WORLD TRADE  
ORGANIZATION   
TN/TF/W/177 
21 May 2012  
 
(12-2681) 
Negotiating Group on Trade Facilitation  
  
 
SUMMARY OF WTO TRADE FACILITATION 
NEEDS ASSESSMENTS RESULTS 
  
Note by the Secretariat 
 
 
The WTO trade facilitation needs assessment pr oject was conducted between September 2007 
and December 2010.  During the life of the project  the WTO Secretariat oversaw the implementation 
of 94 national self-assessments in 60 developing countries and 34 least-developed countries.  The 
project was funded by nine WTO Members th rough the WTO Trade Facilitation Trust Fund.  
Additional support was provided in the form of 76 expert facilitators who were provided by 
23 organizations or national administrations . (See attached Chart of Needs Assessment 
Implementation by Date in Annex I and Chart of Implementation Information by Country in 
Annex II).1 
 
For the information of Members the Secretariat has prepared a consolidation of the findings 
of the needs assessments results that were provided to it.  These results are only indicative and do not 
reflect individual assessments, but rather provide an aggregate overview of the results. The individual 
results are the property of the country and have been he ld in the strictest confidence by the Secretariat.   
 Compliance Levels: 
 
The first version of the Needs Assessment Guid e contained 70 proposed trade facilitation 
measures.  As proposals were streamlined the guide w as revised two times to reflect the changes.  The 
last version of the Guide was issued in early 2009 and contained approximately 45 measures.   Thirty-three countries conducted their Needs Assessments in 2009 using that Guide.  Statistics from this year 
were used for the chart below to show the averag e levels of compliance.  (Only 6 assessments were 
conducted in 2010.)  
The statistics from 2009 show that an av erage of 39 measures were assessed
2.  On average 
Member and observer countries complied with 35% of  proposals, were in partial compliance with 
43%, non-compliant with 17% and 6% of the measu res were found to be not applicable.  These 
figures closely reflect the compliance levels found throughout the duration of the project.  
                                                      
1 In English only. 
2 The final count of measures assessed varied becaus e many measures were assessed together (such as 
publication and publication for transit) , or because some countries did not in clude measures that do not apply to 
them. TN/TF/W/177 
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Compliance level of measures 2009 Average 
Number 2009 
Average % Average % 
2007-2010 
Full compliance 14 35 37 
Partial compliance 17 43 42 
Non compliance 6 17 13 
Not applicable  2 6 6 
Average Total Assessed (many island countries 
did not assess transit issues) 39   
 
Overall Findings:  
The findings of the most common results are summarized below under 3 main topics: 
 
1. Reasons for non-compliance/barriers for implementation of the proposed trade facilitation 
measures 
2. Local remedy/action needed to implement some of the proposed trade facilitation 
measures 
3. Technical assistance and capacity building needs and priorities  
 
1. Reasons for non-compliance/barriers for im plementation of the proposed trade 
facilitation measures 
The main barriers for implementation of the prop osed measures that have been identified in 
the needs assessments can be grouped under five main categories: 
 (i)  Lack of Cooperation/Coordination : all of the assessments undertaken  have depicted a lack of 
cooperation/coordination of some kind, whether it is between two or more government agencies or 
between government agencies and the private sector . The case is most prominent among agencies at 
border posts and/or transit related issues.  Other related barriers in cluded restricted dissemination of 
information and lack of awareness or per ceived need of the proposed measures.  
 
(ii)  Human Resource Constraints:  lack of skilled manpower/technical expertise in customs and 
other government border agencies; lack of planning  and management of human resources; lack of 
tailored and specialized training programs for cu stoms and other border agencies and the private 
sector.  
 
(iii)  Legislation and Policy-related issues:  lack of national legislation for many of the proposed 
trade facilitation measures. In some  cases, the laws exist but no regul ations or procedures have been 
put in place. Additional legislative barriers are rela ted to the adoption, interpretation (ambiguities), 
enforcement and updating of tr ade laws and regulations.  
 (iv)  Institutional-related issues : unclear/overlapping responsib ilities of institutions; overly 
bureaucratic institutional structures; centralization of agencies/institutions in the capital without 
proper dissemination mechanisms for other parts of the country and lack of political will/resistance to change/corruption- e.g. abuse of discretionary power on the part of the implementing agencies. 
 
