G/SCM/Q2/CHN/ 80 
20 November  2019 
(19-7934) Page: 1/12 
Committee on Subsidies and Countervailing Measures  Original:  English  
 
  
SUBSIDIES  
REPLIES TO QUESTIONS F ROM THE UNITED STATE S1 REGARDING  
THE SUB-CENTRAL NEW AND FULL NOTIFIC ATION OF CHINA2 
The following communication, dated 19 November 2019 , is being ci rculated at the request of the 
Delegation of China . 
 
_______________  
 
 
1. We appreciate the answers to the United States’ questions on China’s sub -central 
notification.  We recognize that collecting subsidy information from sub -central entities 
can be a difficult task.  We note, however, only 20 of the 32 sub-central entities are 
covered in China’s first and only sub -central subsidy notification since becoming a WTO 
Member seventeen years ago.  The United States considers this to be inadequate given the 
prevalence of subsidy programs administered by sub -central authorities, as well as a 
history of prohibited subsidies being provided by sub -central entities, as is demonstrated 
in several dispute settlement consultation requests by the United States, and indeed, the 
sub-central notification itself.  Will China c ommit to meeting its obligation under the 
Agreement on Subsidies and Countervailing Measures to include subsidies from all sub -
central entities in its next subsidies notification (which was due June 2017)?  
Reply  
The two notifications submitted by China in 2018 and 2019 with respect to local subsidies have 
covered all the provincial -level administrative territories of China.  
2. While China has notified the Strategic Emerging Industries (SEI) program at the 
central government level, there were no SEI measures i ncluded in the sub -central 
notification.  Why were the sub -central SEI measures listed below not included in the sub -
central notification?  
• Beijing Municipality Opinion on the Implementation of Accelerating the 
Cultivation and Development of Strategic Emergi ng Industries, Beijing Municipal 
People's Government, Jing Zheng Fa [2011] No. 38 (21 July 2011).  
• Fujian Province Plan on the Implementation of Accelerating the Development of 
Strategic Emerging  Industries , Fujian Provincial People's Government, Min 
Zheng [2011] No. 104 (10  December 2011).  
• Jiangxi  Province Interim Measure on the Administration of the S trategic 
Emerging Industries Investment Guidance Fund , Jiangxi Provincial People's 
Government (27 March 2012).  
                                                
1 G/SCM/Q2/CHN/74.  
2 G/SCM/N/95/CHN/Suppl.1 -G/SCM/N/123/CHN/Suppl.1 -G/SCM/N/155/CHN/Suppl.1 -
G/SCM/N/186/CHN/Suppl.1 -G/SCM/N/220/CHN/Suppl.1 -G/SCM/N/253/CHN/Suppl.1 -
G/SCM/N/284/CHN/Suppl.1; 29 July 2016.  G/SCM/Q2/CHN/ 80 
- 2 - 
  • Shandong  Province 12th Five -Year Plan on Strategic Emerging Industries 
Development , Shandong Provincial People's Government, Lu Zheng Fa [2012] 
No. 42 (2 November 2012).  
• Shanghai Municipality Measure on the Administration of the Strategic Emerging 
Industries Development  Special Fund , Shanghai Municipal Development and 
Reform Commission, Shanghai Municipal Department of Finance, Hu Fu Fa [2012] 
No. 72 (4  August 2012).  
• Opinion on the Implementation of State Council Deployment of Accelerating the 
Cultivation and Development  of Strategic Emerging Industries , Guangdong 
Provincial People's Government, Yue Fu [2011] No. 87 (20 July 2011).  
• Gansu Province Plan on the Implementation of the Strategic Emerging Industries 
Development Overall Campaign , Gansu Provincial People's Government, Gan 
Zheng Fa [2014] No.  87 (15 September 2014).  
• Gansu Province Measure for the Administration of the Strategic Emer ging 
Industries Development  Provincial -Level Financial Funding Investment , Gansu 
Provincial People's Government, Gan Zheng Ban Fa [2014] No. 176 (3 November 
2014).  
• Zhejiang  Province Interim Measure on the Administration of the Strategic 
Emerging Industries  Finance Special Fund , Zhejiang Province Department of 
Finance, Zhe Cai Qi [2012] No.  152 (22 May 2012).  
• Ningbo City Rule on the Strategic Emerging Industries Development Special 
Administration (Trial),  Ningbo City Accelerating the Cultivation and Developm ent 
of Strategic Emerging Industries  Work Leading Small Group Office, Yong Xin Ling 
Ban [2013] No. 2 (9 April 2013).  
• Ninghai County Opinion on the Implementation of Accelerating the Cultivation 
and Development  of Strategic Emerging Industries , Ninghai Cou nty People's 
Government, Ning Dang Fa [2013] No. 27 (16 August 2013).  
