WORLD TRADE  
ORGANIZATION  G/RO/W/125 
30 April 2009 
 
 (09-2099) 
Committee on Rules of Origin Original:   English 
  
 
JAPAN’S COMMENTS ON DO CUMENT G/RO/W/111/REV.3 
 
Communication from Japan 
 
 
The following communication, dated 28 April 2009, has been received from the Delegation of Japan. 
 
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A. G
ENERAL COMMENTS  
1. A draft text with track changes is very helpfu l for Members to verify the modifications made 
by the Secretariat.  It would be much appreciated, if the Secretariat would continue to provide such 
draft to Members. 
2. With regard to the issue of the dual-rule appr oach for machinery in Chapters 84 to 90 and 92, 
the CRO Chairperson said in the previous mee tings that she sought guidance from the General 
Council, and looked forward to receiving it.  Japan  shares the view with the Chairperson on this 
matter, and therefore, Japan refrains from subm itting concrete comments on those chapters in 
G/RO/W/111/Rev.3, in the CRO meeting in June. 
B. PREAMBLE  
3. Japan strongly supports the inclusion, in the preamble, of the provision, “Recognizing that 
rules of origin do not prejudice Members’ rights a nd obligations in respect of the application of 
domestic requirements for f ood labelling or for sanitary and phytosanitary measures.”  
C. CHAPTER NOTES AND PSR S 
1. 04.10 
Japan considers that the square  brackets of the Primary rule of 0410 should be dropped, as 
agreed in the Basket 1.  (Please refer to G/RO/45/Add.8/Rev.3). 
2. ex07.12(b) 
 Japan strongly supports the Chair’s proposal on ex0712 (b). 
 
3. 1601, 1602 and 1605 
 Japan understands that Members have already reached consensus on the rules of 1601, 1602 
and 1605 (Please refer to G/RO/45/Add.8./Rev.3).  Therefore, the square brackets for the rules on 
these headings should be deleted.  G/RO/W/125 
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  4. 2103.10, 2103.20 and 2103.90 
 Japan understands that Members have alread y reached consensus on the rules of 2103.10, 
2103.20, 2103.90 (Please refer to G/RO /45/Add.8/Rev.3).  Therefore, the square brackets for the rules 
on these split headings should be deleted.  5. Chapter 39 
 Note 2. Mixtures and Blends
 
  Though Chapter Note 2 (b) was stipulated in G/RO/W/111/Rev.2, it was dropped in G/RO/W/111/Rev.3.  For clarification, Japan would like to be advised of the reason why the provision 
was dropped. 
 
6. ex 50.04(b), ex 50.06(c) 
 Compared with G/RO/W/111/Rev.2, the square  brackets on primary rules for split heading 
50.04(b) and ex 50.06(c) were dropped and the ex ception to the rules was also modified in 
G/RO/W/111/Rev.3.  For clarification, Japan w ould like to be advised of the reason for these 
modifications.  
7. ex 50.05(b), ex 51.06(c) , ex 51.07(c) , ex 51.08(c) , ex 51.09(c) , ex 51.10(c) , ex 52.05(c) , 
ex 52.06(c) , ex 52.10(b) 
 The square brackets on primary rules for split h eadings ex 50.05(b), ex 51.06(c), ex 51.07(c) , 
ex 51.08(c), ex 51.09(c), ex 51.10(c), ex 52.05(c ), ex 52.06(c) and ex 52.10(b) were dropped, in 
G/RO/W/111/Rev.3.  For clarification, Japan woul d like to know the reason why the square brackets 
were dropped. 
 
8. ex 50.07(a) 
 Primary rule of split heading ex 50.07 (a) wa s “[CTH; or change by permanent dyeing or 
permanent printing from unbleached or prebleached yarn with at least two preparatory or finishing 
operations.]” in G/RO/W/111/Rev.2.  On the ot her hand, “yarn” was replaced by “fabric” in 
G/RO/W/111/Rev.3.  For clarification, Japan w ould like to be informed of the reason for the 
modification.  9. 5810.10 
 In G/RO/45/Add.1/Rev.2, the percentage is “50%”.  Therefore, the question mark in the 
primary rules of subheading 5810.10 of G/RO/W/Rev.3 is not necessary. 
 
10. ex 58.11(a) 
 Taking into account the descriptions of the other split headings in chapter 58, the primary rule 
for split heading ex58.11 (a) should be stipulat ed as “[CTH; or chan ge from unbleached or 
prebleached fabric to ---.]” 
 
11. 63.05 
 Compared with G/RO/W/111/Rev.2, the primary rule for heading 63.05 was placed in square 
brackets in G/RO/W/111/Rev.3.  For clarification, Japan would like to know the reason why the rule 
was placed in square brackets.  G/RO/W/125 
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  12. 6307.10 and 6307.90 
 The primary rules for subheading 6307.10 and 6307.90 were replaced with each other, in 
G/RO/W/111/Rev.3, in comparison with G/RO/W/111/Rev.2.  For clarification, Japan would like to know the reason for the replacement. 
 
13. Chapter 82 and 83 Notes 
 Both Chapters 82 and 83 stipulate “Notes Goods or Parts Produced from Blanks”.  It is better 
to use the same description.  For instance, though a comma is placed between “b lank” and “which”, in 
the Note of Chapter 83, it is not the case in that of Chapter 82. 
 
14. 82.06 
 According to the explanation by the Secretaria t at the meeting in October 2008, the process of 
resulting only from putting up goods in sets does NOT confer  origin.  To ensure consistency, with the 
descriptions of the rules of the other articles put up in sets, it is necessary to add the phrase “, except 
when resulting only from putting up in sets” after th e abbreviation “CC” of the primary rules for 
heading 82.06. 
  
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