(v)  Poor Trade-Related Infrastructure: barriers related to poor infrastructure were often 
identified but they were more prominent in the case of the LDCs.  
2. Local remedy/action to help implement some of the proposed trade facilitation measures 
While many of the barriers identified in the previous section would require some form of 
technical assistance and/or capacity building, the sel f-assessments have also identified actions to be  TN/TF/W/177 
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taken on the local/national level. Th ese actions would primarily overcome barriers related to lack of 
cooperation/coordination, legislati on and policy-related issues and institutional related issues.  The 
actions most frequently mentioned in this area are as follows3:  
 
(i) Lack of Cooperation/Coordination: 
 Strengthen inter-institutional coordination through consu ltation among agencies with 
trade-related responsibilities by setting up a national committee/task force on trade facilitation, where it does not already exist.  
 Design administrative and legislative provisions to ensure internal coordination and 
cooperation among border agencies. 
 Improved data gathering, ma nagement & dissemination.  
 Promote the use of information and communication technologies (ICT) as a modern 
method for information transmission. 
 Sensitize key stakeholders on trade facilitation matters. 
 Wider consultation prior to adoption of policies. 
 Promote public-private partnerships. 
 
(ii) Legislation and Policy-related issues: 
 Set up internal units to regularly review a nd update new trade regul ations whether paper-
form (official gazette) or on the relevant websites and databases. 
 Comprehensive review, consolidation and stre amlining of all existing trade related laws 
and regulations. 
 Reform of appeal procedures. 
- Establish adequate mechanism for timely di ssemination of trade laws and procedures. 
- Develop trade and customs procedures and guidelines. 
- Streamline and simplify trade-related documents and procedures. 
 
(iii) Institutional-related issues: 
 Restructure and strengthen various instit utions to focus on trade facilitation. 
 Receive appropriate backing and support from senior management. 
 Strengthen and recruit additional staff. 
 Establish a risk management unit within customs. 
 Establish a customs valuation database. 
 Develop and publish criteria for authorized traders. 
 3. Technical assistance and capacity building needs and priorities  
The technical assistance and capacity build ing (TACB) needs identified in the self-
assessments vary widely depending on the level of  development of each of the countries assessed.  
They range from minimal needs su ch as assistance in setting up awareness workshops/sharing of 
country experiences on publication matters to more complex needs such as the development of ICT 
infrastructure.  A summary of the main TACB priorities identified
4 are as follows: 
 
                                                      
3 This is an illustrative and non-exhaustive list 
4 This is an illustrative and non-exhaustive list 
 TN/TF/W/177 
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(i) Transparency-related needs: 
 Assistance in drafting legislation. 
 Country experience sharing /best practices on trade facilitation measures.  
 Funding a project for the legal translation of all trade laws and regulations for publication 
on  the internet. 
 Establishment of regional enquiry points. 
 Conducting a feasibility study to review fees and charges collected. 
 Harmonization of border procedures. 
 Website development, design and management. 
 
(ii) Customs-related procedures, in cluding transit-related needs: 
 Single Window/one-time submission: financial assistance to establish single window 
infrastructure; request a resident consultant to assist with this project. 
 Risk Management/Analysis: improve risk assessment; develop capacity to set up a risk 
management system which includes before, during and after clearance of goods; set up an automated system for risk analysis, review legislation. 
 Assistance in setting up the following systems: authorized trader; pre-arrival clearance; 
post clearance audit and expedited shipments. 
 Reinforcement of customs administration in order to eliminate pre-shipment inspection 
(PSI) and build capacity to fac ilitate destination inspections.  
 Establishment of clearance & relea se times -conduct a time release study. 
 Setting up a cargo tracking system including training in risk management. 
 Establish a regional bond guarantee system. 
 
(iii) Infrastructure /Equipment/ICT related needs: 
 Development of ICT infrastructure (hardware,  software, networks, valuation database, 
etc).  
 Operationalization and harmonization of juxta posed border posts, including provision of 
necessary equipment. 
 Procurement of laboratories for testing f acilities and improve existing ones; facilitate 
accreditation of laboratories; develop sta ndards and acquisition of equipment and 
training. 
 Acquisition of adequate exper tise and financing for the restructuring of the customs 
department. 
 Equipment for proper functioning of a national enquiry point. 
 