• Ninghai County Notice on Transmitting Down the 2015 Ningbo City Strategic 
Emerging Industries Development Special Financial Subsidies , Ninghai County 
Development and Reform Bureau , Ningh ai County Finance Bureau, Ning Fa Gai 
[2015] No. 23 (22 May 2015).  
• CPC Wenzhou City Ouhai District Commission and Wenzhou City Ouhai District 
People's Government Opinion on the Implementation of Accelerating the 
Cultivation and Development of Strategic Eme rging Industries (Trial),  CPC 
Wenzhou City Ouhai District Commission , Wenzhou City Ouhai District People's 
Government, Ou Wei Fa [2012] No.  91 (20 July 2012).  
• Ouhai District Measure on the Administration of the Cultivation and Development 
of Strategic Emer ging Industries Special Fund (Trial),  Wenzhou City Ouhai 
District People's Government, Wen Ou Zheng Ban Fa [2013] No. 79 (9 May 2013).  
• Sichuan Province Measure on the Use and Administration of the Strategic 
Emerging Industries Development Special Fund , Sic huan Provincial People's 
Government, Chuan Ban Fa [2012] No. 22 (11 April 2012).  
• Sichuan Province Rule on the Implementation of the Measure on the Use and 
Administration  of the Strategic Emerging Industries Development Special Fund , 
Sichuan Province Indust rialization and Urbanization Work Leading Small Group, 
Chuan Gong Cheng [2012] No. 1 (4 June 2012).  G/SCM/Q2/CHN/ 80 
- 3 - 
  • Jiangsu Province Interim Measure on the Administration of the Provincial -Level 
Strategic Emerging Industries Development Special Fund , Jiangsu Provincial 
People's Government, Su Zheng Ban Fa [2012] No. 172 (25 September 2012).  
• Heilongjiang Province 12th Five -Year Plan on Strategic Emerging Industries 
Development , Heilongjiang  Provincial Development and Reform Commission 
(19 August 2015).  
• Xinjiang Uyghur Auton omous Region Interim Measure on the Administration of 
the Strategic Emerging Industries Special Fund , Xinjiang Uyghur Autonomous 
Region Department of Finance, Xinjiang Uyghur Autonomous Region Economic 
and Informatization Commission, Xin Cai Jian [2011] No . 728 
(29 November  2011).  
Reply  
China is of the views  that the list of questions raised against the subsidy notification submitted by a 
member should focus on the subsidy notification itself. With regard to subsidy policies not covered 
by a member in its notification, other members should raise concern in ac cordance with Article 25.10 
of the SCMA of the WTO, which article does not in fact require a notifying member to make written 
reply to those uncovered subsidies. If other members request a notifying member to make 
explanations with respect to the uncovered  policies in the list of questions, it in essence amounts to 
a new obligation of making reply in writing under the Article 25.10. Moreover, China has already 
made explanations and clarifications in previous regular meetings for the strategic emerging 
indus tries-oriented subsidies it has verified. please refer to the minutes of meetings.  
In an effort to show China’s earnest effort to improve the transparency of its trade policies and to 
address the U.S. concerns, China is willing to share with the U.S. side the information it has verified, 
but this does not mean that China agrees with the U.S. practice of raising concern over uncovered 
policies in the list of questions concerning subsidy notifications.  
Now according to what we have verified, the policies of concern to the U.S. fall into several types as 
follows:  
Firstly, policies that are based on market operations, which do not fall into the scope of "subsidies " 
defined by the WTO. This type of policies include mainly the following:  
• Gansu Province Plan on the Implementation of the Strategic Emerging Industries 
Development Overall Campaign, Gansu Provincial People's Government, Gan Zheng Fa 
[2014] No. 87 (15 September 2014).  
• Gansu Province Measure for the Administration of the Strategic Emerging Industries 
Development Provincial -Level Financial Funding Investment, Gansu Provincial People's 
Government, Gan Zheng Ban Fa [2014] No. 176 (3 November 2014) .  
Secondly, policies of guiding nature which do not involve subsidies. This type of policies inclu de 
mainly the following:  
• Heilongjiang Province 12th Five -Year Plan on Strategic Emerging Industries Development, 
Heilongjiang Provincial Development and Reform Commission (19 August 2015).  
