CHINA - MEASURES RELATED TO DEMONSTRATION BASES AND COMMON SERVICE PLATFORMS PROGRAMMES REQUEST FOR THE ESTABLISHMENT OF A PANEL BY THE UNITED STATES
Document: REQUEST FOR THE ESTABLISHMENT OF A PANEL
Date: 10 April 2015
Document codes: WT/DS489/6
Complainant: U.S.
Respondent: China
Third parties: EU, Australia, Canada, India, South Korea, Brazil, Japan, Russia, Colombia, Singapore, Taiwan, Saudi Arabia, Dominican
Dispute stage: Panel
Agreements cited: Art. 3.1(a), 3.2  Subsidies and Countervailing Measures (SCM)

CHINA - MEASURES RELATED TO DEMONSTRATION BASES
AND COMMON SERVICE PLATFORMS PROGRAMMES
REQUEST FOR THE ESTABLISHMENT OF A PANEL BY THE UNITED STATES
The following communication, dated 9 April 2015, from the delegation of the United States to the
Chairperson of the Dispute Settlement Body, is circulated pursuant to Article 6.2 of the DSU.

On 11 February 2015, the United States requested consultations with the Government of the
People's Republic of China ("China") pursuant to Articles 1 and 4 of the Understanding on Rules
and Procedures Governing the Settlement of Disputes ("DSU"), Article XXII:1 of the General
Agreement on Tariffs and Trade 1994 ("GATT 1994"), and Articles 4 and 30 of the Agreement on
Subsidies and Countervailing Measures ("SCM Agreement"), with regard to certain measures
providing subsidies contingent upon export performance to enterprises in several industries in
China. The United States held consultations wi th China on 13 March and 1-2 April 2015. Those
consultations unfortunately did not resolve the dispute.

I. Demonstration Base / Common Service Platform Program and Subsidies

It appears that China provides export-contingent subsidies through a program establishing
"Foreign Trade Transformation and Upgrading Demonstration Bases" ("Demonstration Bases") and
"Common Service Platforms". Demonstration Bases are industrial clusters of enterprises in several
Chinese industries, including the textiles, agriculture, medical products, light industry, special
chemical engineering, new materials, and hard ware and building materials industries. Common
Service Platforms are service suppliers designated by China to provide services to enterprises in
Demonstration Bases. China designates an industrial cluster of enterprises in a particular industry
as a Demonstration Base, based on, inter alia, export performance. China then provides export-
contingent subsidies to the enterprises located in the Demonstration Base through the provision of
discounted or free services by Common Service Platforms.

The Demonstration Base / Common Service Platform program and export subsidies under that
program are reflected in legal instruments that include, but are not limited to, the following,
operating separately or collectively, as well as any amendments or related, successor,
replacement, or implementing measures:

A. Demonstration Base Instruments

Central Level

1. Public Notice on the Third Batch of National Foreign Trade Transformation and Upgrading
Specialized Demonstration Bases List, Ministry of Commerce (23 December 2013).

2. Ministry of Commerce Notice on Organizing th e Application of the Third Batch of National
Foreign Trade Transformation and Upgrading Specialized Demonstration Bases Relevant
Materials, Ministry of Commerce, Shang Mao Han [2013] No. 467 (17 July 2013).

3. Public Notice on the Second Batch of Nation al Foreign Trade Transformation and Upgrading
Specialized Demonstration Bases List, Ministry of Commerce (12 December 2012).

4. Twelfth Five-Year Plan on Foreign Trade Development , Ministry of Commerce
(26 April 2012).

5. Ministry of Commerce Notice on Carrying Out the Second Batch of National Foreign Trade
Transformation and Upgrading Specialized Demonstration Bases Determination Work ,
Ministry of Commerce, Shang Mao Han [2012] No. 208 (10 April 2012).

6. Ministry of Commerce General Office Noti ce on Investigating the Foreign Trade
Transformation and Upgrading Demonstration Bases Development Current Situation ,
Ministry of Commerce, Shang Ban Mao Han [2012] No. 185 (15 March 2012).

7. Ministry of Commerce Notice on Determining the First Batch of National Foreign Trade
Transformation and Upgrading Specialized Demonstration Bases , Ministry of Commerce,
Shang Mao Han [2011] No. 1084 (12 December 2011).

8. Ministry of Commerce Letter on Carrying Out the Cultivation Work for the National Foreign
Trade Transformation and Upgrading Demonstration Bases , Ministry of Commerce, Shang
Mao Han [2011] No. 62 (14 February 2011).

Sub-Central Level

9. Guangxi [Zhuang Autonomous Region] Department of Commerce Measure on the
Administration of Foreign Trade Transformation and Upgrading Demonstration Bases (Trial) ,
Guangxi [Zhuang Autonomous Region] Department of Commerce (1 December 2014).

10. Xixiu District Industry and Trade Bureau Helping Enterprise Application for Provincial Level
Foreign Trade Transformation and Upgrading Demonstration Base Work , Guizhou Province
Department of Commerce (20 November 2014).
11. Notice on Organizing the Carrying Out of the Fourth Batch of Provincial Foreign Trade
Transformation and Upgrading Specialized Demonstration Bases Determination and the First
Batch of Base Reexamination Work, Shandong Province Department of Commerce, Lu Shang
Ban Zi [2014] No. 206 (3 November 2014).

12. Notice on Determining the First Batch of Anhui Province Foreign Trade Transformation and
Upgrading Demonstration Base and Other Enterprises and Anhui Province Electromechanical,
High Technology Product Export Bases and Other Enterprises , Anhui Province Bureau of
Commerce (22 August 2014).

13. Hebei Province Public Notice on the Second Batch of Foreign Trade Transformation and
Upgrading Demonstration Bases and Demonstration Enterprises List , Hebei Province
Department of Commerce (26 June 2014).

14. Public Notice on the Second Batch of Guangdong Province Foreign Trade Transformation and
Upgrading Specialized Demonstration Base List , Guangdong Province Department of
Commerce (2 January 2014).