(iv) Human Resource-related needs: 
 Development of human resource capacity thro ugh specialized and skill-based training on 
legal drafting; risk management; post-clearan ce audit; authorized trader criteria and 
determination; port managemen t; ICT; advance rulings; valuation; appeal mechanisms, 
rules of origin; classification; freight forwarding; and other WCO programmes/standards. 
 Training of personnel in customs, standard bureaus (laboratory testing) and other border 
agencies as well as the private sector. 
 Training in application of international standards. 
 Technical Training in SPS, test procedures. 
 Training in information, organi zation and change management. 
 
  TN/TF/W/177 
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ANNEX I 
TRADE FACILITATION NEEDS ASSESSMENTS  
by Implementation Date 
 
Total Needs Assessments Conducted 94 
Requested but not Conducted (due to lack of follow-up by country or  security situation)  14 
Total Requests 108 
 
  Country  Dates  Facilitators Country 
Status * 
2007 Implemented 
1.  Zambia Feb. 25- Mar.2  WTO, World Bank, WCO, USAID 
Zambia Threshold Project LLDC/LDC 
2.  Mexico Sept. 24 - 28 WTO, WCO  DC 
3.  Bangladesh Oct. 22 - 25 WTO, IMF LDC 
4.  Mauritius Oct. 22 - 26 WTO, UNCTAD DC/SIDS 
5.  Tanzania Oct. 29 – Nov. 2 WTO, USAID  LDC 
6.  Burundi Nov. 19 - 23 OECD, WCO LLDC/LDC 
7.  Paraguay Nov. 26 - 30 UNCTAD, WCO LLDC 
8.  Uganda Dec. 3 - 8 USAID, WCO LLDC/LDC 
9.  Jordan Dec. 9 - 13 WTO, Swit zerl., EU Twinning Project DC 
10.  Honduras Dec. 10 - 14 World Bank, Canada (WCO-CP) DC 
2008 Implemented 
11.  Egypt  Jan.13-17  WTO, World Bank, 
USAID TAPR II Project DC 
12.  Guatemala Mar. 10-13 WCO, World Bank, CBSA DC 
13.  Vietnam Mar.10-14  World Bank, WCO, Sweden, JICA DC 
14.  Rwanda Mar. 10-14  USAID, Switzerland LLDC/LDC 
15.  Yemen+ Mar. 15-19  WTO, WCO, UNCTAD LDC 
16.  Tunisia 31 Mar-4 Apr OECD, Switzerland DC 
17.  Chinese Taipei Mar. 31 -4 Apr WTO, Finland DC 
18.  Nigeria  Apr. 7-1l WCO, USAID, Norway  DC 
19.  Benin April 14-18 WTO, Switzerland LDC 
20.  Dem. Rep. of Congo  April 14-18 WCO, UNCTAD LDC 
21.  Nepal May 12-16 WTO, World Bank LLDC/LDC 
22.  Trinidad and Tobago May 19-23 World Bank, Denmark DC/SIDS 
23.  Dominica May 26-29 UNCTAD, Finland, Switzerland DC/SIDS 
24.  Kenya June 9-13 USAID, WCO  DC 
25.  Antigua and Barbuda June 9-13 WTO, UK DC/SIDS 
26.  Swaziland June 23-27 WTO, USAID Trade Hub LLDC/DC 
27.  Pakistan June 23-27 UNCTAD, Finland, JICA DC 
28.  Lesotho July 7-11 USAID Trade Hub LLDC/LDC 
29.  Gabon July 7-11 OECD, Switzerland DC 
30.  Grenada July 21-25  Finland, UNCTAD DC/SIDS 
31.  Fiji July 28- Aug 1 WTO, AusAID/NZ/OCO DC/SIDS TN/TF/W/177 
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  Country  Dates  Facilitators Country 
Status * 
32.  Jamaica July 28 – Aug 1 USAID, Sweden DC/SIDS 
33.  Ghana Aug. 25-29  WCO, UK, World Bank DC 
34.  Colombia Sept. 1-5 World Bank, UNCTAD DC 
35.  Mali Sept. 8-12 UNCTAD, Swiss consultant LLDC/LDC 
36.  Burkina Faso Oct. 6-10 UNCTAD, OECD, Switzerland LLDC/LDC 
37.  Mozambique Oct 6-10 USAID Trade Hub, WCO LDC 
38.  Morocco Oct 13-17 WCO, Switzerland DC 
39.  Panama Oct.13-17 WTO, World Bank DC 
40.  Cambodia Oct. 20-24 World Bank, UNESCAP, Sweden LDC 
41.  Albania Oct.27-31 WCO, WTO, Switzerland DC 
42.  China Nov. 3-7 OECD, Sweden, UNESCAP DC 
43.  Angola Nov. 3-7 WCO, USAID Trade Hub, USAID LDC 
44.  Central African Rep. Nov.7-13 WTO, Switzerland LLDC/LDC 
45.  Ecuador Nov. 10-14 WTO, World Bank DC 
46.  Papua New Guinea  Nov 17-21 AusAID, OCO DC/SIDS 
47.  Malawi Nov 17-21 USAID Trade Hub LLDC/LDC 
48.  Argentina Nov.24 -28 WTO, World Bank, WCO DC 