Thirdly, subsidy policies already notified by China. This type of  policies include mainly the following:  
• Xinjiang Uyghur Autonomous Region Interim Measure on the Administration of the Strategic 
Emerging Industries Special Fund, Xinjiang Uyghur Autonomous Region Department of 
Finance, Xinjiang Uyghur Autonomous Region E conomic and Informatization Commission, 
Xin Cai Jian [2011] No. 728 (29 November 2011).  G/SCM/Q2/CHN/ 80 
- 4 - 
  3. China has stated that its steel companies do not receive any specific subsidies.  Is it 
China’s position that none  of the hundreds  of line items listed in the annual re ports of the 
steel companies in China under the heading of "Government Subsidies" or "Government 
Grants" should be notified?3 Is it not China’s position that these are all sub -central 
support measures?  
Reply  
The two most recent notifications of China, which covered central and local government subsidies, 
included some subsidy policies for the steel industry. China holds the view that those policies are 
not specific to steel sector in general, but nonetheless incorporates them into the notificatio ns for 
the sake of transparency. For the concerned subsidy items, please refer to the subsidy notifications 
submitted recently by China.  
4. China has stated that it is "considering" notification of its fisheries subsidies.  Since 
becoming a WTO Member, China h as not notified nearly all of its wild capture fishery 
subsidy programs.  Based on China’s 2014 Trade Policy Review and the United States’ 2016 
counter -notification of Chinese fisheries subsidies4, it appears that in recent years, 
subsidies for fishing boat  construction/acquisition or renovation are primarily, if not 
exclusively, provided at the sub -central level.  Based on estimates from China’s Ministry 
of Agriculture,  as of 2015 2,700  distant water fishing vessels are in operat ion, and that 
compared to 2010 at the end of the "Eleventh Five -year Plan ," the number of distant water 
fishing vessels has increased by 60  percent.  Why were none of the provincial boat 
construction/acquisition or renovation programs included in China’s sub -central 
notification?  
Reply  
For the fisheries subsidies  policies, please refer to  the two notifications made by China in 2018 and 
2019 respectively . 
5. Why did China not include in its sub -central notification the subsidy measures listed 
below relating to the Internationally -Well Known Brand program?  
• Notice on Organizing and Carrying Out the 2013 -2015 "Anhui Famous Export 
Brands" Selection Work , Wan Shan g Mao Fa Zi [2013] No. 248, Anhui Province  
Department of Commerce (20 May 2013).  
• Notice Recommending the 2014 -2015 Chongqing International Well -known 
Brand Enterprises , Chongqing Municipality  Foreign Trade and Economic 
Commission  (28 February  2014).  
• Opinio n on Support for Foreign Trade and Economic Development Several 
Policies , Rong Wei Fa [2011] No. 47, Rongchang County Economic and Trade 
Committee (2011).  
• Notice on Organizing  "2014 -2016 Fujian Province Key Cultivation and 
Development International Well -Known Brands" Selection , Fujian Province 
Department of Commerce, Min Shang Wu Wai Mao [2014] No. 22 
(15 September  2014).  
• Fujian Province Foreign Trade and Economic Cooperation Bureau Passing on the 
Ministry of Commerce and Eight Agency [Issued] Guiding Opini on on Promoting 
International Well -Known Brands Cultivation Work , Min Wai Jing Mao Fa [2009] 
No. 16 (27 April 2009).  
                                                
3 See G/SCM/Q2/CHN/70.  
4 See G/SCM/Q2/CHN/59.  G/SCM/Q2/CHN/ 80 
- 5 - 
  • Notice on Doing Well the 2014 -2016 Fujian Province Key Cultivation and 
Development International Well-Known Brands Application Work , Fujian City 
Foreign Trade and Economic Cooperation Bureau (7 August 2014).  
• Notice on Organizing  Enterprises to Apply for th e 2014 -2016 "Fujian Province 
Key Cultivation and Development International Well -Known Brands" , Quanzhou 
City Foreign Trade and Economic Cooperation Bureau (5 August 2014).  
• Notice on Recommending the 2013 -2014 "Fujian Province Key Cultivation and 
Developmen t International Well -Known Brands" Enterprises, Fujian City Foreign 
Trade and Economic Cooperation Bureau (20 July 2011).  
• Notice on Advancing Stone, Ceramic, and Kitchen and Bathroom Industry Steady 
Healthy Development Twenty Policies, Nan Wei Ban [2015] N o. 16, CPC Nan'an 
City Committee Office, Nan'an City People's Government (3 February 2015).  
• Implementing Opinion on Accelerating Industrial Leapfrog Development, Zhang 
Wei Fa [2015] No. 3, CPC Zhangzhou City Committee, Zhangzhou City People's 
Government (7  February 2015).  
• Notice on Several Measures to Advance the Textile, Shoe, and Clothing Industry's 
Healthy Development, Quanzhou City People's Government (6 January 2015).  
• Opinions on Promoting the Upgrade and Development of the Manufacturing 
Sector, Jin  Zheng Wen [2013] No. 64, Jinjiang City People's Government 
(25 March 2013).  