15. Guangdong Province Department of Commerce, Guangdong Province Department of Finance
Notice on Doing Well the 2013 Supporting Enterprises to Purchase International Well-Known
Brands and Promote Foreign Trade Transformation and Upgrading Special Fund Application
and Administrative Work , Guangdong Province Department of Commerce, Department of
Finance, Yue Wai Jing Mao Cai Zi [2013] No. 14 (12 October 2013).

16. Notice on Doing Well the 2013 Shunde District Foreign Trade Transformation and Upgrading
Demonstration Base Construction Fund Use and Administration Work , Foshan City Shunde
District (Guangdong Province) Economic and Science Promotion Bureau, Shun Jing Fa
[2013] No. 62 (2 April 2013).

17. [Gansu] Provincial Department of Commerce Public Notice on the First Batch of Science and
Technology Trade Promotion Bases and Electromechanical Products Foreign Trade
Transformation and Upgrading Demonstration Bases , Gansu Province Department of

Commerce (13 September 2013).

18. Gansu Province Measure on Electromechanical Products Foreign Trade Transformation and
Upgrading Demonstration Bases Determination , Gansu Province Department of Commerce,
Gan Shang Wu Chan Ye Fa [2013] No. 244 (6 June 2013).

19. Notice on Doing Well the 2013 Foreign Trade Development Specialized Fund Application
Work, S h a n d o n g P r o v i n c e D e p a r t m e n t o f C o m m e r c e , D e p a r t m e n t o f F i n a n c e , L u C a i Q i
[2013] No. 20 (15 May 2013).

20. Public Notice on the Second Batch of Shando ng Province Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases List , Shandong Province Department of
Commerce (11 January 2013).

21. Shanxi Provincial Department of Commerce Notice on Organizing the Application of the Third
Batch of National Foreign Trade Transformation and Upgrading Specialized Demonstration
Bases, Shanxi Province Department of Commerce, Jin Shang Mao Han [2013] No. 494
(2 August 2013).

22. Shanxi Province Second Batch of Provinci al Level Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases Determination Work Plan , Shanxi Province
Department of Commerce (2013).

23. Notice on Further Promoting the Entire City's Export Bases Construction Work , Jingzhong
City (Shanxi Province) Bureau of Commerce (15 March 2013).

24. Notice on Carrying Out the Second Batch of Provincial Level Foreign Trade Transformation
and Upgrading Specialized Demonstration Bases Determination Work , Jinzhong City (Shanxi
Province) Bureau of Commerce (15 March 2013).

25. Opinions on the Guidance of Accelerating th e Inner Mongolia Autonomous Region Foreign
Trade Transformation and Upgrading Demonstration Bases Construction Work , Inner
Mongolia Autonomous Region Department of Commerce, Inner Mongolia Autonomous Region
Department of Finance, People's Republic of China Huhehaote City Customs, People's
Republic of China Manzhouli City Customs, People's Republic of China Inner Mongolia
[Autonomous Region] Exit-Entry Inspection and Quarantine Bureau, Nei Shang Mao Zi
[2013] No. 870 (10 October 2013).

26. Notice on Organizing the Application of the Third Batch of National Foreign Trade
Transformation and Upgrading Specialized Demonstration Bases , Xinjiang Uygur
Autonomous Region Department of Commerce, Xin Shang Wai Mao Han [2013] No. 15
(30 July 2013).

27. Notice on Carrying Out the Second Batch of the Shandong Government Foreign Trade
Transformation and Upgrading Specialized Demonstration Bases Determination Work ,
Shandong Province Department of Commerce (31 October 2012).

28. Laiwu City People's Government Opinions on Accelerating Foreign Trade Transformation and
Upgrading to Promote Foreign Trade Development that is Good and Fast , Laiwu City
(Shandong Province) People's Government, Lai Zheng Fa [2012] No. 43
(12 November 2012).

29. Rule on the Implementation of 2012 Weifang City Support of Foreign Economy and Trade
Development Policies , Weifang City (Shandong Province) Bureau of Finance, Bureau of
Commerce, Wei Cai Qi [2012] No. 143 (9 October 2012).

30. Opinions on Accelerating the Promotion of Shanxi Province Foreign Trade Transformation
and Upgrading Demonstration Bases Construction , Shanxi Province Department of
Commerce (26 October 2012).

31. Shanxi Province Measure on the Administration of Foreign Trade Transformation and
Upgrading Demonstration Bases (Trial) , Shanxi Province Department of Commerce
(25 October 2012).

32. Notice on Carrying Out the First Batch of Provincial Level Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases Determination Work , Shanxi Province
Department of Commerce (14 August 2012).

33. Notice on Carrying Out the Second Batch of the Guangdong Provincial Foreign Trade
Transformation and Upgrading Specialized De monstration Bases Application, Review, and
Determination Work , Guangdong Province Department of Foreign Trade and Economic
Cooperation, Yue Wai Jing Mao Guan Zi [2012] No. 21 (6 August 2012).

34. Notice on Doing Well the 2012 Guangdong Prov ince Foreign Trade Transformation and
Upgrading Demonstration Bases Construction Fund Use Administration Work , Guangdong
Province Department of Foreign Trade and Econ omic Cooperation, Department of Finance,
Yue Wai Jing Mao Gui Cai Zi [2012] No. 10 (29 May 2012).

35. 2012 Guangdong Province Foreign Trade Transformation and Upgrading Demonstration
Bases Cultivation Work Plan , Guangdong Province Foreign Trade Transformation and
Upgrading Demonstration Bases Cultivation Work Leading Small Group, Yue Wai Jing Mao
Guan Zi [2012] No. 5 (21 February 2012).

36. Notice on Strengthening Foreign Trade Transformation and Upgrading Demonstration Bases
Publicity Work , Guangdong Province Foreign Trad e Transformation and Upgrading
Demonstration Bases Cultivation Work Leading Small Group, Yue Wai Jing Mao Guan Zi
[2012] No. 3 (31 January 2012).

