WT/REG391/2  
 
27 March 2019  
(19-1793) Page: 1/9 
Committee on Regional Trade Agreements  Original: English/Spanish  
 
FREE TRADE  AGREEMENT BETWEEN CHINA  AND GEORGIA  
(GOODS AND SERVICES)  
QUESTIONS AND REPLIE S 
 The following communication, dated 21 March 2019 , is being circulated at the request of the 
delegations of  China and Georgia . 
 
_______________  
 
 
Questions from the  delegation of Ecuador  
 
Bilateral safeguards  
1.1.  Paragraph 3.31 indicates that a safeguard measure may not be maintained or applied 
for a period exceeding one year but may be extended by one year if the authorities 
determine that the measure continues to be ne cessary and will facilitate adjustment of 
the industry. It also indicates that the measure shall terminate at the end of the 
transitional period.  
Could you please explain how the transitional period is defined? If a measure is 
extended, how is it demonstra ted that the industry is adjusting?  
Joint Response from the Parties  
 
 According to Article 7.4.1, transitional perio d of the transitional safeguard measure shall be a 
period not exceeding three years  from the entry into force of the Agreement (the year of 2018). 
Neither Party may apply or maintain a transitional safeguard measure for a period exce eding one 
year, except that the period may be extended by up to one yea r, if the competent authorities 
determine, in conformity with the procedures set out in sect ion B (Trans itional  Safeguard Measures) 
of Chapter 7, that the  transitional safeguard measure continues to be necessary to prevent or 
remedy s erious injury and to facilitate adjustment and that there is evidence that the industry is 
adjusting , in line with  Article 7.4.2 (b). Evidence for industry adjusti ng usually  includes , but not  
limited to,  industry adjusting plans, implementa tion status of adjusting plans and inputs for technical 
reformations.  
 
Anti-dumping and countervailing measures  
1.2.  Article 7.1.3 pro vides that neither Party shall use a methodology based on a 
surrogate value of a third country for the purpose of determining normal value when 
calculat ing a dumping margin in an anti -dumping investigation.  
Will no type of analysis be carried out with respect to a product under investigation 
in order to determine whether the prices can be used to determine normal value?  
Joint Response from the Parties  
 
 According to Article 7.1.1, both Parties will i nitiate anti -dumping measures in line with the 
Agreement on Implementati on of Article VI of the General  Agreement on Tariffs and Trade 1994 
(GATT 1994) contained in  Annex 1 A to the WTO Agreement, and product investigation will be carried WT/REG391/2  
 
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  out. H owever, neither Party shall use a methodology base d on sur rogate value of a third country for 
the purpose of determining normal  value when calculating dumping margin in an anti -dumping 
investigation.  
 
Regulatory provisions on trade in goods  
 
Customs -related procedures  
 
1.3.  According to paragraph 3.39, "[…] The Partie s agreed to use efficient customs 
procedures, based as appropriate on international standards aiming to reduce costs and 
unnecessary delays in trade between them, in particular the recommended practices of 
the World Customs Organization. And the revised In ternational Convention on the 
Simplification and Harmonization of Customs Procedures (revised Kyoto Convention) 
(Article 4.3.2). Each Party shall limit controls, formalities and the number of documents 
required in the context of trade in goods between the Parties to those necessary and 
appropriate to ensure compliance with legal requirements in order to simplify procedures 
to the greatest extent possible (Article 4.3.3). Article  4.3.4 provides that the customs 
administration of each Party shall periodically  review its customs procedures with a view 
to exploring options for the simplification and enhancement of mutually beneficial 
arrangements to facilitate international trade". […]  
At what intervals will the periodic reviews of the Parties' customs procedures be 
carried out? Do both Parties have a road map for setting short -, medium - and long -term 
goals for improving their customs processes?  
Joint Response from the Parties  
 
 Periodic reviews and roadmaps have bee n incorporated in comprehensive reform  efforts and 
trade facilitation efforts by China 's General Administration of Customs (GACC). Full implementation 
of the Trade Facilitation Agreement (TFA) is one of GACC 's most important tasks during the  period  
of the  13th Five-year Plan. GACC  is currently  making  all efforts in integrating customs procedur es 
nationwide, streamlining  and optimizing administration, pushing forward single -window  
establishment. According to the Doing Business Report 2019  issued by the  World Bank, China 's 
business environment in dex ranked 65th worldwide, up from the previous  rank of 97th. In 2018, 
Entry -exit Administration of Inspection and Quarantine  was integrated into GACC, which has greatly 
simplifie d and optimize d customs  procedures.  
 
