G/TBT/W/413  
 
1 June 2015  
(15-2906)  Page: 1/3  
Committee on Technical Barriers to Trade  Original: English  
 
  TRANSPARENCY 
SEVENTH TRIENNIAL REVIEW 
Submission from Japan  
 The following submission, dated 1 June 2015, is being circulated at the request of the 
delegation of Japan. 
 
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1  BACKGROUND 
1.1.  Ensuring transparency during preparation of  technical regulations, standards and conformity 
assessment procedures is a fundamental pillar in the implementation of the TBT Agreement.1 The 
TBT Committee has been progressively discussing this matter such as the encouragement of 
utilizing websites in view of providing information in a more timely manner.  
1.2.  The Committee has especially developed a considerable discussion on the preparation of 
technical regulations and conformity assessment procedures.2 Enhancing the function of WTO 
websites (e.g., the TBT IMS and the TBT NSS) promotes providing information via the Internet and facilitates Members' use of information about TBT notifications of technical regulations and 
conformity assessment procedures. 
1.3.  On the other hand, on the preparation of standards, although the effectiveness of utilizing 
the Internet has been well-recognized in the TBT Committee
3, the discussion and provision of 
information via the Internet have not progressed sufficiently. 
1.2  Work programme  
1.4.  Article 4.1 of the TBT Agreement provides  that Members shall ensure that their central 
government standardizing bodies accept and comply with the Code of Good Practice in Annex 3 to 
the Agreement. Paragraph J of the Code of Good Practice stipulates that the standardizing body 
shall publish a work programme for standards at least once every six months and notify the existence thereof to the ISO/IEC Information Centre, containing information of how and where the 
publication in which the work programme is published can be obtained. On the operational aspect, 
the ISO/IEC Information Centre publishes via the Internet the WTO TBT Standards Code Directory which is the list of such information from each Member.
4 In addition, in past Triennial Reviews the 
Committee agreed to encourage standardizing bodies that communicate their work programmes 
via the Internet to specify the exact web pages where the information on work programmes is 
located under the item "Publication" of the notification form.5 
1.5.  However, in many cases, with respect to the information about the central government 
standardizing bodies notified to the ISO/IEC Information Centre, the webpages addresses where 
                                               
1 G/TBT/1/Rev.12, 4.1, Recommendation (a). 
2 G/TBT/1/Rev.12, 4.3.1.3, Recommendations (e), 4.3. 1.7, Recommendations (b)(iii), (c)(ii) and (iii),  
(d)(iii) and (iv), 4.4.2, Recommendations (a) and (b), 4.4.4, 4.10 and 4.12. 
3 G/TBT/1/Rev.12, 4.3.2.2, Decision (a), Recommendations (b)(ii), 4.3.2.3, Recommendation (b). 
4 The WTO TBT Standards Code Di rectory may be downloaded at 
http://www.standardsinfo.net/info/inttrade.html . 
5 G/TBT/1/Rev.12, 4.3.2.2, Recommendations (b)(ii). G/TBT/W/413 
 
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  the work programmes are supposed to be located indicates only the top pages addresses of the 
websites of the central government standardizing bodies. Such a situation often makes it difficult or takes much time to access the specific website address where the work programme is posted. It is difficult to say that the environment has been fully established so that Members can obtain 
quickly and easily information on the preparation of standards of other Members. 
1.6.  Therefore, during preparation of standards by the central government standardizing bodies, it 
is important to encourage them to publish their work programmes on websites and also to notify 
the specific website addresses where the programm es are posted (not the top pages addresses of 
their websites) to the ISO/IEC Information Centre. Japan believes that this enables Members to access the information on the work programmes timely and easily. 
1.3  Submission of comments on draft standards  
1.7.  Regarding the submission of comments on a draft standard, paragraph L of the Code of Good 
Practice provides that no later than at the start of the comment period, the standardizing body shall publish a notice announcing the period for commenting in the publication referred to in 
paragraph J. Furthermore, paragraph M states that  on the request of any interested party within 
the territory of a Member of the WTO, the standard izing body shall promptly provide, or arrange to 
provide, a copy of the draft standard which it has submitted for comments. From the operational 
aspect, the Committee agreed in the past Triennial  Reviews that the electronic publication of 
notices announcing the periods for comments can constitute another possibility for the fulfilment of the transparency obligation
6. 
1.8.  However, in contrast to publication of work programmes, the Code of Good Practice does not 
stipulate the way of providing the information regarding the publication of a notice announcing the 
period for commenting, such as the name of th e publication and how and where the publication 
can be obtained. For this reason, such information of each Member has not been sufficiently 
shared among Members. Consequently, even when a notice announcing the period for commenting 
is published somewhere, interested Members or industries cannot realize the existence of the notice and would lose the opportunity of submitting comments. In addition, paragraph L provides 
that the standardizing body shall allow a period  of at least 60 days for the submission of 
comments on the draft standard. However, if the ab ove publication or the copy of the draft is in 
print media, it would take time for interested parties to obtain them. 
1.9.  Therefore, regarding preparation of standa rds by central government standardizing bodies, 
from the aspect of enhancing the transparency, it is effective to encourage Members to discuss 
and find appropriate ways to share the information among Members about the publication in which a notice announcing the period for commenting on the draft standard is published. Utilizing the 
ISO/IEC Information Centre may be one of the possi bilities. Furthermore, it is also effective to 
encourage the central government standardizing bo dies to provide the said publication via the 
Internet and to make the draft standard which is submitted for comments available for browsing 
electronically on the above publication. 
2  PROPOSALS 2.1.  From the background as above, regard ing preparation of standards by the central 
government standardizing bodies, Japan would like to propose the following. 
2.2.  With regard to work programmes: 
a. the Committee encourages Member’s central government standardizing bodies: 
i. to publish their work programmes on websites and  
ii. to notify to the ISO/IEC Information Centre the specific website addresses where the 
work programmes are posted  
                                               
6 G/TBT/1/Rev.12, 4.3.2.3, Recommendations (b). G/TBT/W/413 
 
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  2.3.  With regard to submission of comments on a draft standard by Member’s central government 
standardizing bodies:  
a. the Committee encourages Members to discuss how to share the information among 
Members about the publication of a notice announcing the period for commenting on the 
draft standard, and 
b. the Committee encourages the central government standardizing bodies: 
i. to provide the publication referred to in para. 12.(a) via the Internet; and 
ii. to make the draft standard which is submitted for comments available for browsing 
electronically on the above publication. 
3  BENEFIT FROM THIS PROPOSAL 3.1.  In the context of the global spread of the Internet and its convenience as a tool for sharing 
information, information disclosure via the Internet is becoming easier and more important. Japan 
believes this proposal contributes to the enhancement of the transparency during preparation of standards. 
 
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