• Notice on Passing on Jimei District Measure on Implementing Standardization 
and Brand Development Strategic Rewards, Ji Fu Ban [2012] No. 113, Xiamen 
City Jimei District People's Government (6 December 2012).  
• Dehua County Three -Year Action Plan for Further Promoting Enterprises' 
Indigenous Innovation, De Zheng [2011] No. 176, Dehua County People's 
Government (12  May 2011).  
• Several Opinions on Implementing Brand Strategic Developmen t and Brand 
Economy, Xia Fu [2011] No. 349, Xiamen City People's Government 
(24 August  2011).  
• Guiding Opinion on Promoting Foreign Economic and Trade Enterprises' 
Indigenous Innovation and Indigenous International Well -Known Brand 
Construction, Yue Wai Jin g Mao Ting Zi [2011] No. 12, Guangdong Province 
Foreign Trade and Economic Bureau (27  September 2011).  
• Notice on Carrying Out Guangzhou City 2012 -2013 Key Cultivation and 
Development Indigenous International Well -Known Brands Enterprise 
Designation Work, G uangzhou City People's Government (30 July 2012).  
• Work Plan for the 2011 -2013 Guangdong Province Foreign Trade and Economic 
Bureau Key Cultivation and Development International Well -Known Brands 
Designation, Yue Wai Jing Mao Ji Zi [2011] No. 7, Guangdong P rovince Foreign 
Trade and Economic Bureau (2011).  
• Haojiang District Measures on Promoting Foreign Trade Import and Export 
Development (Trial), Shan Hao Fu Ban [2012] No. 69, Shantou City Haojiang 
District People's Government (26 April 2012).  
• Dongguan City Support Measure for Processing Trade Enterprises Brand 
Creation, Dong Fu Ban [2012] No. 118, Dongguan City People's Government 
(3 August 2012).  G/SCM/Q2/CHN/ 80 
- 6 - 
  • Preferential Policies to Support Foreign -invested Enterprise Trademark 
Registration and International Well -Known  Brands, Dongguan City People's 
Government (2012).  
• Implementing Opinion to Further Promote Henan Province International Well -
Known Brands Cultivation and Construction Work, Yu Shang Mao [2010] No. 9, 
Henan Province People's Government, Henan Province Devel opment and Reform 
Commission, Henan Province Department of Finance, Henan Province 
Department of Science and Technology, Zhengzhou Customs of the People's 
Republic China, Henan Province Administration of Taxation, Henan Exit -Entry 
Inspection and Quarantine  Bureau of the People's Republic of China 
(19 May 2010).  
• Opinion on Promoting International Well -Known Brands Cultivation Work, Hebi 
City People's Government (22 September 2009).  
• Notice on Organizing the Recommendation and Selection of the 2013 -2015 
"Henan  Province International Well -Known Brands" Activities, Henan Province 
Department of Commerce (5  January 2013).  
• Henan Province Selection Measure on International Well -Known Products 
(May  19, 2010).  
• Notice on the Issuance of the Kaifeng City Award Measures f or Attracting 
Business and Investment Target Administration Evaluation and the Kaifeng City 
Award Measure on Foreign Trade Work Evaluation, Bian Zheng [2015] No. 18, 
Kaifeng City People's Government (15  February  2015).  
• Opinion on Accelerating Feicheng Bran d Construction, CPC Feicheng Committee, 
Feicheng City People's Government (22 August 2013).  
• Opinion on Promoting Foreign Trade Accelerated Development, Zheng Zheng 
[2012] No.  26, Zhengzhou City People's Government (12 June 2012).  
• Notice on Carrying Out the  2010 Hubei Province International Well -Known 
Brands Selection and Application Work, E Shang Wai [2010] No. 21, Hubei 
Province Department of Commerce (30 July 2010)  
• Implementing Opinion on Promoting International Well -Known Brands 
Cultivation Work, Hunan P rovince Department of Commerce, Hunan Province 
Development and Reform Commission, Hunan Province Department of Finance, 
Hunan Province Department of Science and Technology, Changsha City Customs, 
Hunan Province Administration of Taxation, Hunan Province Ad ministration for 
Industry and Commerce, Hunan Province Administration of Quality Supervision, 
Inspection, and Quarantine, Exit -Entry Inspection and Quarantine Bureau (7 
August 2009).  
• Notice on Candidate Nomination for the 2015 "Hunan International Well -Known 
Brands", Xiang Shang Mao [2015] No. 17, Hunan Province Department of 
Commerce (5  June  2015).  
• Notice on Candidate Nomination for the 2014 "Hunan International Well -Known 
Brands", Xiang Shang Mao [2014] No. 19, Hunan Province Department of 
Commerce (6 May  2014).  
