REPORT OF
THE COMMITTEE TO THE COUNCIL FOR TRADE IN GOODS
ACTIONS
TAKEN AND DISCUSSIONS ON POSSIBLE FUTURE ACTIONS
TO IMPROVE SUBMISSION OF NOTIFICATIONS
(ADOPTED
ON 28 OCTOBER 2025)
1.1. This report is being prepared at
the request[1] of the Council for Trade in Goods
(CTG) and has been adopted by the Committee on Subsidies and Countervailing
Measures (SCM Committee) on 28 October 2025 for submission to the CTG.
1.2. At its formal meeting of 9 April 2025, the CTG considered a new Secretariat
report entitled "Notifications Status of Regular/Periodic and One Time
Only Notifications in the Goods Area (1995‑2024)" (_G/C/W/859). The report, prepared at the request of the CTG, provides detailed data
on submission rates and trends regarding regular/periodic and one-time
notifications. At the same April 2025 meeting of the CTG, Members recognized
that each subsidiary body is best placed to address the specific notification
obligations within its purview. Accordingly, they agreed that the CTG could
play a coordinating role to support improvements in the overall status of such
notifications, building on the model of the earlier reform by doing
discussions.
1.3. All CTG subsidiary bodies were thus
requested to: (1) discuss the additional steps that could be taken to improve the
regular/periodic and one‑time only notification requirements they oversee;
(2) identify the steps needed to improve the quality and timeliness of
notifications; and (3) inform the Council of past actions that have worked
well in improving the number of submitted notifications. All subsidiary bodies
were also requested to report back to the CTG by 10 November 2025, to
enable consideration at the final formal CTG meeting of the year.
1.4. At its Regular meeting held on 29
April 2025, the outgoing Chair of the SCM Committee made a statement explaining
the above-mentioned details and indicated that this matter would be brought to
the attention of the incoming Chair who would initiate consultations with
Members in this respect.[2]
1.5. On 15
September 2025, Members received a communication inviting them to attend
informal consultations on these issues which were held on 29 September 2025.
During that meeting, concerns were raised regarding the time lag between
subsidy implementation and the review of subsidy notifications, as well as the
limited time available to scrutinize circulated notifications. In addition, one
delegation shared its experiences with efforts to improve the efficiency of
notification preparation, including the exploration of new technological tools
such as artificial intelligence (AI). A separate item was subsequently added to
the agenda of the Committee's regular meeting of 28 October 2025 to
discuss and adopt this report for submission to the CTG.
1.6. This report sets out: (i) past actions taken to improve the number
of notifications submitted; (ii) Secretariat activities undertaken to enhance
transparency under the SCM Agreement; (iii) the role of the Chair and related
Committee deliberations; and (iv) discussions on additional steps to be taken
by the Committee to improve regular/periodic and
one-time only notification requirements, as well as the quality and timeliness
of notifications.
2.1. The Committee on Subsidies and Countervailing Measures has, over the
years, adopted and refined a number of formats and procedures aimed at ensuring
that notifications under the Agreement are made in a consistent and transparent
manner.
2.2. Pursuant to Article 32.6 of the Agreement on Subsidies and
Countervailing Measures (SCM Agreement), Members must notify the full
integrated text(s) of their laws, regulations and administrative procedures in
one of the WTO languages. Any modification to the laws, regulations or
administrative procedures must also be notified promptly. A notification has to
be made even where a Member does not maintain such laws/regulations.
2.3. Legislative notifications are reviewed at the regular meetings of
the SCM Committee. In addition to its general Rules of Procedures, the SCM
Committee adopted specific procedures for the review of legislative
notifications in 1996. These procedures were revised to add further clarity in 2014
(_G/SCM/W/293/Rev.1) which resulted in the retention of all unanswered written
questions covering legislative notifications under review, on the agendas of
the SCM Committee's meetings until written answers are submitted. Legislative
notifications are formatted and circulated by the Secretariat upon receipt.
2.4. Article 25.12 of the SCM Agreement calls for notification of
domestic authorities competent to initiate and conduct countervailing duty
investigations. This notification requirement can be fulfilled by providing to
the Committee the name, address, telephone numbers, and e-mail address(es) of
the investigating authority. There is no standard format for such
notifications.
2.5. The Secretariat circulates prior to each meeting an updated list of
Members' authorities competent to conduct countervailing duty investigations as
notified by Members in _G/SCM/N/18/…
series.