37. Chaozhou City People's Gove rnment Several Opinions on Accelerating Foreign Trade
Transformation and Upgrading to Achieve Ex port-Oriented Steady Economic Development ,
Chaozhou City (Guangdong Province) People's Government, Chao Fu [2012] No. 34
(4 September 2012).

38. Dongguan City Measure on the Implementation of Optimizing Processing Trade
Transformation and Upgrading the Services Environment , Dongguan City (Guangdong
Province) People's Government, Dong Fu Ban [2012] No. 125 (3 August 2012).

39. Shenzhen City Measure on the Administra tion of the Determination of Foreign
Transformation and Upgrading Demonstration Bases , Shenzhen City (Guangdong Province)
Economy, Trade, and Information Commission, Shen Jing Mao Xin Xi Mi Shu Zi [2012] No.
1356 (31 May 2012).

40. Bao'an District Opinions on the Implementation of Promoting Industrial Transformation and
Upgrading and Accelerating the Transformation of the Mode of Economic Development ,
Bao'an District (Shenzhen City, Guangdong Province) Science and Innovation Department
(10 August 2012).

41. Dabu County Plan on the Implementation of the Ceramics Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases Cultivation , Meizhou City (Guangdong Province)
Department of Foreign Trade and Economic Cooperation (9 January 2012).

42. Notice on Applying for the Second Batch of National Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases , Henan Province Department of Commerce, Yu
Shang Mao Han Zi [2012] No. 53 (29 April 2012).

43. Hebi City Opinions on the Implementation of Promoting the Steady and Healthy
Development of Foreign Trade , Hebi City (Henan Province) People's Government, He Zheng
Ban [2012] No. 60 (16 October 2012).

44. Jiangxi Provincial People's Government Opinio ns on Further Promoting the Development of
the Tea Industry , Jiangxi Provincial People's Government, Gan Fu Ban Fa [2012] No. 51,
(17 July 2012).

45. Notice on Doing Well the Second Batch of National Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases Determination Work , Qingyuan District (Ji'an
City, Jiangxi Province) Bureau of Commerce, Gan Shang Wai Mao Zi [2012] No. 60
(28 April 2012).

46. Sichuan Provincial Commerce Department Notice on Carrying Out the Second Batch of
National Foreign Trade Transformation and Upgrading Specialized Demonstration Bases
Application Work , Sichuan Province Department of Commerce, Chuan Shang Mao [2012]
No. 42 (3 May 2012).

47. Beijing Municipality Opinions on Accelerating Foreign Structural Adjustment Transformation
of the Foreign Trade Development Mode , Beijing Municipal Commission of Commerce,
Municipal Bureau of Finance, Jing Shang Wu Wai Yun Zi [2012] No. 7 (25 April 2012).

48. Zhejiang Province Department of Commerce Passi ng on the Ministry of Commerce Notice on
Carrying Out the Second Batch of National Foreign Trade Transformation and Upgrading
Specialized Demonstration Bases Determination Work , Zhejiang Province Department of
Commerce, Zhe Shang Wu Mao Fa [2012] No. 134 (23 April 2012).

49. Hebei Province Foreign Trade Development Twelfth Five-Year Plan , Hebei Province
Department of Commerce (9 April 2012).

50. Notice on Carrying Out the 2011 Heilongjiang Province Foreign Trade Transformation Base
Cultivation Work , Heilongjiang Province Department of Commerce, Hei Shang Mao Han
[2012] No. 233 (13 March 2012).

51. Notice on the Implementation of Accelerating the Promotion of Fruit Exports Transformation
and Upgrading Demonstration Base Construction , Weinan City (Shaanxi Province) People's
Government, Wei Zheng Ban Fa (2012) No. 81 (27 April 2012).

52. Public Notice on the First Batch of the Guan gdong Province Foreign Trade Transformation
and Upgrading Specialized Demonstration Bases List , Guangdong Province Foreign Trade
Transformation and Upgrading Demonstration Bases Cultivation Work Leading Small Group
(22 November 2011).

53. Notice on Doing Well the 2011 Guangdong Prov ince Foreign Trade Transformation and
Upgrading Demonstration Bases Construction Fund Use and Administration , Guangdong
Province Department of Foreign Trade and Economic Cooperation, Bureau of Finance, Yue
Wai Jing Mao Gui Cai Zi [2011] No. 23 (13 October 2011).

54. Opinions on the Guidance of Carrying Out th e Foreign Trade Transformation and Upgrading
Demonstration Bases Cultivation Work , Guangdong Province Foreign Trade Transformation
and Upgrading Demonstration Bases Cultivation Work Leading Small Group, Yue Wai Jing
Mao Ting Zi [2011] No. 10 (22 August 2011).

55. Guangdong Province Interim Measure on the Administration of Foreign Trade Transformation
and Upgrading Specialized Demonstration Bases , Guangdong Province Foreign Trade
Transformation and Upgrading Demonstration Bases Cultivation Work Leading Small Group,
Yue Wai Jing Mao Guan Zi [2011] No. 31 (22 August 2011).

56. Public Notice on the First Batch of the Shando ng Province Foreign Trade Transformation and
Upgrading Specialized Demonstration Bases List , Shandong Province Department of
Commerce (20 December 2011).

57. Notice on Carrying Out the First Batch of Shandong Province Foreign Trade Transformation
and Upgrading Specialized Demonstration Bases Determination Work , Shandong Province
Department of Commerce (13 September 2011).

58. Opinions on Accelerating the Promotion of Foreign Trade Transformation and Upgrading
Demonstration Bases Construction , Shandong Province Department of Commerce,
Department of Finance, Lu Shang Wu Wai Mao Zi [2011] No. 609 (29 August 2011).