49.  St Kitts and Nevis Dec 1- 5 WTO, UNCTAD, UK DC/SIDS 
50.  St Lucia Dec 1-5 WTO, UNCTAD, UK DC/SIDS 
51.  St Vincent & 
Grenadines Dec 1-5 WTO, UNCTAD, UK DC/SIDS 
52.  Seychelles+ Dec 1-5 USAID Trade Hub DC/SIDS 
53.  Dominican Republic Dec 8-11 WTO, WCO, WCO DC/SIDS 
54.  Cote d'Ivoire Dec 8-11 WCO, Switzerland DC 
2009 Implemented  
55.  Madagascar Jan 19-23 WTO, OECD, WCO LDC 
56.  Suriname Feb. 9-13 USAID, Finland  DC/SIDS 
57.  Philippines Feb 9-13 WB, UNESCAP, WCO DC 
58.  Afghanistan+  March 6-10 UNCTAD, USAID  LLDC/LDC 
59.  Malaysia April 13-17 WTO, Finland, JICA DC 
60.  Nicaragua April 13-17 UNCTAD, WCO, WB DC 
61.  Djibouti April 19-23 WCO. Switzerland LDC 
62.  Cape Verde May 11-14 WCO, UNCTAD, Switzerland DC/SIDS 
63.  Botswana May 11-15 USAID Trade Hub  LLDC 
64.  Zimbabwe  May 11-15 World Bank, UNCTAD LLDC/DC 
65.  Uruguay May 13-15 World Bank, WCO DC 
66.  Comoros  May 18-22 UNCTAD, Swiss, WCO LDC/SIDS 
67.  Sri Lanka May 18-21 WB, Japan DC 
68.  Tonga May 25-29 OCO, AusAID DC/SIDS 
69.  Mongolia May 25-29 World Bank, Sweden, Japan LLDC 
70.  Belize  June 8-12 Sweden, Switzerland, OECS DC/SIDS 
71.  Brunei Darussalam   June 15-19 World Bank, Pakistan, Japan  DC 
72.  Senegal  June 15-19 UNCTAD, Switzerland, EC LDC  TN/TF/W/177 
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  Country  Dates  Facilitators Country 
Status * 
73.  Togo June 29 – July 3 UNCTAD, Switzerland, WCO LDC 
74.  Barbados July 13-17  WTO, CRNM, Barbados DC/SIDS 
75.  Indonesia July 27-31 OECD, Japan, UNESCAP DC 
76.  Solomon Islands  September 14-18 AusAID, OCO LDC/SIDS 
77.  Lao PDR September 21-24 World Bank, Sweden, Finland LLDC/LDC 
78.  Costa Rica September 22-25 WTO, Swiss, WCO DC 
79.  Maldives Sept 28-October 1 UNE SCAP, UK. Pakistan LDC/SIDS 
80.  Bahrain – GCC 
regional October 10-14 WTO, WCO, UK, Sweden, Finland, 
WB DC/SIDS 
81.  Kuwait – GCC  October 10-14 WTO, WCO, UK, Sweden, Finland, 
WB DC 
82.  Oman - GCC October 10-14 WTO, WCO, UK, Sweden, Finland, 
WB DC 
83.  Qatar - GCC October 10-14 WTO, WCO, UK, Sweden, Fin., WB DC 
84.  Saudi Arabia, 
Kingdom of - GCC October 10-14 WTO, WCO, UK, Sweden, Fin., WB DC 
85.  UAE – GCC regional October 10-14 WTO, WCO, UK, Sweden, Fin., WB DC 
86.  Kiribati October 8 - 15 AusAID, OCO LDC/SIDS 
87.  Sudan+( UN level 3) Oct 27- Nov 1 Sudan negotiator LDC 
88.  Vanuatu November 23-27 AusAID, OCO LDC/SIDS 
2010 Implemented  
89.  Congo (Brazzaville) February 1 - 5 UNCTAD, WCO, Switzerland DC 
90.  Namibia March 8-12 USAID Trade Hub, World Bank DC 
91.  Niger March 15-19 WCO, UNCTAD LDC/LLDC 
92.  Samoa May 10-14 AusAid, OCO LDC/SIDS 
93.  Ethiopia+ October 11-15 World Bank, Sweden LDC/LLDC 
94.  Algeria+ October 17-21 WTO, Swiss consultant DC 
Inactive Requests – request made but no follow-up to request for notification and/or to schedule dates. 
1.  Bolivia, Plurinational 
State of   LLDC/DC 
2.  Cameroon   DC 
3.  Chile   DC 
4.  Kyrgyz Republic   CIT 
5.  Sierra Leone   LDC 
6.  Mauritania   LDC 
7.  Moldova   CIT 
8.  Serbia   CIT 
9.  Venezuela   DC 
10.  Azerbaijan+   CIT 
11.  Turkey  Made initial request but decided to 
conduct assessment independently. DC 
Not Conducted Due to Security Situation 
12.  Chad UN level 3   LLDC/LDC 
13.  Guinea UN level 3   LDC 
14.  Haiti UN level 3   LDC/SIDS TN/TF/W/177 
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*LLDC: Landlocked Developing Country; LDC: Least Devel oped Country; SIDS: Small Isla nd Developing State; CIT: 
Country in Transition; DC: Developing Country. 
+ Acceding Country.  TN/TF/W/177 
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ANNEX II 
TRADE FACILITATION NEEDS ASSESSMENTS  
Implementation Information by Country 
 
