WORLD TRADE  
ORGANIZATION  TN/MA/W/46/Add.17 
15 May 2006 
 (06-2355) 
Negotiating Group on Market Access Original:   English 
  
  
NON-TARIFF BARRIER NOTIFICATIONS 
 
Addendum
 
 
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Page
  
I.
 BRAZIL ......................................................................................................................... ............2  
 
  
  TN/MA/W/46/Add.17 
Page 2 
I. BRAZIL 
 
Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Enzymatic 
preparations for pre-
tanning (HS 3202.90) Additional requirements to the veterinary 
certificate: besides the presentation of the 
veterinary certificate, the importing country 
impedes the entry of chemical products of animal origin unless there are guarantees that 
their respective processes of fabrication were 
able to eliminate any contamination of the raw material. Trade restrictive effect Part IV B SPS Agreement NGMA 
 Grass and pruning 
shears (HS Chapter 
82) Preshipment inspection during the loading of 
containers. Unstableness and 
unpredictability of trade Part II I Agreement on 
Preshipment Inspection NGTF 
 Panels of 
industrialized wood 
(HS Chapter 68)  Quotas; requirement of certificates and visa 
documents with high costs and delays; 
restrictions of weight and volume;  limitation of free storage  in destination ports, mainly  in 
countries where the ships arrive before the 
banking documents; embarkment prohibition in ships older than 25 years; certificates of 
Lloyd's ships. Trade restrictive effect Part V A 
Part III C 
Part VII E TBT Agreement, GATT 
Articles VIII and XI NGMA 
 Woods (HS Chapter 
44) Requirement of load inspection carried only by 
technical and specialized qualification office 
without representation in the exporting county; 
delayed issuance of certification by the former agency, causing delay to send documents and 
to release the load by the importer and 
incidental costs. Unstableness and 
unpredictability of trade Part II G 
Part II  I 
Part III  C Agreement on 
Preshipment Inspection 
and  GATT Article VIII NGMA   
   TN/MA/W/46/Add.17
 Page 3Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Electric Products (HS 
Chapter 85) Non-acceptance of exporting country 
regulations based on the IEC, requiring 
compliance with specific regulations, with high costs and waste of time. 
 
Requirement to undertake individual tests for 
similar models that present little differences of voltage. Trade restrictive effect Part III B 
Part III C TBT Agreement NGMA 
 Chemical Products 
(HS Chapter 28-38) Packaging: some products such as magnesium, 
calcium and silicon and the calcium carburet shall not be in contact with water and, for this 
reason, are transported in big bags-one way, 
using maritime transport. 
 
Requirement to transport calcium carburet 
through a packaging in metallic containers, what increases costs and reduces 
competitiveness. Trade restrictive effect Part III B 
Part V  K TBT Agreement NGMA  
 Pharmaceutical 
products (HS Chapter 
30) Legislation on bioterrorism generating 
excessively rigorous rules for pharmaceutical 
products, requiring registration in the country 
of all proprietors, operators or agents in charge of a domestic or foreign company which 
manufactures, processes, packages or stocks of 
pharmaceutical products.  Trade restrictive effect  
 