59. Opinions on the Implementation of Accelerating the Promotion of Foreign Trade
Transformation and Upgrading Demonstration Bases Construction , Weifang City (Shandong
Province) People's Government, Wei Zheng Ban Zi [2011] No 44 (22 March 2011).

B. Common Service Platform Instruments

Central Level

60. Ministry of Finance, Ministry of Commerce Notice on the 2014 Foreign Trade Development
Special Fund Application Work , Ministry of Finance, Ministry of Commerce, Cai Qi [2014]
2014 No. 58 (17 April 2014).

61. Measure on the Administration of the Foreign Trade Development Special Fund , Ministry of
Finance, Ministry of Commerce, Cai Qi [2014] No. 36 (9 April 2014).

62. Ministry of Finance, Ministry of Commerce Notice on Doing Well the Administrative Work of
the 2013 Foreign Trade Common Service Platform Construction Fund , Ministry of Finance,
Ministry of Commerce, Cai Qi [2013] No. 101 (28 May 2013).

63. Ministry of Finance, Ministry of Commerce Notice on the Revocation of Documents Related to
the Foreign Trade Common Service Platform Construction Fund, Ministry of Finance, Ministry
of Commerce, Cai Qi [2013] No. 293 (30 September 2013).

64. State Council General Office Several Opinions on Promoting Foreign Trade Steady Growth ,
State Council, Guo Ban Fa [2012] No. 49 (16 September 2012).

65. Ministry of Finance, Ministry of Commerce Notice on Doing Well the Administrative Work of
the 2012 Foreign Trade Common Service Platform Construction Fund , Ministry of Finance,
Ministry of Commerce, Cai Qi [2012] No. 147 (20 June 2012).

66. Ministry of Finance, Ministry of Commerce Notice on Doing Well the Administrative Work of
the 2011 Foreign Trade Common Service Platform Construction Fund , Ministry of Finance,
Ministry of Commerce, Cai Qi [2011] No. 88 (April 2011).

67. Ministry of Finance Notice on Arranging the 2011 Foreign Trade Common Service Platform
Construction Fund, Ministry of Finance, Cai Qi [2010] No. 245 (No Date).

Sub-Central Level

68. Shanghai Municipality Rule on the Implementation of the Foreign Trade Development Special
Fund, Shanghai Municipal Commission of Commerce, Municipal Finance Bureau, Hu Shang
Cai [2015] No. 26 (19 January 2015).

69. Beijing Municipality Rule on the Implementation and Administration of the Foreign Trade
Development Fund, Beijing Municipal Bureau, Municipal Commission of Commerce, Jing Cai
Qi [2014] No. 2494 (5 December 2014).

70. Tianjin Municipality Rule on the Implementation of the Measure for the Administration of the
Foreign Trade Development Special Fund , Tianjin Municipal Finance Bureau, Commission of
Commerce, Jin Cai Qi [2014] No. 29 (28 August 2014).

71. Fujian Province Measure on the Implementation and Administration of the Central Foreign
Trade Development Special Fund , Fujian Province Department of Finance, Department of
Commerce, Min Cai Wai [2014] No. 36 (29 August 2014).

72. Xiamen City Rule on the Implementation of the Foreign Trade Development Special Fund,
Xiamen (Fujian Province) Municipal Bureau of Finance, Municipal Bureau of Commerce, Xia
Cai Qi [2014] No. 36 (22 September 2014).

73. Guangdong Province Department of Commerce, Guangdong Province Department of Finance
Notice on Doing Well the Application Work of the 2014 Foreign Trade Development Special

Fund Foreign Bases and Enterprise Upgrading Internalization Business Capability Projects ,
Guangdong Province Department of Commerce, Department of Finance, Yue Shang Wu Cai
Han [2014] No. 113 (24 September 2014).

74. Advance Notice on Doing Well the Application Work of the 2014 Foreign Trade Development
Special Fund Foreign Trade Common Service Platform Projects , Nanhai District (Foshan City,
Guangdong Province) Economic and Science and Technology Promotion Bureau Foreign
Trade Development Division (23 September 2014).

75. Public Notice on the 2014 Second Batch Foreign Trade Transformation and Upgrading
Projects, Hebei Province Department of Commerce, Department of Finance
(13 November 2014).

76. Public Notice on the 2014 First Batch Foreig n Trade Transformation and Upgrading Projects ,
Hebei Province Department of Commerce, Department of Finance (21 October 2014).

77. Rule on the Implementation of the Foreign Trade Development Special Fund, Henan Province
Department of Commerce, Yu Cai Qi [2014] No. 82 (14 October 2014).

78. Hunan Province Department of Commerce Notice on Allocating the Foreign Trade
Development Fund, Hunan Province Department of Commerce (28 August 2014).

79. Rule on the Implementation and Administrati on of the Central Foreign Trade Development
Special Fund , Sichuan Province Department of Fina nce, Department of Commerce, Chuan
Cai Jian [2014] No. 163 (10 September 2014).

80. Sichuan Province Department of Commerc e Notice on 2014 Central Foreign Trade
Development Special Fund Application Work , Sichuan Province Department of Finance,
Department of Commerce, Chuan Cai Jian [2014] No. 174 (24 September 2014).

81. Notice on Filing the 2014 Foreign Trade Development Special Fund Application Work ,
Xinjiang Uygur Autonomous Region Department of Commerce, Xing Shang Fa [2014]
No. 171 (1 September 2014).

82. Zhejiang Province Rule on the Implementati on of the Foreign Trade Development Special
Fund, Zhejiang Province Department of Financ e, Department of Commerce, Zhe Cai Qi
[2014] No. 145 (7 August 2014).

83. Notice on Doing Well the 2014 Foreign Trade Development Special Fund Application Work ,
Zhejiang Province Department of Commerce, Department of Finance, Zhe Shang Wu Lian Fa
[2014] No. 116 (2 September 2014).