• Notice on Candidate Nomination for the 2013 "Hunan International Well -Known 
Brands", Xiang Shang Mao Fa [2013] No. 16, Hunan Province Department of 
Commerce (15  May 2013).  G/SCM/Q2/CHN/ 80 
- 7 - 
  • Measure for the Hunan Province International -Well Known Brands Designation 
and Administration, Xiang Shang Mao Fa [2010] No. 8, Hunan Province 
Department of Commerce (2 April 2010).  
• Notice on Doing Well the 2013 Hunan Province Foreign Trade Development Fund 
Project Application, Xiang Shang Cai [2013] No. 57, Hunan Pro vince Department 
of Commerce, Hunan Province Department of Finance (17 June 2013).  
• Opinion on Accelerating Foreign Trade Development, Xiang Xiang Zheng Fa 
[2013] No.  6, Xiangxiang City People's Government (23 May 2013).  
• Implementing Opinion on Accelerating  Industrial Development, Xintian County 
People's Government (20 November 2013).  
• Measure on Industrial Enterprise Development Preferential Policies and 
Rewards, Hongjiang City People's Government (7 March 2012).  
• Changde City Interim Measure on Continuation of Industrial Shifting 
Development and Processing Trade Guiding Fund Administration, Changde City 
People's Government (24  February 2012).  
• Several Policies for the Implementation of Accelerating Development and Open 
Economy, Xiang Zheng Fa [2011] No. 8, Hun an Provincial People's Government 
(4 May 2011).  
• Provision on Encouraging the County's Industrial Economic Development Zones 
and Industrial Development, Long Fa [2010] No. 12, CPC Longhui County 
Committee, Longhui County People's Government (30 December 201 0). 
• Inner Mongolia Implementing Plan on Promoting International Well -Known 
Brands Cultivation Work "Ten Thousand Talent Program" (Trial), Nei Mao Cu 
Shang Zi [2014] No. 5, Inner Mongolia Chamber of International Commerce 
(27 November 2014).  
• Notice on Carry ing out 2015 "Inner Mongolia Key Cultivation and Development 
International Well -Known Brands" Selection and Designation Work, Nei Pin Gong 
Wei Zi [2015] No. 1, Inner Mongolia International Well -Known Brands 
Cultivation Work Committee (16  March  2015).  
• Notic e on Passing Down the 2014 -2016 Jiangsu Province International Well -
Known Brands Cultivation Work Key Points, Su Shang Mao [2014] No. 18, Jiangsu 
Province Department of Commerce (8 January 2014).  
• City Government Office Notice on Passing on the Wuxi City Cu ltivation of Province 
International Well -Known Brands Three Year Action Plan, Xi Zheng Ban Fa 
[2011] No.  275, Wuxi City People's Government (19 October 2011).  
• Measure on the 2014 -2016 Jiangsu Province Key Cultivation and Development 
Province International Well-Known Brands Selection, Jiangsu Province (2014).  
• Notice on Organizing and Applying for the 2014 -2016 Jiangsu Province Key 
Cultivation and Development Province International Well -Known Brands, 
Nanjing City Bureau of Commerce (13 January 2014).  
• Implemen ting Rules on the 2014 -2015 Suzhou City Export Brand Selection, 
Suzhou City Commerce Bureau (2014).  
• Notice on Carrying Out the 2013 -2014 Suzhou City Export Brand Selection Work, 
Shang Wai Mao [2013] No. 277, Suzhou City Commerce Bureau (31 May 2013).  G/SCM/Q2/CHN/ 80 
- 8 - 
  • Selection Standards for the 2013 -2014 Wuxi City Key Cultivation and 
Development International Well -Known Brands, Wuxi City Commerce Bureau 
(2013).  
• Implementing Rules on the 2012 -2013 Suzhou City Export Brand Selection, 
Suzhou City Commerce Bureau (2012).  
• Notice on the Selection of the 2012 -2013 Nantong City Key Cultivation and 
Development Province International Well -Known Brands, Nantong City 
Commerce Bureau (21  February  2012).  
• Notice on Carrying Out the 2011 -2013 Jiangsu Province Key Cultivation and 
Develo pment Province International Well -Known Brands Selection Work, Jiangsu 
Province Department of Commerce (12 January 2011).  
• Implementing Rule on the 2011 -2012 Suzhou City Export Brands Selection, 
Suzhou City Commerce Bureau (5 August 2011).  
• Measure on the Se lection of Hua'an City Export Brands, Huai Zheng Ban Fa [2011] 
No. 127, Huai'an City People's Government (14 September 2011).  
