RESTRICTED  
  
WT/ACC/COM/23/Rev.5  
 
13 October 2022  
(22-7712) Page: 1/14  
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 13 October 2022, is being circulated at the request of the 
delegation of the Union of the Comoros.  
 
_______________  
 
  
 
1 Please note that the Comoros undertakes to complete the 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.5  
 
- 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) Trad e facilitation  ................................ ................................ ................................ ..... 10 
4. TBT-RELATED MEASURES  ................................ ................................ .....................  12 
5. MEASURES RELATED TO THE FOREIGN TRADE REGIME  ................................ ........  12 
  WT/ACC/COM/23/Rev.5  
 
- 3 - 1. SPS-RELATED MEASURES   
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 bui lding 
3. Preparation of provisions on pesticides  1. 2023 -2024 
2-3: 2023 -2024 
Establishment of the National Plant Protection Organization 
(NPPO) in accordance with IPPC requirements  Establishment of an office and appointment of the officials in charge  Fourth quarter of 2023  
Establishment of technical libraries, for example a CODEX 
library  Establishment of a CODEX, OIE and IPPC library  2022-2023 
Establishment of a multisectoral laboratory  1. Establishment of laboratory  
2. Purchase of necessary testing equipm ent Fourth quarter of 2022  
2022-2023 
Establishment 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  
• Six veterinary nurses  2022-2025 
Establishment of a medium - and long -term training plan for 
the use of pesticides  Training of 10 people on the prudent use of pesticides  
 2022-2025 
Promotion 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 
implementing the SPS system  
2. Encourage all actors to take ownership of the regulations  
3. Support the entities involved in implementing the SPS system as par t 
of drafting and implementing a programme of action  
4. Put in place the consultation framework for all entities involved in 
implementing the SPS system  
5. Define the roles and responsibilities of the stakeholders involved in 
implementing the SPS system to enhan ce 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. Promote the use of legislative, 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: 2022 -2025  WT/ACC/COM/23/Rev.5  
 
- 4 - 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 defining 
sustainable management approaches and meth ods 
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. Identify and assess the resources need ed 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 i mplementing 
the SPS system  
9. Put in place a system to implement SPS measures that are clear, 
coherent and adapted to local realities, and define roles and 
responsibilities  
10. Define the action plan and management 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 SPS 
system and measures  
13. Study the possibility of involving f arming, livestock farming and 
fishing communities in the implementation of the SPS system  1-13: 2023 -2024  WT/ACC/COM/23/Rev.5  
 
- 5 - 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 roles and responsibilities of each key player in collecting 
information  
4. Promote participa tory research in the implementation of SPS 
measures  
5. Define and implement effective information -sharing procedures and 
strengthen communication among all stakeholders in 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 appropriate indicators for monitoring the entities involved in 
the SPS system  
9. Develop and i mplement an effective communication plan to support 
the capacity -building strategy of SPS system stakeholders  1-9: 2023 -2024  WT/ACC/COM/23/Rev.5  
 
- 6 - 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 vari ous 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 streamline 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 levels, and 
participate in existing SPS system networks at the regional and 
international levels  
7. Provide operational support to SPS system bodies and mobilize 
programmes and projects to support the establishm ent and operation 
of those entities  
8. Organize an awareness -raising campaign for greater participation and 
representation of professionals and users in the implementation of the 
SPS system (policy, 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 o f 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 overseeing SPS measures  
12. Train and strengthen the capacities of the auton omous 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 their right to adequate service and able to 
demand it  
13. Disseminate re gularly SPS -related laws and regulations in force  1-13: 2022 -2024  WT/ACC/COM/23/Rev.5  
 
- 7 - 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. Organize a regular meeting to validate and/or revise the capacity -
building strategy of SPS system stakeholders  
2. Organize an annual meeting to take stock of implementation of the 
capacity -building strategy for stakeholders in the SPS system and 
identify possibilities  
3. Organize an annual meeting of servic es, programmes and projects 
involved in the SPS system with a view to sharing progress made, and 
capitalizing on and developing synergies  1-3: 2022 -2024 
Implement the necessary accompanying measures  1. Develop and adopt the necessary regulatory 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 imple mentation 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 institutions, including the University of the 
Comoros  
5. Undertake studies on the marketing channels of processed products  1-5: 2022 -2024 
 
 
 
 
   WT/ACC/COM/23/Rev.5  
 
- 8 - 2. TRIPS -RELATED MEASURES  
Description  Action to be taken  Time -frame  
Law on ratification of the 
2015 Bangui Agreement  Effective implementation  2022-2024  
 
 
Capacity building  Training of personnel, including customs officials, police officers, and officials responsible for 
protecting registered trademarks  2022-2024 
Creation of a registered trademark database  Fourth quarter of 2023  
Computerization of the Comorian Intellectual Property Office (OCPI)  Second quarter of 2023  
Institutionalization of the labelling of products protected by geographical indications (GIs)  2022-2024 
 