84. Dalian City Rule on the Implementation of the Measure for the Administration of the Foreign
Trade Development Special Fund , Dalian Municipal (Liaoning Province) Bureau of Finance,
Foreign Trade and Economic Cooperation Bureau, Da Cai Qi [2014] No. 677
(27 August 2014).

85. Notice on Applying for the 2014 Foreign Trade Development Special Fund (Promotion of
Foreign Trade Transformation and Upgrading) , Rongchang City (Shandong Province) Bureau
of Commerce, Bureau of Finance (5 September 2014).

86. Public Notice on the Planned 2013 Foreign Trade Common Service Platform Construction
Special Fund Supported Projects , Shanghai Municipal Commission of Commerce
(1 December 2014).

87. Interim Measure on the Administration of the Chongqing Municipality Foreign Trade Common
Service Platform Construction Fund
, Chongqing Municipality Foreign Trade and Economic
Relations Commission, Finance Bureau, Yu Wai Jing Mao Fa [2014] No. 79 (22 September
2014).

88. Notice on the Application for the Surplus Ov er the Years of the Guangxi Foreign Trade
Common Service Platform Construction Projects , Guangxi Zhuang Autonomous Region

Department of Commerce, Department of Finance, Gui Shang Cai Fa [2014] No. 3
(5 March 2014).

89. Notice on Doing Well the Application Work of the 2014 Foreign Trade Common Service
Platform Construction Fund Projects , Shaanxi Province Department of Commerce,
Department of Finance (4 April 2014).

90. Public Notice on the Planned 2013 Henan Prov ince Foreign Trade Common Service Platform
Construction Fund Supported Projects, Puyang City (Henan Province) Bureau of Commerce,
Bureau of Finance (25 December 2014).

91. Notice on Doing Well the Application Work of the 2013 Xuchang City Foreign Trade Export
Base Common Service Platform Fund Projects , Xuchang City (Henan Province) Bureau of
Commerce, Bureau of Finance (11 November 2014).

92. Nanyang City Foreign Trade Common Service Platform Construction Fund List of Supported
[Projects], Nanyang City (Henan Province) Bure a u o f F i n a n c e , B u r e a u o f C o m m e r c e
(2 December 2014).

93. Notice on Disbursing the 2014 Foreign Trade Common Service Platform Construction Fund ,
Nanyang City (Henan Province) Bureau of Finance, Wan Cai Yu [2014] No. 791 (2014).

94. Notice on Doing Well the Application and Administrative Work of the Foreign Trade Common
Service Platform Construction Fund , Baoying County (Yangzhou City, Jiangsu Province)
Bureau of Commerce, Bureau of Finance, Bao Shang [2014] No. 51, Bao Cai Gong Mao
[2014] No. 16 (28 August 2014).

95. Advance Notice on Applying for the 2014 Foreign Trade Common Service Platform Support ,
Dongguan City (Guangdong Province) Bureau of Commerce (22 September 2014).

96. Notice on Carrying Out the Application for the 2014 Hangzhou City Foreign Trade Common
Service Platform Projects , Hangzhou City, Xiaoshan District (Hangzhou City, Zhejiang
Province) Bureau of Commerce, Bureau of Finance (10 December 2014).

97. Notice on the Second and Third Batch Foreign Trade Common Service Platform Construction
Fund Project Review Work, Xiamen (Fujian Province) Municipal Bureau of Commerce, Bureau
of Finance, Xia Shang Wu [2014] No. 230 (3 September 2014).

98. Notice on the Application for the Sixth Batch Foreign Trade Common Service Platform
Construction Fund Projects , Xiamen (Fujian Province) Municipal Bureau of Commerce,
Bureau of Finance, Xia Shang Wu [2014] No. 206 (30 July 2014).

99. Notice on Disbursing the 2013 Foreign Trade Common Service Platform Construction Fund ,
Xinjiang Production and Construction Corps, Second Division (Xinjiang Uygur Autonomous
Region) Bureau of Finance, Shi Cai Fa [2014] No. 75 (No Date).

100. Notice on Organizing the Application for the 2013 Jilin Province Foreign Trade Common
Service Platform Construction Fund Project , Jilin Province Department of Commerce,
Department of Finance (29 September 2013).

101. Notice on Doing Well the Application Work of the 2012-2013 Foreign Trade Common Service
Platform Construction Fund Projects , Hainan Province Department of Commerce,
Department of Finance, Qiong Shang Wu Mao [2013] No. 167 (15 May 2013).

102. Hainan Province Public Notice on the Pla nned 2012-2013 List of Supported Foreign Trade
Common Service Platform Projects , Hainan Province Department of Commerce
(12 September 2013).

103. Notice on Doing Well the Administrative Work of the 2013 Foreign Trade Common Service
Platform Construction Fund , Zhejiang Province Department of Commerce, Department of
Finance, Zhe Shang Wu Lian Fa [2013] No. 84 (26 July 2013).

104. Notice on Applying for the 2013 Foreign Trade Common Service Platform Support Fund ,
Fujian Province Department of Foreign Trad e and Economic Cooperation, Department of
Finance, Min Wai Jing Mao Ji Cai [2013] No. 44 (16 July 2013).

105. Notice on the Administrative and Application Work of the 2013 Foreign Trade Common
Service Platform Construction Fund, Hunan Province Department of Commerce, Department
of Finance, Xiang Shang Mao Fa [2013] No. 29 (16 July 2013).

106. Public Notice on the 2013 "Foreign Trade Common Service Platform" Determination Results,
Hunan Province Department of Commerce (9 July 2013).

107. Supplemental Notice on Applying for the 2013 Foreign Trade Common Service Platform
Construction Fund Projects , Anhui Province Bureau of Commerce, Wan Shang Chan Han
[2013] No. 11 (24 April 2013).

108. Notice on Doing Well the Administrative Work of the 2013 Foreign Trade Common Service
Platform Construction Fund , Hebei Province Department of Finance, Department of
Commerce, Ji Cai Qi [2013] No. 9 (10 April 2013).