• Opinion on Several Policies to Promote the Entire City's Industrial Economic 
Transformation and Upgrade, Qi Zheng Fa [2015] No. 10 , Qidong City People's 
Government (4  February  2015).  
• Measure on the Implementation of Nanjing City Support of Foreign Trade Steady 
Growth, Nanjing City People's Government (13 August 2014).  
• Measure on the 2014 Foreign Trade Steady Growth Special Fund Admin istration 
and Use, She Shang Wu [2014] No. 62, Sheyang County Commerce Bureau, 
Sheyang County Finance Bureau (26 July 2014).  
• Taicang City Measure on Promoting Foreign Trade Import and Export 
Development  Rewards, Tai Zheng Gui [2014] No. 1, Taicang City Peo ple's 
Government (26 June 2014).  
• Implementing Opinion on the 2014 Provincial -level Commerce Development 
Fund to Support Foreign Trade Transformation and Upgrade, Su Cai Gong Mao 
[2014] No. 75, Jiangsu Province Department of Finance, Jiangsu Province 
Depart ment of Commerce (25  June 2014).  
• Implementing Opinion on Lianyungang City Supporting Foreign Trade Steady 
Growth, Lian Zheng Ban Fa [2014] No. 115, Lianyungang City People's 
Government (20 August 2014).  
• Implementing Rule on Pei County Commerce Development Special Fund 
Supporting Foreign Trade Steady Growth (2013 Revised Version), Pei County 
Finance Bureau, Pei  County Commerce Bureau (15 October 2013).  
• Measure on 2013 Taicang City Promoting Foreign Trade Import and Export 
Development Rewards, Tai  Zheng Fa [2013] No. 61, Taicang City People's 
Government (9 July 2013).  
• Opinion on Promoting Foreign Trade Development Several Policies, Nantong City 
People's Government (14 June 2012).  
• Measure on the Administration of the Provincial Commerce and Developm ent 
Special Fund (Interim), Suqian City Finance Bureau, Suqian City Commerce 
Bureau (2012).  G/SCM/Q2/CHN/ 80 
- 9 - 
  • Nanjing City Supporting Foreign Trade Transformation and Upgrade and 
Commerce Development Special Fund Application Requirements and Tables, 
Nanjing City Commerce Bu reau (2011).  
• Kunshan City Measure on the Administration of Provincial -Level Commerce 
Development Special Fund Use, Kunshan City Finance Bureau, Kunshan City 
Commerce Bureau (12  August 2011).  
• Notice on the Issuance of the 2014 -2016 Jiangsu Province Key Cult ivation and 
Development International Well -Known Brands List, Su Shang Mao [2014] No. 
631, Jiangsu Province Department of Commerce (16 July 2014).  
• Notice on Applying for the "Shaanxi Province International Well -Known Brand 
Enterprises", Shaan Shang Fa [201 0] No. 621, Shaanxi Province Department of 
Commerce, Shaanxi Province Department of Finance (1 November 2010).  
• Notice on Organizing the 2014 -2016 "Shandong Province Key Cultivation and 
Development International Well -Known Brands" Selection Activities, Lv S hang Zi 
[2014] No. 95, Shandong Province Department of Commerce (21 May 2014).  
• Notice on Organizing the Application for the 2014 -2016 "Shandong Province Key 
Cultivation and Development International Well -Known Brands", Weifang City 
Commerce Bureau (26  May 2014).  
• Notice on Organizing, Recommending Our City's Enterprises to Participate in the 
2014 -2016 "Shandong Province Key Cultivation and Development International 
Well-Known Brands", Qingdao City Commerce Bureau (4 June 2014).  
• Notice on Doing Well the 2013 Foreign Trade Development Special Fund 
Application Work, Lu Cai Qi [2013] No. 20, Shandong Province Department of 
Finance, Shandong Province Department of Commerce (15 May 2013).  
• Notice on Carrying Out the Shandong Province Key Cultivation and Development 
International Well -Known Brands Selection Work, Shandong Province 
Department of Commerce (7 September 2011).  
• Opinion on Further Accelerating Open Economic Development, Qu Zheng Fa 
[2013] No.  14, Qufu City People's Government (14 August 2013).  
• Opinion on Ac celerating Foreign Trade Transformation and Upgrade and 
Promoting Foreign Trade Good and Fast Development, Lai Zheng Fa [2012] 
No. 43, Laiwu City People's Government (12 November 2012).  
• Rule on the Tianjin Municipality Exit -Entry Inspection and Quarantine Bureau 
Promoting International Well -Known Brands Cultivation Work, Jin Jian Ren 
[2010] No. 0155, Tianjin Municipality Exit -Entry Inspection and Quarantine 
Bureau (19 July 2010).  
