. /.   WORLD TRADE  
ORGANIZATION  G/TBT/W/293 
28 October 2008 
 (08-5227) 
Committee on Technical Barriers to Trade Original:   English 
  
 
TRANSITIONAL REVIEW MECHANISM IN CONNECTION WITH PARAGRAPH 18  
OF THE PROTOCOL ON THE ACCESSION OF THE PEOPLE’S REPUBLIC OF CHINA 
 
Questions and Comments from Japan to China
 
 
 
 The following communication, dated 27 October 2008, is being circulated at the request of the delegation of Japan
. 
 
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I. CONFORMITY ASSESSMENT 
1. Conformity assessment bodies ("CAB") of foreign countries have not been allowed to engage 
in certification activity in China according to Artic le 9 and Article 13 of the regulations of the 
People's Republic of China on Certification a nd Accreditation, permitting only Chinese CABs to 
conduct such activities.  No foreign CAB has yet b een allowed to engage in certification activities 
under the CCC system.  Pursuant to the provision  in Article 6.4 of the TBT Agreement and the 
commitment in Paragraph 195 of the Report of the Working Party on the Accession of China, Japan would like to request that local foreign-owned CABs, as well as foreign-based CABs, engage in 
certification activities under the CCC system without discrimination. 
II. THE ADMINISTRATION OF THE CONTROL OF POLLUTION CAUSED BY 
ELECTRONIC INFORMATION PRODUCTS 
2. Article 3.3.4 of the Regulation prohibits "the  import of electronic and information products 
that do not meet the national or industrial sta ndards pertaining to the restriction of hazardous 
substances in electronic and information products".   As it is difficult for Japanese companies to 
understand from this text which are the standards that  must be met, Japan requests China to specify 
and provide a list of the standards referred to in this article. 
3. At the last TRM session, China replied that they  are preparing the test standard and if the 
future IEC standard would be practical for China, they would follow that standard.  Japan requests 
China to make the objects of the standard clear a nd promote it adequately according to Article 2.4 of 
the TBT Agreement which requires Members to use relevant international standards as a basis for 
their technical regulations. 
III. CHINA’S REGISTRATION SYSTEM FOR ENVIRONMENTAL MANAGEMENT 
ON THE IMPORT AND EXPORT OF TOXIC CHEMICALS 
4. Japan has continuing concerns regarding this issue. The Chinese State Environment 
Protection Agency (SEPA) released a revision of "Highly Restricted Imported and Exported Toxic 
Chemicals" on 28 December 2005, putting it into effect on 1 January 2006.  A total of 158 chemicals 
were newly added to the revised list of toxic chem icals, some of which are widely used in the G/TBT/W/293 
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  chemical industry.  The "Regulations System for Environmental Management in the Initial Imports of 
Chemical Products and the Import and Export of  Toxic Chemicals" (the "System") requires 
companies to pay US$10,000 to SEPA in order to ob tain a Registration Certificate for exporting to 
China the chemicals on the list. 
5. The Registration Certificate is valid for two y ears per contract. Japan asked how China would 
deal with the "System" after the expiration of the two-year period.  At the last TRM session, China 
replied that stakeholders from abroad could partic ipate in the revising process.  At the last TBT 
meeting held in July 2008, China answered that this pr ocess is still under review. We would like to 
know the status of the revision. 
 
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