109. Qinghai Province Opinions on the Administrati on and Implementation of the Foreign Trade
Common Service Platform Construction Fund , Qinghai Province Department of Commerce,
Department of Finance, Qing Shang Ji Dian Zi [2013] No. 155 (14 May 2013).

110. Qinghai Province Department of Commerce Noti ce on Organizing the Application of 2013
Foreign Trade Common Service Platform Construction Projects, Qinghai Province Department
of Commerce (14 April 2013).

111. Notice on Doing Well the Administrative Work of the 2013 Foreign Trade Common Service
Platform Construction Fund , Shandong Province Department of Finance, Department of
Commerce, Lu Cai Qi [2013] No. 38 (31 July 2013).

112. Notice on Doing Well the Administrative Work of Our [Autonomous] Region 2013 Foreign
Trade Common Service Platform Construction Fund , Xinjiang Uygur Autonomous Region
Department of Commerce, Department of Finance, Xin Shang Fa [2013] No. 163 (21 August
2013).

113. Notice on Doing Well the Administrative Work of the Tianjin Municipality 2013 Foreign Trade
Foreign Trade [sic] Common Service Platform Construction Fund , Tianjin Commission of
Commerce, Finance Bureau, Jin Cai Qi Er [2013] No. 9 (No Date).

114. Notice on Doing Well the Application Work of the 2013 Guizhou Province Foreign Trade
Common Service Platform Construction Fund Projects, Qian Shang Fa [2013] No. 69 (2013).

115. Notice on Doing Well the Administrative Work of the Liaoning Province 2013 Foreign Trade
Common Service Platform Construction Fund, Liao Cai Liu [2013] No. 515 (2013).

116. Notice on Issuing the Administrative Meas ure on the Guangxi Foreign Trade Common
Service Platform Construction Fund , Guangxi Zhuang Autonomous Region Department of
Finance, Department of Commerce, Gui Cai Shang [2013] No. 62 (11 September 2013).

117. Notice on Doing Well the Administrative Work of the 2013 Foreign Trade Common Service
Platform Construction Fund , Jiangsu Province Department of Finance, Department of
Commerce, Su Cai Gong Mao [2013] No. 154 (8 November 2013).

118. Notice on Doing Well the Administrative Work of the 2013 Guangdong Province Foreign
Trade Common Service Platform Construction Fund
, Guangdong Province Department of
Foreign Trade and Economic Cooperation, Department of Finance, Yue Wai Jing Mao Cai Zi
[2013] No. 12 (17 September 2013).

119. Notice on Doing Well the Application Work of the 2013 Foreign Trade Common Service
Platform Construction Projects , Longquan City (Zhejiang Province) Bureau of Commerce,
Bureau of Finance (5 September 2013).

120. Notice on Doing Well the Administrative Work of the 2013 Foreign Trade Common Service
Platform Construction Fund, Xiaoshan District (Hangzhou City, Zhejiang Province) Bureau of
Commerce (27 August 2013).

121. Notice on Doing Well the Application Work of the 2013 Foreign Trade Common Service
Platform Construction Fund, Zhengzhou City (Henan Province) Bureau of Commerce (9 July
2013).

122. Xuchang City Bureau of Commerce Notice on Strengthening the Work of the Foreign Trade
Common Service Platform Construction , Xuchang City (Henan Province) Bureau of
Commerce, Xu Shang Wu Zi [2013] No. 7 (15 January 2013).

123. Notice on Disbursing the 2013 Foreign Trade Common Service Platform Construction Fund ,
Nanyang City (Henan Province) Bureau of Finance, Wan Cai Yu [2013] No. 865 (2013).

124. Report on Submitting the 2013 Shaanxi Province Foreign Trade Common Service Platform
Construction Fund Projects, Yan'an City (Shaanxi Province) Bureau of Commerce, Bureau of
Finance, Yan Shi Shang Zi [2013] No. 83.

125. Wuxi City Public Notice on the Foreign Trade Common Service Platform Projects , Wuxi City
(Jiangsu Province) Bureau of Commerce, Bureau of Finance (16 July 2013).

126. Notice on the Application Work of the 2013 Foreign Trade Common Service Platform
Construction Fund , Nantong City (Jiangsu Province) Bureau of Commerce, Bureau of
Finance, Tong Shang Fa [2013] No. 226 (15 November 2013).

127. Kunming City (Interim) Measure on the Administration of the Foreign Trade Common
Service Platform Construction Fund , Kunming City (Yunnan Province) Bureau of Finance,
Bureau of Commerce, Kun Cai Qi Er [2013] No. 103 (29 September 2013).

128. Xiamen City Measure on the Administration and Use of the Foreign Trade Common Service
Platform Construction Fund , Xiamen (Fujian Province) Municipal Bureau of Commerce,
Bureau of Finance, Xia Shang Wu [2013] No. 339 (22 October 2013).

129. Notice on Doing Well the Administrative Work of the 2013 Foreign Trade Common Service
Platform Construction Fund , Qingdao City (Shandong Province) Department of Finance,
Department of Commerce, Qing Cai Qi [2013] No. 34 (7 August 2013).

130. Notice on Doing Well the Administrative Work of the 2012 Guangdong Province Foreign
Trade Common Service Platform Construction Fund , Guangdong Province Department of
Foreign Trade and Economic Cooperation, Depart ment of Finance, Yue Wai Jing Mao Gui Cai
Zi [2012] No. 18 (17 September 2012).

131. Notice on Doing Well the Administrative Work of the 2012 Foreign Trade Common Service
Platform Construction Fund , Jiangsu Province Department of Finance, Department of
Commerce, Su Cai Gong Mao [2012] No. 107 (29 August 2012).

132. Notice on Doing Well the Application Work of the 2012 Guizhou Province Foreign Trade
Common Service Platform Construction Fund Projects , Guizhou Province Department of
Commerce, Qian Shang Fa [2012] No. 199 (14 August 2012).