Law on copyright and related 
rights Effective implementation  Fourth quarter of 2 023 
Collective management organization (CMO ) technical assistance, e.g. the establishment of an 
online sales digitization system for the benefit of the CMO  2022-2024 
Structuring of institutions for the management of copyright and related rights in relation to the 
value chain  2022-2024 
Transposi tion of the provisions of the TRIPS Agreement into Law No. 20 -004/AU of 23 June 2020 
on copyright and related rights  First quarter of 2024  
 
 
   WT/ACC/COM/23/Rev.5  
 
- 9 - 3. CUSTOMS FORMALITIES   
(a) Measures related to the Customs Valuation Agreement   
Description  Action to be taken  Time -frame  
Revision of the 2015 Customs 
Code to take into account 
Articles 1 -9 of the WTO Customs 
Valuation Agreement  Integration of Articles 1 -9 of the Customs Valuation Agreement into the Customs Code  Second quarter of 2023  
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: Fourth quarter of 2023  
Creation of a technological 
information base including a 
database on risk assessment  1. Analysis of mirror data for statistical needs 2.  
2. Risk assessment training; workshops/seminars led by "risk assessment" specialists  Fourth quarter of 2022  
 
   WT/ACC/COM/23/Rev.5  
 
- 10 - (b) Fees and charges   
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 Union of the 
Comoros  1. Provision to be made for the elimination of the RCCI in the 2022 Finance  Law 
2. Provision to be made for the elimination of the AI and RCI in the 2023 Finance Law  
3. Provision to be made for the elimination of the PI in the 2024 Finance Law  1. First quarter of 2023  
2. First quarter of 2024  
3. First quarter of 2025  
Establishment of the VAT regime  1. Impact study on the implementation of VAT  
2. Consultations with large enterprises  
3. Communication campaign  
4. Preparation of a draft law in this respect, to be validated at a national workshop  
5. Training of accountants  
6. Creation of a control body  
7. Adoption of draft law by Parliament, and enactment  2022-2023 
Elimination of the Single Administrative Charge 
(RAU) at the customs cordon  Provision to be made for the elimination of the RAU in the 2024 Finance Law  First quarter of 2025  
 
(c) Trade facilitation   
Subject  Action to be taken  Time -frame  
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  Fourth quarter of 
2023  
Consultations  Provide for regular consultations between border agencies and traders or other stakeholders located 
within its territory (Article  2.2) Fourth quarter of 
2023 
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 operations and reducing and simplifying requirements (A rticle 10.1)  Fourth quarter of 
2023 
Appeal or review  Establish a legal system of administrative or judicial appeal or review so that any person subject to 
an administrative decision is entitled to a revision and correction, on an impartial and independent  
basis, with regard to decisions handed down by the customs authority (Article 4)  Fourth quarter of 
2023 
Processing before arrival  Adopt or maintain a mechanism enabling the trader to submit important documentation prior to the 
arrival of goods (Article 7 .1) Fourth quarter of 
2023 
Electronic payment  Establishment of a mechanism allowing traders the option of electronic payment for duties, taxes, 
fees and charges (Article  7.2) Fourth quarter of 
2023 
Authorized operator  Create a fair system that rewards re spect for the rules and establish additional trade facilitation 
measures for selected operators (Article  7.7) Fourth quarter of 
2023 
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)  Fourth quarter of 
2023  WT/ACC/COM/23/Rev.5  
 
- 11 - Subject  Action to be taken  Time -frame  
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.  Fourth quarter of 
2023  
Penalties  Ensure that penalty me asures 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 establishing them  Fourth quarte r of 
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) Fourth quarter of 
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 and charges (Article 7.3)  Fourth quarter of 
2023 
 
   WT/ACC/COM/23/Rev.5  
 
- 12 - 4. TBT-RELATED MEASURES    
A. Measures during the accession process  
Description  Action to be taken  Time -frame  
Establishment of the Comorian Standardization Office  1. Recruitment of a consultant  
2. Submission of a memorandum to the Council of Ministers for approval  
3. Preparation of a draft decree of establishment  1-3: quarter of 2023  
B. Measures after accession  
Description  Action to be taken  Time -frame  
Capacity building for quality infrastructure  Training on:  
− Metrology  
− Standardization  
− English language (language study programme)  2023-2024 
 
 
5. MEASURES RELATED TO THE FOREIGN TRADE REGIME   
A. Measures during the accession process  
Description  Action to be taken  Time -frame  
Implementation of the Law on foreign trade  1. Preparation of implementing texts  
2. Training of personnel and organization of services concerned  
3. Implementation of the law by the relevant services  
4. Notification of the law and its implementing texts to the WTO  2022-2023 
 
__________