compliance depends on 
the size, nature and model of the 
business, HKC exercises flexibility 
in the accreditation process. (ITC 
toolkit)  
                                                
25 https://www.wto.org/english/tratop_e/msmes_e/fsb_presentation.pdf .   INF/MSME/W/8  
- 12 - 
 
TFA provisions  TFA measures  MSME pain points  Relevant recommendations from 
external studies or presentations to 
MSME IWG1 Good national/regional  
practices2 
Article 7.8: Expedited Shipments  
• §8.2(a) Members shall minimize the 
documentation required for the release 
of expedited shipments  in accordance 
with paragraph 1 of Article 10 and, to 
the extent possible, provide for release 
based on a single submission of 
information on certain shipments ; 
• §8.2(b) provide for expedited 
shipments to be released under normal 
circumstances as rapidly as possible 
after arrival , provided the information 
required for release has been 
submitted;  
• §8.2(d) provide, to the extent possible, 
for a de minimis s hipment value or 
dutiable amount for which customs 
duties and taxes will not be collected , 
aside from certain prescribed goods. 
Internal taxes, such as value added 
taxes and excise taxes, applied to 
imports consistently with Article III of 
the GATT  1994 ar e not subject to this 
provision.  
 Expedited 
Shipments  MSMEs can benefit from e -commerce if 
they have access to efficient, reliable 
logistics services that they can afford.  
Postal systems are, by definition, not 
focused on profit, and aim to fulfil citizen 
and business needs. They can help 
MSME s by providing more choices and 
services that are competitive with what 
MSME s receive from express couriers. 
(ITC toolkit)  
 ITC toolki t: 
• Strengthen postal services to meet the 
needs of MSME s – invest in logistics 
facilities and cross -border solutions with 
efficient procedures.  
 
FIATA presentation:  
• Governments should lessen or waive 
superfluous fees, inspection procedures 
and paperwork fo r MSME s that satisfy a 
minimum shipment value or volume 
criteria, aimed at giving preference to the 
expedition of MSME shipments in particular.  1) Canada Post Solutions for Small 
Business26 
• A savings program created for small 
businesses which offer s discounts 
of up to 34% on shipments within 
Canada and up to 47% 
internationally. It also provides 
marketing tools to target and reach 
new customers through direct mail.  
 
 
__________  
                                                
26 https://www.canadapost.ca/cpc/ en/business/small -business.page .