(If the second column is blank then no request was made) 
Developing Countries 
1.  Albania Completed Oct. 2008  32.  Grenada Completed July 2008 
2.  Antigua and 
Barbuda Completed June 2008 33.  Guatemala Completed March 2008 
3.  Argentina Completed Nov. 2008 34.  Guyana  
4.  Armenia  35.  Honduras Completed Dec. 2007 
5.  Bahrain Completed Oct. 2009 36.  Hong Kong, 
China  
6.  Barbados Completed July 2009 37.  India  
7.  Belize Completed June 2009 38.  Indonesia Completed July 2009 
8.  Bolivia, 
Plurinational 
State of Requested but did not 
follow through 39. Israel  
9.  Botswana Completed May 2009 40.  Jamaica Completed Aug. 2008 
10.  Brazil  41.  Jordan Completed Dec. 2007 
11.  Brunei 
Darussalam Completed June 2009 42.  Kenya Completed June 2008 
43. Korea  
12.  Cameroon Requested but did not 
follow through 44. Kuwait Completed Oct. 2009 
13.  Cape Verde Completed May 2009 45. Kyrgyz 
Republic Requested but did not 
follow through 
14.  Chile Requested but did not 
follow through 46. Macao, 
China  
15.  China Completed Nov. 2008 47.  Malaysia Completed April 2008 
16.  Colombia Completed Sept. 2008 48.  Mauritius Completed Oct. 2007 
17.  Costa Rica Completed Sept. 2009 49.  Mexico Completed Sept. 2007 
18.  Côte d'Ivoire Completed Dec. 2008 50. Moldova Requested but did not 
follow through 
19.  Congo 
(Brazzaville) Completed Feb. 2010 51.  Mongolia Completed May 2009 
20.  Croatia  52.  Morocco Completed Oct. 2008 
21.  Cuba  53.  Namibia Completed March 2010 
22.  Dominica Completed May 2008 54.  Nicaragua Completed April 2009 
23.  Dominican 
Republic Completed Dec. 2008 55.  Nigeria Completed April 2008 
24.  Ecuador Completed Nov. 2008 56.  Oman Completed Oct. 2009 
25.  Egypt Completed Jan 2008 57.  Pakistan Completed June 2008 
26.  El Salvador Conducted self-
assessment without technical assessment  58. Panama Completed Oct. 2008 
27.  Rep. of the 
Fiji Islands Completed Aug. 2008 59.  Papua New 
Guinea Completed Nov. 2008 
28.  Former 
Yugoslav Rep.  of Macedonia  60.  Paraguay Completed Nov. 2007 
29.  Gabon Completed July 2008 61.  Peru  
30.  Georgia  62.  Philippines Completed Feb. 2009 TN/TF/W/177 
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Developing Countries 
31.  Ghana Completed Aug. 2008 63.  Qatar Completed Oct. 2009 
Developing Countries 
 