 Georgia Revenue Service (GRS) (United Tax and Customs Administration) maintains a 
continuous review and update system for all customs -related procedures applicable to foreign trade. 
There is an Advisory Board set -up under the Customs Department of the GRS, composed of 
representatives of the pr ivate sector, various business associations, SMEs and other relevant 
stakeholders as well. The board meets to discuss any and all outstanding issues existing with the 
customs/clearance procedures applicable in the state and provides recommendations.  
 
A Tim e Release Study endorsed by the World Customs Organization is carried out on biennial 
basis and entails measuring of the time spend for goods from their initial arrival at the customs 
crossing points to their final release. The study is designed to help cu stoms administrations identify 
bottlenecks and other types of obstacles along the chain of customs procedures. Based on the 
findings GRS initiates a revision process targeted at resolving of the issues if any and striving to 
further facilitate and streamli ne procedures wherever possible.  
 
 In 2018 Georgia acceded to the revised International Convention on the Simplification and 
Harmonization of Customs Procedures (revised Kyoto Convention) and proper implementation of the 
Convention is one of the top priori ties of the GRS.  
 
 In 2018 an internal working group was set up within the GRS with a mandate to review 
international rankings/indexes and reports evaluating the performance of customs procedures in the 
country with the purpose to produce suggestions and r ecommendations designed to improve the 
efficiency and overall standing in these instruments.  
 WT/REG391/2  
 
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  From this year a newly formed National Committee on Trade Facilitation begins its work. The 
Committee is established in accordance to Article 23.2 of the WTO Trade Facilitation Agreement. In 
its work the Committee will coordinate all of the trade facilitat ion related activities including the 
revision of customs related procedures.  
 
1.4.  According to paragraph 3.45, "[…] The Parties shall provide importers, exporters or 
any other person affected by administrative decisions on a customs matter with access to 
an ad ministrative level review of decisions by its customs authorities, and a judicial 
review of decisions subject to its laws and regulations (Article  4.9)". […]  
How will the administrative and judicial reviews of customs authority decisions be 
carried out and  what time -frames have been established for receiving a ruling ? 
Joint Response from the Parties  
 
 For China, w here a citizen, juristic person or any other organization believes  that a specific  
GACC administrative act has infringed his/her/its  legitimate rights or interests, he/she/it may, within 
60 days as from  the day when he/she/it becomes aware of the act, apply for  administrative 
reconsideration . GACC administrative  reconsideration authorities shall, in performing the functions 
of administr ative reconsideration, follow the principles of legitimacy,  impartiality , transparency, 
timeliness and convenience for the people,  adhere to administration by law , and make corrections 
whenever  mistakes occur, so as to ensure the correct implementation of laws, administrative 
regulations and GACC rules.  The GACC administrative reconsideration authority shall make an  
administrative reconsideration decision within 60 days as from the  date of acceptance of an 
application. However, under any of the  following circumstances, the time -limit may be extended by 
30 days  upon approval by the person -in-charge of the GACC administrative reconsideration 
authority:  
 
a. The administrative reconsideration case is a major one, the  circumstances of the case are 
complicated and it  is hard to make a decision;  
b. It is decided that an administrative reconsideration hearing will  be held;  
c. The applicant has agreed to extend the time -limit;  
d. A third party is a participant in the administrative  reconsideration; or  
e. The applicant or a third  party concerned has presented new facts  or evidence, which 
require further investigation.  
 Further details are provided in GACC Rules on Administrative  Reconsideration , the draft 
translation of  which can be found at:  
 http://english.customs.gov.cn/Statics/810e0842 -3409-42b5-803b-5bf7e2c441ae.html  
 
 For judicial reviews, details are provided in the Administrative Procedure Law of China , revised 
in 2017, the Chine se text of which  can be found at : 
http://www.gov.cn/xinwen/2017 -07/05/content_5243206.htm .  
 