The requirement increases costs 
and impedes exports, in particular those from SME’s 
from developing countries. 
 Part II G 
Part IV C 
Part V K TBT and SPS  
Agreements NGMA  
  TN/MA/W/46/Add.17 
Page 4 
Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Graphic Products (HS 
Chapter 49) Legislation of foreign trade requires that 
exporters assign a local commercial 
representative or establish a subsidiary in that country, in order to be legally responsible for 
the compliance with the technical regulations 
required for the product. Trade restrictiveness. 
Discriminatory effect. Only 
national importers, manufacturers and traders, 
along with those countries with 
which the government have celebrated Free Trade 
Agreements (FTA), are granted 
the certificate of compliance with the pertinent technical regulations. Part III B 
Part V E TBT Agreement NGMA  
 Slates (HS Chapter 96) Non-acceptance of the results of tests 
undertaken by accredited laboratories in the exporting country and requirement that tests of 
resistance be performed by a technician from 
the importing country. Exporting companies have to bear all the costs related to the trip of 
this technician, for each dispatch that takes 
place.  Those costs amount to 10.000 euros for each operation. Trade restrictive effect Part III C TBT Agreement NGMA 
 Electric and Electronic 
Equipment (HS Chapter 85). Prohibition of importation of electric and 
electronic equipment containing hazardous substances.  
 Trade restrictive effect  Part V B GATT Article XI NGMA  
 Chemical Products, 
Plastics and Rubbers, 
downstream and 
upstream products  (HS Chapters 28 to 
40); Base metals (HS 
Chapters 72 to 83) Burdensome requirements to register, evaluate 
and receive authorizati on to export; additional 
requirements concerning, marking, labeling 
and packaging. 
 Increasing costs of the product 
through the requirement to 
undertake additional tests, 
registration, evaluation, authorization, thus undermining 
product competitiveness. Part III C 
Part IV A 
Part V B 
Part V K TBT Agreement NGMA   
   TN/MA/W/46/Add.17
 Page 5Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Textile and Textile 
Articles (HS Chapters 
50 to 63) Raw hides and leather (HS 
Chapters 41 and 42) 
Azo dyes (HS 3204 19). Requirement to obtain an import certif icate. The requirement of additional 
test increases the cost of the 
product and undermines competitiveness. Part I D 
Part III C 
Part V B TBT Agreement NGMA  
 Information 
technology products. Electrical machinery (HS Chapters 84, 85 
and 90). Non-transparent customs classi fication. Unpredictability Part II C GATT Articles VIII and 
X NGTF 
 Automobiles and their 
parts, building 
automobile machines 
(HS Chapters 84, 85 and 87). Customs procedures lack  transparency and are 
complicated. Unpredictability Part II G GATT Articles VIII and 
X NGTF 
 Mineral products (HS 
Heading 2529 and 2846). Quantitative import restrictions and non-
transparent quota allocation. Trade restrictive effect  Part V A GATT Articles X and 
XI NGMA and NGTF 
 Information 
technology products (HS Chapter 84, 85 
and 90) Non-transparent  customs cla ssification. Unpredictability  Part II C GATT Articles VIII and 
X NGTF 
 Gas cylinders (HS 
7311.00) Customs valuation. The invoice price is never 
accepted. Unpredictability Part II B GATT Articles VIII and 
Agreement on Customs 
Valuation NGTF 
 Vacuum cleaners, 
floor polishers, 
washing machines and 
portable appliance.  (HS Chapter 85) Imposition of penalty fine in case of minor 
breaches or mistakes in documents required by 
the Customs Administration. Trade restrictive effects Part II G GATT Articles V and 
VIII NGTF  
  TN/MA/W/46/Add.17 
Page 6 
Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Vacuum cleaners, 
floor polishers, 
washing machines and portable appliance. 
(HS Chapter 85) Requirement of serial number information for 
each product. Trade restrictive effects Part III A TBT Agreement NGMA and NGTF 
 Vacuum cleaner 
motors (HS Chapter 
85) Import licenses shall be granted before each 
shipment. A fine is imposed if shipment takes 
place without previous importation license. Trade restrictive effects Part II H Agreement on Import 
Licensing Procedures NGTF 
 Pharmaceutical 
products (HS Chapter 30). Requirement to present primary pattern. Delays  in product delivery  Part IV A SPS and TBT 
Agreement NGMA  
 Pharmaceutical 
products (HS Chapter 30). Requirement to present complete “Drug Master 
File” (DMF) even for substances already 
registered. Delays in product delivery and 
excessive documentation.  Part IV A SPS and TBT 
Agreement; GATT 
Article VIII NGMA  
 Pharmaceutical 
products (HS Chapter 30). Requirement to present monthly chromatogram 
for all stability studies. Excessive documentation  Part IV A SPS Agreement 
and GATT Article VIII NGMA and NGTF 
 Pharmaceutical 
products (HS Chapter 30). Requirement of an import certificate 
authorizing the entry of controlled pharmaceutical products. Issuance of this 