64. St. Kitts and 
Nevis Completed Dec. 2008  75. Tonga Completed May 2009 
65. St. Lucia Completed Dec. 2008  76. Trinidad and 
Tobago Completed May 2008 
66. St. Vincent 
and the 
Grenadines Completed Dec. 2008  77. Tunisia Completed April 2008 
67. Saudi 
Arabia, 
Kingdom of Completed Oct. 2009  78. Turkey Requested but decided to 
conduct on own 
68. Singapore   79. Ukraine  
69. South Africa   80. United Arab 
Emirates Completed Oct. 2009 
70. Sri Lanka Completed May 2009  81. Uruguay Completed May 2009 
71. Suriname Completed Feb. 2009  82. Venezuela Requested but did not 
follow-through 
72. Swaziland Completed June 2008  83. Viet Nam Completed March 2008 
73. Taipei, 
Chinese Completed April 2008  84. Zimbabwe Completed May 2009 
74. Thailand      
Total Developing Countries that did not request or did not follow through on their request = 24 
 
Least Developed Countries  
1.  Angola Completed Nov. 2008  17. Malawi Completed Nov. 2007 
2.  Bangladesh Completed Oct. 2007 18. Maldives Completed Sept. 2009 
3.  Benin Completed April 2008 19. Mali Completed Sept. 2008 
4.  Burkina Faso Completed Oct. 2008 20. Mauritania Requested but did not 
follow-through 
5.  Burundi Completed Nov. 2007 21. Mozambique Completed Oct. 2008 
6.  Cambodia Completed Oct. 2008 22. Myanmar  
7.  Central African 
Republic Completed Nov. 2008 23. Nepal Completed May 2008 
8.  Chad Not conducted because 
of security issues  24. Niger Completed March 2010 
9.  Dem. Rep. 
Congo Completed April 2008 25. Rwanda Completed March 2008 
10.  Djibouti Completed April 2009 26. Senegal Completed June 2009 
11.  Gambia  27. Sierra Leone Requested but did not 
follow-through 
12.  Guinea Bissau  28. Solomon Islands Completed Sept. 2009 
13.  Guinea, Rep. of Not conducted because 
of security issues 29. Tanzania Completed Oct. 2007 
14.  Haiti Not conducted because 
of security issues 30. Togo Completed June 2009 
15.  Lesotho Completed July 2008 31. Uganda Completed Dec. 2007 
16.  Madagascar Completed Jan. 2009 32. Zambia Completed Feb. 2007 
Total Least Developed Countries that did not request  or did not follow through on their request = 8 
 
  TN/TF/W/177 
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Observer Governments  
1. Afghanistan Completed March 2009  14. Lao P.D.R. Completed Sept. 2009 
2. Algeria Completed Oct. 2010 15. Lebanon  
16. Liberia  
3. Azerbaijan Requested but did not 
follow-through 17. Libya  
4. Bahamas  18. Montenegro  
5. Belarus  19. Russian 
Federation  
6. Bhutan  20. Samoa Completed May 2010 
7. Bosnia and 
Herzegovina  21. Sao Tome and 
Principe  
8. Comoros Completed May 2009 22. Serbia Requested but did not 
follow-through 
9. Equatorial Guinea  23. Seychelles Completed Dec. 2008 
10. Ethiopia 
  Completed Oct. 2010 
  24. Sudan Completed Oct. 2009 
25. Tajikistan  
11. Iran  26. Uzbekistan  
12. Iraq  27. Vanuatu Completed Nov. 2009 
13. Kazakhstan  28. Yemen Completed March 2008 
Total Observer Governments that did not request or did not follow through on their request with no 
request = 18  
 
 
 
 
__________