 For Georgia , it provides two tier appeal system within the structure of the Ministry of Finance:  
 
 - Dispute resolution board of the GRS  
 - Dispute resolution board under the Ministry of Finance  
 
 All Decisions can also be appealed in courts of Georgia. An appeal needs to be made within 
the 30 -day time -period after the initial receipt of the ruling to which the appeal applies to. The 
time-frame can be extended beyond provided previously unbeknown information or circumstances 
have been brought to light influencing the outcome of the ruling.  
 
 The appeal needs to be presented in a written or ele ctronic form at : 
 https://eservices.rs.ge/Login.aspx?redirect_url=https://eservices.rs.ge/Login.aspx    WT/REG391/2  
 
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   The application will be reviewed in a 20 -day time-frame, this time may be suspended if 
additional documentation is required or if new evidence have been discovered. Decision of the 
Revenue Service can be appealed with the Dispute resolution board under the Ministry of Finance 
within the 20 -day time -period of the ruling.  
 
Sector Specific Commitments  
 
China  
 
1.5.  According to paragraph 4.21, China's FTA commitments on services (in positive list 
format) very closely mirror its GATS commitments, minus several original limitations that 
were time -bound upon acc ession and have expired.  
 Could you please indicate whether those exclusions relate to China's WTO Accession 
Protocol, what they are and how they would apply in the context of the Trade Agreement 
with Georgia and with respect to non -preferential trade rela tions ? 
Joint Response from the Parties  
 
 China made  high-level commitments in trad e in services upon accession to the WTO in 2001, 
opening up 100 sub -sectors of 9 sectors, approaching the  average  level of the commitments of 
108 sub-sectors by developed economies . China 's commitments under GATS are applicable to all 
WTO members, including Georgia.  In China -Georgia FTA, both sides have sec ured higher level 
achievements. China and Georgia made market access commitments on several specific sectors and 
reache d consensus on Financia l Services, Movement of Natural Persons, Transport and Related 
Services, a nd Traditional Chinese Medicine Services.  
 
Other  
 
Electronic Commerce  
 
1.6.  Paragraph  5.27 states that, in Chapter 12 (Areas of Cooperation), Article 12.2, the 
Parties recognize the economic growth and opportunity provided by electronic commerce, 
the importance of promoting its use and development and the applicability of the 
WTO  Agreement to measures affecting electronic commerce (Article 12.2.1), and agree to 
share information and experience on issues related to electronic commerce, including, 
inter  alia, laws and regulations, rules and standards and best practices.  
 What is meant by the reference to the applicability of the WTO Agreement in relation 
to measures  affecting electronic commerce? Have those measures been identified or listed 
and, if so, could you please explain how the measures affect electronic commerce 
(if possible, by providing an example)?  
Joint Response from the Parties  
 
 In light of the complex ity and cross -cutting  nature of electronic commerce, GATT 1994, GATS, 
TRIPS and other WTO Agreements are applicable  to measures affecting e -commerce. Fo r example, 
along with the rapid development of e -commerce globally, transacti ng parties located in diffe rent 
customs territories increasingly conclude transac tions through electronic means, and then process 
payment, logistics and other business processes. T he whole process and related measures facilitate 
cross-border e -commerce an d is inseparable with trade in goods, trade in services, and even 
intellectual property rights .  
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  Questions from the delegation of Mexico  
 
Provisions on trade in services  
Sector specific provisions on trade in services  
Telecommunication services  
1.7.  Paragraph 4.48: China's Schedule of Concessions and Com mitments in Services in 
Annex 8 -E to the Agreement attaches the Telecoms Reference paper as well as Notes for 
Scheduling Basic Telecommunications Commitments (S/GBT/W/2/Rev.1) and the 
Chairman's Note on Market Access Limitations on Spect rum Availability (S/GBT/W/3). 
Those documents are not attached to Georgia's Schedule of Concessions and 
Commitments in Services in Annex 8 -F of the Agreement.  
What market access limitations has China set with respect to radio spectrum 
availability ? 
Joint R esponse from the Parties  
 
 China 's commitments on the allocation and u se of radio spectrum follow the requirements of 
the Reference Paper (Attachment 1)  for basic telecommunications services, the requirements of 
Article 6 of Allocation and  Use of Scarce Re sources  in particular.  
 