document can take up to sixty days. Delay in product delivery and 
contract cancellation. Part IV A SPS Agreement NGMA 
 Pharmaceutical 
products (HS Chapter 
30). Certification of pallets  Additional costs and undue 
delay.  Part IV A SPS Agreement NGMA 
 Textiles and textile 
articles (HS Chapters 
50 to 63)  Consularization of trade documents for exports 
by letter of credit. Fees charged are not related 
to the service rendered  and are unpredictable 
and non transparent. The requirement imposes 
excessive bureaucracy, 
increasing costs and delivery 
time what undermines the product competitiveness. There 
is also unpredictability in price 
formation for export due to the lack of transparency in fees charged and procedures. Part II   D GATT Articles VIII and 
X NGTF  
   TN/MA/W/46/Add.17
 Page 7Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Articles of apparel and 
clothing accessories 
knitted or crocheted. (HS Chapters 61 and 
62) Requirement of labeling certification to issue 
letter of credit in the importing country. Only 
one institution can issue the certificate, but the article composition verification must be done 
before its own producti on and in accordance to 
specific technical regulation. The requirement increases 
export costs, causes delays and 
shipment loss. Part V   K TBT Agreement NGMA 
 Textiles and textile 
articles. (HS Chapters 
50 to 63 )  Import prohibition of textiles and textile 
articles produced with azo colourants which 
may release one or more of the aromatic amines above 30 ppm in the finished product. Trade restrictive effect. Besides, 
the requirement of additional 
documentation causes delays and shipment loss.           Part III   B TBT Agreement NGMA 
 Aluminum and articles 
thereof. (HS Chapter 
76) Requirement of consular visa and trade 
documents legalization. The requirement increases 
bureaucracy and costs. In one 
country, for instance, the legalization of trade documents 
amounts to US$ 1,000 per 
operation, representing about US$ 60/ton in a container of 
aluminum which is equivalent 
to the freight price. Part II   D GATT Article VIII NGTF 
 Aluminum and articles 
thereof (HS Chapter 
76) Inconsistent and unpredictable rules to issue 
certificates in general. The current situation makes 
operations difficult and 
increases costs. Part II   G GATT Article VIII and 
X NGTF 
 Ceramic products (HS 
Chapter 69)  Burdensome labeling requirement for certain 
ceramic products. The requirement inhibits 
exports. Part V   K TBT Agreement NGMA 
 Ceramic products (HS 
Chapter 69) Requirement of preshipment inspection. The requirement increases 
delivery time and costs. Part II   I PSI Agreement NGTF 
 Ceramic products (HS 
Chapter 69) The exporters are obliged to label their 
products in the importing country customs. The requirement causes delays 
and increases costs. Part V   K TBT Agreement NGMA 
 Ceramic products (HS 
Chapter 69) Requirement of radioactivity and quality 
certificates for all imported products. The requirement increases 
costs.. Part III   C TBT Agreement NGMA  
 Ceramic products (HS 
Chapter 69)  Requirement of certification for each type of 
product in every single operation. The requirement inhibits 
exports. Part III   C TBT Agreement NGMA  
  TN/MA/W/46/Add.17 
Page 8 
Maintaining 
participant Products 
affected by the 
barrier Nature of the barrier Trade effects of the 
barrier Inventory 
category Relevant WTO 
provision Treatment of 
the barrier 
1 2 3 4 5 6 7 
 Ceramic products (HS 
Chapter 69)  National certification of products. The laboratory inspection 
required by the importing 
country amounts to about US$ 4,000 per year. There is an 
additional cost of US$ 300 for 
preshipment inspections. Part III   C          
Part II   I TBT Agreement, PSI 
Agreement NGMA and NGTF 
 Ceramic products (HS 
Chapter 69) Requirement of a special certificate for 
government procurement. The requirement increases costs 
excessively. Part I  C 
Part III B  TBT Agreement NGMA 
 Trailers and semi-
trailers; other vehicles, not mechanically 
propelled; parts 
thereof. (HS 8716) Requirement of licensing by local competent 
bodies of the importing country. In some cases, there are discriminatory requirements against 
imported products. The requirement increases costs 
and is lengthy due to the necessity of having designated 
technicians of the exporting 
companies in the importing country during the proceedings. Part III   B          
Part V   F TBT Agreement GATT 
Article III NGMA 
 Trailers and semi-
trailers; other vehicles, not mechanically 
propelled; parts 
thereof. (HS 8717) The requirement of the National System for 
Testing and Certification inhibits exports as replacement parts must be certificated by local 
laboratories before shipment. The tests are lengthy and 
expensive acting as a barrier to exports of final products.  Part III   C TBT Agreement NGMA  
 
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