133. Notice on Doing Well the Administrative Work of the 2012 Foreign Trade Common Service
Platform Construction Fund, Hebei Province Department of Commerce, Ji Cai Qi [2012] No.
36 (17 May 2012).

134. Notice on Disbursing the 2012 Foreign Trade Common Service Platform Construction Fund,
Hebei Province Department of Finance, Ji Cai Qi [2012] No. 111 (No Date).

135. Notice on Plan for Applying for the 2012 Foreign Trade Common Service Platform
Construction Project, Zhejiang Province Department of Commerce, Department of Finance,
Zhe Shang Wu Lian Fa [2012] No. 46 (23 April 2012).

136. Notice on the Strengthening the Foreign Trade Common Service Platform Construction Work,
Zhejiang Province Department of Commerce, Department of Finance, Zhe Shang Wu Lian Fa
[2012] No. 27 (2 March 2012).

137. Notice on Recruiting 2012 Foreign Trade Common Service Platform Project, Qinghai Province
Department of Commerce, Department of Finance (16 March 2012).

138. Beijing Municipal Commission of Commerce Reply on Disbursing the 2011 Beijing Foreign
Trade Common Service Platform Construction Fund , Beijing Municipal Commission of
Commerce, Jing Shang Wu Cai Wu Zi [2012] No. 54 (2012).

139. Notice on Disbursing the Foreign Trade Common Service Platform Construction Fund ,
Liaoning Province Department of Finance, Liao Cai Zhi Liu [2012] No. 1231 (2012).

140. Anhui Province Department of Finance Notice on Disbursing the 2012 First Batch Foreign
Trade Common Service Platform Construction Fund [Quota], Cai Qi [2012] No. 1592 (2012).

141. Notice on Disbursing the 2012 Foreign Trade Common Service Platform Construction Fund ,
Xinjiang Production and Construction Corps (Xinjiang Uygur Autonomous Region) Bureau of
Finance, Shi Cai Fa [2012] No. 665 (No Date).

142. Notice on Application Matters [Regarding] the 2012 Foreign Trade Common Service Platform
Construction Fund, Yantai City (Shandong Province) Bureau of Commerce (2 July 2012).

143. Notice on Disbursing the 2012 Inner Mongolia Autonomous Region Foreign Trade Common
Service Platform Construction Fund , Huhehaote City (Inner Mongolia Autonomous Region)
Bureau of Finance, Hu Cai Gong [2012] No. 69 (2012).

144. Notice on Disbursing the 2012 Foreign Trade Common Service Platform Construction Fund ,
Xingtai City (Hebei Province) Bureau of Finance, Xing Shi Cai Shang [2012] No. 37 (2012).

145. Xiamen City Measure on the Administration and Use of the Foreign Trade Common Service
Platform Construction Fund , Xiamen (Fujian Province) Municipal Bureau of Commerce,
Bureau of Finance, Xia Shang Wu [2013] No. 160 (8 May 2013).

146. Notice on Carrying Out the Application Work of the 2011 Chongqing Municipality Foreign
Trade Common Service Platform Construction Fund Support Projects , Chongqing Municipal
Foreign Trade and Economic Relations Commission, Finance Bureau, Yu Wai Jing Mao Fa
[2011] No. 325 (31 August 2011).

147. Notice on Doing Well the Administrative Work of the 2011 Foreign Trade Common Service
Platform Construction Fund , Hebei Province Department of Commerce, Ji Cai Qi [2011]
No. 62 (4 July 2011).

148. Notice on Doing Well the Application Work of the 2011 Foreign Trade Common Service
Platform Construction Fund Projects , Shaanxi Province Department of Commerce,
Department of Finance (10 June 2011).

149. Notice on Applying for the 2011 Qinghai Province Foreign Trade Common Service Platform
Construction Fund Project , Qinghai Province Department of Commerce, Qing Shang Mao Zi
[2011] No. 105 (15 March 2011).

150. Notice on Doing Well the Work of Administrating and Using the 2011 Foreign Trade Common
Service Platform Construction Special Fund , Shandong Province Department of Finance,
Department of Commerce, Lu Cai Qi [2011] No. 36 (26 July 2011).

151. Notice on Doing Well the Administrative Work of the 2011 Guangdong Province Foreign
Trade Common Service Platform Construction Fund , Guangdong Province Department of
Foreign Trade and Economic Cooperation, Depart ment of Finance, Yue Wai Jing Mao Gui Cai
Zi [2011] No. 20 (25 August 2011).

152. Notice on Doing Well the Administrative Work of the 2011 Foreign Trade Common Service
Platform Construction Special Fund , Zhejiang Province Department of Finance, Department
of Commerce, Zhe Cai Qi [2011] No. 206 (18 July 2011).

153. Notice on Organizing the Application for the 2011 Jilin Province Foreign Trade Common
Service Platform Construction Fund Project , Jilin Province Department of Finance, Ji Cai Qi
[2011] No. 503 (12 August 2011).

154. Notice on Organizing the Application for the 2011 Shanghai Municipality Foreign Trade
Common Service Platform Construction Fund Project , Shanghai Municipal Commission of
Commerce, Municipal Finance Bureau (19 April 2012 [sic]).

155. Notice on Carrying Out the Application for the 2011 Foreign Trade Export Base Common
Service Platform Construction Fund Project , Hangzhou City (Zhejiang Province) Bureau of
Foreign Trade and Economic Cooperation, Bureau of Finance (19 September 2011).

156. Notice on Doing Well the Administrative Work of the 2011 Foreign Trade Common Service
Platform Construction Fund , Ningbo City (Zhejiang Province) Bureau of Foreign Trade and
Economic Cooperation, Bureau of Finance, Yong Cai Zheng Wai [2011] No. 635, Yong Wai
Jing Mao Mao Guan [2011] No. 60 (1 July 2011).