2.6. Article 25.11 of the SCM Agreement requires Members to notify, without delay,
all preliminary or final actions taken with respect to countervailing duties (ad
hoc notifications). It also stipulates that Members shall submit, on a
semi-annual basis, reports on any countervailing duty actions taken within the
preceding six months. In June 1995, the SCM Committee agreed on a standard
format for semi-annual reports (_G/SCM/2) and on the minimum information
to be provided in ad hoc notifications (_G/SCM/3). At its regular meeting on
20 October 2009, the SCM Committee adopted revised versions of these two
notification formats.[3]
2.7. There is a significant number of Members that do not have a competent
authority to conduct countervailing duty investigations and which therefore
have not imposed any countervailing measures and are unlikely to do so in the
foreseeable future. In order to relieve these Members from the obligation to
submit semi-annual reports of countervailing actions, the SCM Committee, at its
regular meeting on 20 October 2009, adopted a one-time notification format (_G/SCM/129).[4] A Member submitting this type of
notification will not be expected to submit semi-annual reports of
countervailing actions until such time as it sets up a competent authority and
starts conducting investigations. This is a tangible
improvement that both provides transparency and assists Members that fall in
that category with fulfilling this notification obligation and obviates the
repeated submission of nil notifications. Currently, forty-four Members belong
in this category. One-time notifications are circulated in the G/SCM/N/202/... series.
2.8. In addition to the circulation of the semi-annual reports, a list developed
by the Secretariat reflecting the status of these notifications for the
relevant reporting period is circulated prior to each meeting.[5] The Secretariat also issues
monthly reports containing information on the different ad hoc
notifications received from Members and provides the
electronic version of such documents to delegates and other government
officials, upon request.[6]
2.9. Article 26.1 of the SCM Agreement stipulates that the SCM Committee shall
examine new and full subsidy notifications of Members in special sessions to be
held every third year and that updating notifications made in the intervening
years are to be examined at each regular meeting of the SCM Committee. In
May 2001, the SCM Committee decided that new and full subsidy notifications
would be made every two years and that the annual updating notifications would
be de-emphasised.[7] The SCM Committee extended this
decision in 2003 and 2005.[8]
2.10. In July 1995, the Committee adopted a questionnaire format for subsidy
notifications under Article 25 of the SCM Agreement and under Article
XVI of the GATT 1994.[9] In November 2003, the SCM
Committee adopted a revised version of this questionnaire format for subsidy
notifications (_G/SCM/6/Rev.1).[10] The adoption of the original
format for subsidy notifications in 1995 and the adoption of the revised format
for subsidy notifications in 2003 were based on discussions in the Working
Party on Subsidy Notifications, which the SCM Committee had established in
February 1995 pursuant to footnote 54 to Article 25.3 of the SCM Agreement.[11]
2.11. Members' subsidy notifications are reviewed at special meetings of the SCM
Committee, which are held back-to-back with its regular meetings. At such
meetings, Members may raise questions regarding a notified programme, the
failure to notify a programme, or the failure to submit any notification. The
procedures followed by the SCM Committee for such reviews, as contained in
document _G/SCM/117, were most recently re-adopted
in April 2025, for the review of 2025 new and full notifications.[12] Written questions and answers
concerning subsidy notifications are circulated in the _G/SCM/Q2/… document series. All unanswered
written questions posed regarding new and full subsidy notifications are
identified in the annotated draft agenda and also retained in the final convening
notice of the special meeting.
2.12. Article 27.13 of the SCM Agreement provides that the provisions of
Part III do not apply to certain subsidies granted within and directly linked
to a privatization programme of a developing country Member—such as debt
forgiveness or subsidies to cover social costs—provided that the programme and
the subsidies are temporary, duly notified to the Committee, and lead to the
eventual privatization of the enterprise concerned. To qualify for this exemption,
any such privatization programme must be notified, following the format in _G/SCM/15.
2.13. Article 27.5 of the SCM Agreement provides that a developing Member which
reaches export competitiveness in a given product has to phase out its export
subsidies for that product within two years. For Members in Annex VII which
reach export competitiveness, this period is eight years. Under Article 27.6,
export competitiveness may be determined either on the basis of a notification
by the developing Member at issue, or on the basis of a computation by the
Secretariat conducted at the request of any Member. No standard format has been
developed for such notifications, and to date, no such notifications have been
submitted.