• Notice on Carrying Out the 2011 "Tianjin Municipality International Well -Known  
Brands" Designation Work, Tianjin Municipality Commerce Committee (15 
November 2011).  
• Notice on Carrying Out the 2014 "Zhejiang Export Brands" Designation Work, 
Zhe Shang Wu Mao Fa [2014] No. 104, Zhejiang Province Department of 
Commerce (20  June  2014).  
Reply 
China is of the view that the list of questions raised regarding  the subsidy notification submitted by 
a member should focus on the subsidy notification itself. With regard to subsidy policies not covered 
by a member in its notification, other members  should raise concern in accordance with Article 25.10 G/SCM/Q2/CHN/ 80 
- 10 - 
  of the SCMA of the WTO, which does not in fact require a notifying member to make written reply 
to those uncovered subsidies. If other members request a notifying member to make explanations 
with respe ct to the uncovered policies in the list of questions, it in essence amounts to a new 
obligation of making reply in writing under the Article 25.10. Moreover, China has already made 
explanations and clarifications in previous regular meetings with respect to the International Well-
known Brand projects it has verified. Therefore, the U.S. side is suggested to consult minutes of the 
meetings concerned for details.  
In an effort to show China’s earnest effort to improve the transparency of its trade policies and to 
address the U.S. concerns, China is willing to share with the U.S. side the information it has verified, 
but this does not mean that China agrees with the U.S. practice of raising concern with regard to 
uncovered policies in the list of questions concerning subsidy notifications.  
Now according to what we have verified, the policies of concern to the U.S. fall into several types as 
follows:  
First, policies which grant honorary titles of "international well -known brands " rather than provide 
subsidies such as  
• Notice on Organizing and Carrying Out the 2013 -2015 "Anhui Famous Export Brands" 
Selection Work, Wan Shang Mao Fa Zi [2013] No. 248, Anhui Province Department of 
Commerce (20 May 2013).  
• Notice on Organizing "2014 -2016 Fujian Province Key Cultivation and D evelopment 
International Well -Known Brands" Selection, Fujian Province Department of Commerce, Min 
Shang Wu Wai Mao [2014] No. 22 (15 September 2014).  
• Fujian Province Foreign Trade and Economic Cooperation Bureau Passing on the Ministry of 
Commerce and Ei ght Agency [Issued] Guiding Opinion on Promoting International Well -
Known Brands Cultivation Work, Min Wai Jing Mao Fa [2009] No. 16 (27 April 2009).  
• Notice on Doing Well the 2014 -2016 Fujian Province Key Cultivation and Development 
International Well -Known Brands Application Work, Fujian City Foreign Trade and Economic 
Cooperation Bureau (7 August 2014).  
• Notice on Organizing Enterprises to Apply for the 2014 -2016 "Fujian Province Key Cultivation 
and Development International Well -Known Brands", Quanzhou City Foreign Trade and 
Economic Cooperation Bureau (5 August 2014).  
• Notice on Carrying Out Guangzhou City 2012 -2013 Key Cultivation and Development 
Indigenous International Well -Known Brands Enterprise Designation Work, Guangzhou City 
People's Government (30 July 2012).  
• Implementing Opinion to Further Promote Henan Province International Well -Known Brands 
Cultivation and Construction Work, Yu Shang Mao [2010] No. 9, Henan Province People's 
Government, Henan Province Development and Reform Commission, Hena n Province 
Department of Finance, Henan Province Department of Science and Technology, Zhengzhou 
Customs of the People's Republic China, Henan Province Administration of Taxation, Henan 
Exit-Entry Inspection and Quarantine Bureau of the People's Republic o f China 
(19 May 2010).  
• Notice on Organizing the Recommendation and Selection of the 2013 -2015 "Henan Province 
International Well -Known Brands" Activities, Henan Province Department of Commerce 
(5 January 2013).  
• Henan Province Selection Measure on Interna tional Well -Known Products (May  19, 2010).  
• Notice on Carrying Out the 2010 Hubei Province International Well -Known Brands Selection 
and Application Work, E Shang Wai [2010] No. 21, Hubei Province Department of Commerce 
(30 July 2010) .  G/SCM/Q2/CHN/ 80 
- 11 - 
  • Notice on Carrying  Out the 2014 "Zhejiang Export Brands" Designation Work, Zhe Shang 
Wu Mao  Fa  [2014]  No.   104,   Zhejiang   Province   Department   of   Commerce 
(20 June 2014).  
Second, planning or catalogues are documents of guiding nature, which do not involve speci fic 
subsidies such as  
• Implementing Opinion on Accelerating Industrial Leapfrog Development, Zhang Wei Fa 
[2015] No. 3, CPC Zhangzhou City Committee, Zhangzhou City People's Government 
(7 February 2015).  