General provisions of the Agreement  
Other  
Competition  
1.8.  Paragraph 5.25:  In Chapter 10 of the Agreement the Parties have agreed disciplines 
on competition. Anti -competitive business practices means business activities or 
transactions that are incompatible with the proper functioning of the Agreement insofar 
as they may affect trade between the Parties (Article 10.2.1). Each Party agrees to 
maintain or adopt competition laws that promote and protect the competitive process in 
its market  by proscribing anti -competitive business practices (Article 10.3.1). Each Party 
agrees to be transparent, non -discriminatory and procedurally fair in the enforcement of 
competition law (Article 10.4.1) and to ensure that during an investigation to determi ne 
whether conduct violates its competition law, or before it imposes a sanction or remedy 
against a person a reasonable opportunity to present opinion or evidence in its defence 
(Article 10.4.3).  
What are the anti -competitive business practices set out in  the agreement to be 
applied by both Parties ? 
Joint Response from the Parties  
 
 Anti-competitive business practices have been clearly defined by Article 10.2 of Definitions , 
Chapter 10 of  Competition . Both  parties have identified 3 scenarios, which are the  most common  
situations  among all economies: (a) agreements  between enterprises, decisions by association s of 
enterprises, and  concerted  practices, which have as their object or effect the prevention,  restriction, 
or distortion of competition in the territ ory of either Party as a whole  or in a  substantial part thereof; 
(b) any abuse by one or  more enterprises of a  dominant  position in the territory of either Party as a 
whole or  in a substantial  part thereof;  or (c) concentrations between enterprises, wh ich significantly  
impede  effective competition, in particular as a result of t he creation or  strengthening of  a dominant 
position in the terri tory of either Party as a whole  or in a substantial  part thereof.   
 
1.9.  Paragraph 5.26: The Parties have also agreed to ma ke public their laws, regulations, 
guidelines on competition and any rules issued in relation to the administration of such 
(Article 10.5.1). Confidential information shall be protected (Article 10.7.2). Competition 
authorities are required to be independe nt (Article 10.9). The Parties agree to address 
specific matters under the Chapter through consultations as required (Article 10.11). 
Dispute settlement under the Agreement is not available for matters covered by the 
Chapter (Article 10.10).  WT/REG391/2  
 
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  Currently, wha t are the Parties' independent competition authorities and how do 
they coordinate with the regulatory authorities for the telecommunications and 
broadcasting sectors ? 
Joint Response from the Parties  
 
 According to China 's Anti -monopoly Law and authorizatio n by the State Council, State 
Administration for Market Regulation  (SAMR) is China 's competent  authority responsible for 
anti-monopoly enforcement . For anti-monopoly administration in sectors of telecommunication and  
broadcasting,  SAMR  will consult related regulatory  authorities in its enforcement.  
 
 Independent competition authority in terms of in Georgia is Competition Agency of Georgia, 
which was established in 2014 on the legal basis of Georgian Law on Competition. The Agency is 
accountable to the Prime Minister of Georgia and is independent in its activities and decision -making 
process.  
 
 Article 3 (q) of Georgian Law on Competition defines regulated sectors of economy, under 
which also falls telecommunications and broadcasting se ctor. Relevant authority in sphere of 
telecommunications and broadcasting is Georgian National Communications Commission.  According 
Chapter VI of Georgian Law on Competition, Competition Agency cooperates with relevant regulatory 
authorities of a regulated  sector. If a complaint regarding an alleged distortion of competition in a 
regulated sector of the economy is submitted to the Agency, the  Agency shall forward this complaint 
to the regulatory authority of the relevant regulated sector of the economy. Fur ther forms of 
cooperation are defined in the Article 31 of Georgian Law on Competition, as well as in MoU which 
was signed between Competition Agency of Georgia and Georgian National Communications 
Commission in 2017.  
 
Questions from the delegation of Thailand  
 
Transport services  
 
1.10.   Paragraph 4.30: China permits qualified maritime service suppliers of Georgia to 
establish wholly Georgian -owned ship management enterprises in the China (Shanghai) 
Pilot Free Trade Zone (Shanghai FTZ).  
a. Apart from the improvement on the commitment in respect of Maritime 
Transport, are there any other commitments improved by the use of the China 
(Shanghai) Pilot Free Trade Zone (Shanghai FTZ)?  
Joint Response from the Parties  
 