157. Public Notice on the Xiamen City First Batch Foreign Trade Common Service Platform
Project, Xiamen (Fujian Province) Municipal Bureau of Trade Development
(31 January 2011).

158. Xiamen City Measure on the Administration and Use of the Foreign Trade Common Service
Platform Construction Fund , Xiamen (Fujian Province) Municipal Bureau of Commerce,
Bureau of Finance, Xia Shang Wu Gui Cai [2011] No. 275 (24 June 2011).

159. Notice on Doing Well the Use and Administrative Work of the 2011 Shenzhen City Central
Foreign Trade Common Service Platform Construction Fund , Shenzhen City (Guangdong
Province) Economic Trade and Information Commission, Shen Ke Gong Mao Xin Ji Cai Zi
[2011] No. 184 (9 November 2011).

160. Notice on 2014 Our Province's Application Work for the Foreign Trade Promotion Policy Fund
Projects, Anhui Province Bureau of Commerce, Department of Finance (4 April 2014).

161. Notice on Provincial Level 2014 Application Work for the Foreign Trade Promotion Policy
Fund Projects, Wuhu City (Anhui Province) Bureau of Commerce (10 April 2014).

162. Fujian Province Interim Measure on the Administration of the Trade Promotion Special Fund
Use, Fujian Province Department of Finance, Department of Commerce, Min Cai Wai [2014]
No. 38 (10 September 2014).

163. Luoyang City Commerce Bureau Notice on the Supplemental Submission of the 2014 Foreign
Trade Promotion Fund Projects , Luoyang Municipal (Henan Province) Bureau of Commerce
(14 March 2014).

164. Several Measures on Supporting Foreign Trade Steady Growth , Beijing Municipality People's
Government Office, Jing Zheng Ban Fa [2014] No. 55 (14 October 2014).

165. Jiangxi Provincial People's Government Office Opinions on the Implementation of the
Support of the Entire Province's Foreign Trade Steady Growth , Jiangxi Provincial People's
Government, Gan Fu Ting Fa [2014] No. 37 (27 August 2014).

166. Several Measures on Supporting Foreign Trade Steady Growth , Beijing Municipality People's
Government Office, Jing Zheng Ban Fa [2014] No. 55 (14 October 2014).

Because the Demonstration Base / Common Service Platform program and export subsidies under
that program, as reflected in the instruments listed in Sections I.A and I.B, are subsidies
contingent upon export performance provided to enterprises located in China, the measures

appear to be inconsistent with Article 3.1(a) of the SCM Agreement, and China appears to have
acted inconsistently with Article 3.2 of the SCM Agreement.

II. Demonstration Base Grant Programs and Subsidies

It appears that China provides export-contingen t subsidies through nine programs that provide
grants to entities participating in the Demonstration Base program. As noted, China designates an
industrial cluster of enterprises in a particular industry as a Demonstration Base, based on, inter
alia, export performance.

Each program and the export subsidies under that program are reflected in the nine respective
legal instruments below, operating in conjunction with the Demonstration Base program (as
reflected in the legal instruments set out in Section I.A), as well as any amendments or related,
successor, replacement, or implementing measures:

167. Bao'an District Several Measures on Further Promoting Taiwanese Enterprise Transformation
and Upgrading , Communist Party of China Shenzhen City Committee Bao'an District
(Guangdong Province) United Front Department (1 March 2013).

168. Zhuhai City Measure on the Administration of Expanding Import Special Supporting Funds ,
Zhuhai City Science and Technology Department, Zhuhai City Bureau of Finance, Zhu Ke
Gong Mao Xin [2012] No. 114 (9 October 2012).

169. Dabu County Preferential Measure on Accelerating the Ceramics Industry Development ,
Dabu County (Meizhou City, Guangdong Provin ce) People's Government, Bu Fu Ban [2012]
No. 84 (5 September 2012).

170. Foshan City Nanhai District Measure for Promoting Brand Strategy and Indigenous
Innovation Assistance and Rewards , Nanhai District (Foshan City, Guangdong Province)
People's Government, Nan Fu [2012] No. 85 (24 February 2012).

171. Longhua New District Several Measures on Accelerating the Promotion of Industrial
Transformation and Upgrading, Longhua New District (Shenzhen City, Guangdong Province)
Economic Services Bureau (28 August 2012).

172. Make Robust Institutional Systems and Accelera te Promotion and Implementation to Create
Poultry Foreign Trade Transformation and Upgrading Demonstration Bases , Zhucheng City
(Shandong Province) Bureau of Commerce (14 January 2013).

173. Weifang City 2012 Support Foreign Economic and Trade Development Policies , Weifang City
Bureau of Finance, Weifang City (Shandong Province) Bureau of Commerce, Wei Cai Qi
[2012] No. 73 (5 May 2012).

174. Tai'an City Twelfth Five-Year Financial Resources Construction Policies Guideline , Tai'an City
(Shandong Province) Financial Resources Construction Leading Small Group Office, Tai Cai
Yuan Ban [2012] No. 4 (16 April 2012).

175. Wenzhou City People's Govern ment Several Opinions on Promoting Foreign Trade Growth ,
Wenzhou City (Zhejiang Province) People's Government, Wen Zheng Fa [2012] No. 63
(11 July 2012).

Because each program and the subsidies under the program, as reflected in the instruments
referred to above, are subsidies contingent upon export performance provided to enterprises
located in China, the measures appear to be inconsistent with Article 3.1(a) of the SCM
Agreement, and China appears to have acted inconsistently with Article 3.2 of the SCM Agreement.

Therefore, the United States respectfully requests, pursuant to Article 6 of the DSU and Article 4.4
of the SCM Agreement, that the Dispute Settlem ent Body ("DSB") establish a panel to examine
this matter, with standard terms of reference as set out in Article 7.1 of the DSU. Pursuant to
Article 4.4 of the SCM Agreement, the panel shall be established immediately, unless the DSB
decides by consensus not to establish a panel.