• Opinions on Promoting the Upgrade and Development of  the Manufacturing Sector, Jin Zheng 
Wen [2013] No. 64, Jinjiang City People's Government (25 March 2013).  
• Opinion on Promoting International Well -Known Brands Cultivation Work, Hebi City People's 
Government (22 September 2009).  
Third, relevant policies existed but no subsidy has ever been granted in accordance with such policies 
including  
• Notice on Advancing Stone, Ceramic, and Kitchen and Bathroom Industry  Steady Healthy 
Development Twenty Policies, Nan Wei Ban [2015] No. 16, CPC Nan'an City Committee 
Office, Nan'an City People's Government (3 February 2015).  
• Dehua County Three -Year Action Plan for Further Promoting Enterprises' Indigenous 
Innovation, De Zheng [2011] No. 176, Dehua County People's Government (12 May 2011).  
• Guiding Opinion on Promoting  Foreign Economic and Trade Enterprises' Indigenous 
Innovation and Indigenous International Well -Known Brand Construction, Yue Wai Jing Mao 
Ting Zi [2011] No. 12, Guangdong Province Foreign Trade and Economic Bureau 
(27 September 2011).  
• Work Plan for the 2 011-2013 Guangdong Province Foreign Trade and Economic Bureau Key 
Cultivation and Development International Well -Known Brands Designation, Yue Wai Jing 
Mao Ji Zi [2011] No. 7, Guangdong Province Foreign Trade and Economic Bureau (2011).  
• Haojiang District Measures on Promoting Foreign Trade Import and Export Development 
(Trial), Shan Hao Fu Ban [2012] No. 69, Shantou City Haojiang District People's Government 
(26 April 2012).  
• Opinion on Accelerating Foreign Trade Development, Xiang Xiang Zheng Fa [2013] No . 6, 
Xiangxiang City People's Government (23 May 2013).  
• Implementing Opinion on Accelerating Industrial Development, Xintian County People's 
Government (20  November2013).  
• Changde City Interim Measure on Continuation of Industrial Shifting Development and  
Processing Trade Guiding Fund Administration, Changde City People's Government 
(24 February  2012).  
• Inner Mongolia Implementing Plan on Promoting International Well -Known Brands 
Cultivation Work "Ten Thousand Talent Program" (Trial), Nei Mao Cu Shang Zi [2014] No.  5, 
Inner Mongolia Chamber of International Commerce (27 November 2014).  
• Notice on Carrying  out 2015 "Inner Mongolia Key Cultivation and Development International 
Well-Known Brands" Selection and Designation Work, Nei Pin Gong Wei Zi [2015] No. 1, 
Inner Mongolia International Well -Known Brands Cultivation Work Committee 
(16 March  2015).  G/SCM/Q2/CHN/ 80 
- 12 - 
  • Notice on Organizing the 2014 -2016 "Shandong Province Key Cultivation and Development 
International Well -Known Brands" Selection Activities, Lv Shang Zi [2014] No. 95, Shandong 
Province Department of Commerce (21 May 2014).  
• Notice on Organizing the Applic ation for the 2014 -2016 "Shandong Province Key Cultivation 
and Development International Well -Known Brands", Weifang City Commerce Bureau 
(26 May 2014).  
• Notice on Organizing, Recommending Our City's Enterprises to Participate in the 2014 - 2016 
"Shandong P rovince Key Cultivation and Development International Well -Known Brands", 
Qingdao City Commerce Bureau (4 June 2014).  
• Opinion on Further Accelerating Open Economic Development, Qu Zheng Fa [2013] No. 14, 
Qufu City People's Government (14 August 2013).  
• Rule on the Tianjin Municipality Exit -Entry Inspection and Quarantine Bureau Promoting 
International Well -Known Brands Cultivation Work, Jin Jian Ren [2010] No. 0155, Tianjin 
Municipality Exit -Entry Inspection and Quarantine Bureau (19 July 2010).  
• Notice on  Carrying Out the 2011 "Tianjin Municipality International Well -Known Brands" 
Designation Work, Tianjin Municipality Commerce Committee (15 November 2011).  
Fourth, subsidy policies claimed by the US side do not exist such as  
• Notice on Recommending the 201 3-2014 "Fujian Province Key Cultivation and Development 
International Well -Known Brands" Enterprises, Fujian City Foreign Trade and Economic 
Cooperation Bureau (20 July 2011).  
• Preferential Policies to Support Foreign -invested Enterprise Trademark Registra tion and 
International Well -Known Brands, Dongguan City People's Government (2012).  
• Measure on Industrial Enterprise Development Preferential Policies and Rewards, Hongjiang 
City People's Government (7 March 2012).  
__________