 China actively promotes the practices and experiences of the opening -up policy in China 
(Shanghai) Pilot Free Trade Zone (Shanghai FTZ), and  makes further commitments in the fields of 
Legal Services and Travel  Agency and Tour Operator, apart from the Maritime Services. For Legal 
Services, Georgian law firms , which have established their representative offices in the Shanghai 
FTZ may enter into contracts with Chinese law firms within the Shanghai FTZ, or may form a 
commercial association with Chinese law firms in the Shanghai FTZ.  For Travel Agency and Tour 
Operator, China -Georgia joint venture travel agencies and tour operators that have been registered 
and established in the Shanghai FTZ may engage in the activities of Chinese traveling abroad and 
to Hong Kong, China and Macao, China,  provided that these China -Georgia joint venture travel 
agencies and tour operators have met relevant requirements.  
 
b. What are the targeted sectors of creating the China (Shanghai) Pilot Free Trade 
Zone (Shanghai FTZ)? What are the differences of the requir ement of business 
registration in Shanghai FTZ and other areas in China?  
Joint Response from the Parties  
 
 Shanghai FTZ has promote d the opening up of service sectors, such as financial services,  
telecommunications, internet, culture, cultural relics, main tenance and repair, shipping services and 
advanced manufacturing industries , by ways of  further eas ing the limitations on investment market WT/REG391/2  
 
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  access,  aiming at  the highest international standard, and shortening the  negative list for foreign 
investment within  the Shanghai FTZ . 
 
China has adopted negative -list approach on foreign investment  administration nationwide 
since 1 October 2016. For those  foreign -investment enterprises not subject to access administration, 
their establishment and change would be realized through only filling for record  and no longer need 
to be examined and approved. Besides, enterprises  established in Shanghai FTZ will benefit from  a 
set of processing procedures  that are more streamlined and convenient.  
 
Other services sectors  
 
1.11.   Paragraph 4.37: For other sectors (construction and related engineering services; 
distribution services; environmental services; financial services; health related and social 
services; and recreational and cultural and sporting services), Georgia replicates  its 
GATS  commitments.   
 According to environmental services, what are the limitations or the reservation in 
both sides of the liberalizations of environmental services?   
 
Joint Response from the Parties  
 
 China has made market access commitments on Sewage  Services, Solid Waste Disposal 
Services, Cleaning Services of Exhaust Gases, Noise Abatement Services, Nature and Landscape 
Protection Services, Other Environmental Protection Services, and Sanitation Services, and has 
provided national treatment to forei gn-service suppliers. To be specific,  foreign -service suppliers 
engaged in environment services are permitted to  provide services only in the form of joint ventures, 
with foreign majority  ownership permitted. For Mode 1, no commitment is made except for  
environmental consultation services. For Mode 2, there is no restriction. For  Mode 4, no commitment 
has been made except horizontal commitments.   
 
 For environmental services, Georgia made market access and National treatment 
commitments on Sewage services , Refuse disposal services, Sanitation and similar services, 
Cleaning services of exhaust gases, Noise abatement services, Other nature and landscape 
protection services and Other environmental protection services. For Mode 1, no commitment is 
made other t han consulting and advisory services, except for other environmental protection 
services (CPC 9409) where Mode 1 is fully liberalised. Establishment in all committed sub -sectors is 
fully liberalised. For  Mode 4, no commitment has been made except horizonta l commitments.  
 
Investment  
1.12.   Paragraph 4.44: Article 12.1 of Chapter 12 on Areas of Cooperation between the 
Parties concerns Investment. It provides that each other Party shall, subject to its general 
policy on foreign investment, promote investments of the other Party and shall admit such 
investmen t in accordance with its applicable laws and regulations and the international 
commitments entered into between the Parties.  
 Regarding Areas of Cooperation between the Parties concerns Investment, what are 
the current and the direction for the future poli cy on foreign investment of each Party? 
How do those policies reflex the cooperation between the Parties? Please elaborate and 
provide us examples.  
 
Joint Response from the Parties  
 
 China 's Law on Foreign Investment , which  will enter into force on 1 January  2020,  will adopt 
the administration model of pre -establishment national  treatment plus negative list. For those 
foreign -invested enterprises not subject to  access administration, their establishment and changes 
would be realized by  only filing for record, instead of the examination and approval system. The  
negative list is to be published nationwide and, as part of China 's Law on  Foreign Investment , is 
binding, thus providing legal protection for foreign  investors. Georgia can  receive better treatme nt, 
according to Chapter 12 on  Areas of  Cooperatio n which e nsure s Georgia 's investors ' rights under 
China 's Law on  Foreign Investment . Meanwhile, the Parties will further assess and, if  necessary,  WT/REG391/2  
 
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  endeavor to conduct negotiations with a view to revising the Agreement  between the Government 
of the People 's Republic of China and the  Government of the Republic of Georgia Concerning the 
Encouragement and  Reciprocal Protection of Investments (in force since 1995) . 
 
 The Law of Georgia on Investment Activity Promotion and Guarantees, which has been in 
place since 1996, defines the legal basis for realizing both foreign and local investments and their 
protection guarantees in the Georgian territory. The purpose of the Law is to establish an 
investment -promoting  regime. The Law secures equal treatment and rights for Georgians and foreign 
investors.  
 
 Aiming to further optimize procedures necessary for investing and entrepreneurial activities, 
the Law on State Support to Investments was adopted in 2006. This law d efines the Legal Entity of 
Public Law - Produce in Georgia, as the representative of Government of Georgia in the field of 
investment support. The Investment Division of the Agency acts as the moderator between foreign 
investors and the Government of Georg ia, ensuring access to updated information, an efficient 
means of communication with Government bodies, and functioning as a "one-stop-shop" that 
supports investors throughout the investment process.  
 
 In addition to the existing horizontal legal framewor k, Georgia has signed bilateral investment 
promotion and protection agreements with 33 countries.  
 
Table 4.4 China: Sector -specific liberalization under the Agreement, excluding mode 4 and 
horizontal limitations  
1.13.   4. Distribution service (D. Franchising), China indicated that this sector has full 
GATS Sectoral Commitments.  
 Please elaborate the "full" sectoral commitments under GATS in the distribution 
service (Franchising). Does it mean that foreign companies can own 100% share in 
franchising sector and there are no other Market Access and National Treatment 
limitations for this sub sector?  
 
Joint Re sponse from the Parties  
 
 China has made full commitment s in respect of Franchising Services. Georgian service 
suppliers are allowed to establish wholly foreign -owned subsidiaries and branches without any equity 
restriction, while receiving  national treatm ent.  
 
Financial services  
1.14.   Paragraph 4.46: On regulatory transparency, the Parties recognize that transparent 
measures governing the activities of financial service suppliers are important to facilitate 
access to each other 's market, each Party shall ensure  that measures of general 
application adopted or maintained by a Party are promptly published or otherwise 
generally made available. Article 6 requires that arbitrators on an arbitral tribunal 
established in accordance with Article 15 (Dispute Settlement) shall have the necessary 
expertise relevant to the specific financial service under dispute.  
a. According to transparent measures governing the activities of financial service 
suppliers, what are the measures and how do they regulate in a way that can 
ensure the transparency? Would they somehow be obstacles in operating 
financial services?  
Joint Res ponse from the Parties  
 
 Financial Services is one of the key areas of coo peration between two sides, and a Financial 
Services Annex is set out under the Chapter 8 of Trade in Services . With respect to transparency, 
Article 5 of Regulatory Transparency  stipulates the specific obligations of both sides on transparency. 
Meanwhile, Article 3 of Domestic Regulation  ensures that both Parties reserve their regulatory  policy 
spaces while fulfilling  transparency obligations.  
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  b. According to Article 6 and Article  15, what are the requirements of arbitrators 
and how can "necessary expertise relevant to the specific financial service under 
dispute " be assessed . 
Joint Response from the Parties  
 
 The qualifications and requirements of arbitrators are set out in para 6 , Article  6, Chapter 15 
of Dispute Settlement . Regarding "necessary expertise ", no concrete definition or explanation is 
provided in the Agreement. I t is usually  to be assessed according to the situation of the specific 
dispute.  
 
Tourism and related services  
1.15.   For tourism and related services, with respect to hotels and restaurants, China has 
removed a qualification to the mode 4 commitment under the GATS, concerning foreign 
managers, specialists, chef and senior executives need to have signed a contrac t with a 
joint venture hotel and restaurants.  
Does this condition apply to all provinces in China?  
 
Joint Response from the Parties  
 
 In respect of Hotels and Restaurants, China 's commitments are applicable to all provinces 
in China.  
 
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