3.1. The Secretariat
systematically contacts Members
that have not yet submitted their notifications to facilitate their timely
circulation and review at upcoming meetings. It also follows up with Members to
clarify inconsistencies identified in submitted notifications, such as in
countervailing duty semi‑annual reports, and provides informal feedback on
draft notifications upon request.
3.2. In addition, the Secretariat
regularly receives
many delegations (Geneva and capital-based) and responds to all queries related to the notification processes
and the use of relevant data portals.
3.3. Every year since 2009, the Secretariat has prepared, at the request
of Members, a background note offering an overview of how Members have
fulfilled their notification obligations under the SCM Agreement since
1995. The report outlines each of the relevant obligations and presents
detailed information on the extent to which Members have submitted the required
notifications. The Secretariat updates this report twice a year, ahead of the
regular meetings of the SCM Committee, and circulates it in the _G/SCM/W/546/…
series.
3.4. Members that were granted extensions under Article 27.4 pursuant to the
procedures in _WT/L/691 were required, under paragraph
2(c) of the procedures, to submit transparency notifications in respect of each
of the final two-years phase-out period, calendar years 2014 and 2015. The
Members with extensions were to have completed the elimination of their export
subsidies not later than 31 December 2015. They also were required to
provide a final transparency notification in respect of calendar year 2015. The
Secretariat updates and circulates a table showing the status of notifications
and of actions reported by Members with extensions under Article 27.4 in the
revisions of the document _RD/SCM/36.
3.5. The Secretariat has been involved in a series of
projects aimed at digitizing the trade remedy notification process and
improving the way information on the use of trade remedy measures is compiled,
stored and presented to Members.
3.6. A major development in this regard was the launch,
in 2020, of the Countervailing
Notification Portal, which allows
Members to electronically create and submit semi-annual reports through a
dedicated e‑platform while minimizing effort and reducing reporting errors, and
the addition of the "Explore Data" function, which provides online
access to all information submitted by Members in their semi-annual reports.
The Secretariat has given presentations, demonstrations and training sessions
tailored to the needs of individual delegations to increase Members' awareness
of the Portal and its functionality. The
Portal is used extensively by Members to submit their semi-annual reports.
3.7. In parallel, the Secretariat has upgraded and
restructured the anti-dumping and countervailing duty databases, which has
required intensive work with individual Members to clean up past records in
those databases. This work has culminated in the development, by the Rules and
IT Divisions of the WTO Secretariat, of the Trade Remedies Data Portal, a
searchable database of information on trade remedy actions that presents this
information in an accessible, customizable and user‑friendly
manner. This Portal was presented to Members at the regular meeting in October
2022 and went online in November 2022.
3.8. The Secretariat has also developed a separate webpage for the SCM Committee where all
information pertaining to its work and functioning can be found, including all
the different presentations on the submission of notifications and the
functioning of the portal for submission of semi-annual reports.
3.9. In addition, the most recent statistics, based on information from Members'
semi-annual reports, are made available on the WTO's dedicated Subsidies and
Countervailing Measures webpage.
3.10. The Secretariat circulates after each meeting a "deadlines
document" summarizing key upcoming deadlines for notification submissions
and responses to questions raised during SCM Committee meetings. This
supports timely submission of notifications, allows delegations to recapitulate
the deadlines for answers to questions raised in connection to the last meeting
and indicates the future deadlines for documentation to be submitted in
connection with the next meeting.
3.11. Calls for the submission of semi-annual reports are circulated prior
to each notification cycle, followed by a reminder towards the end of the
cycle.
3.12. Furthermore, in advance of the Committee's October meeting each
year, the Secretariat circulates a draft of the annual report for Members'
review. This report includes a series of tables that present the status of
various types of notifications—highlighting both those submitted by Members and
those still outstanding.
3.13. In response to Member requests, and recognizing that capacity
constraints—particularly for LDCs and certain developing Members—can make it
difficult to fulfil transparency obligations, the Secretariat has undertaken
targeted technical assistance initiatives to improve the submission rate of
subsidy notifications under the SCM Agreement.
3.14. In 2023, the Secretariat launched a structured, multi-phase technical
assistance project dedicated to improving the preparation and submission of
subsidy notifications. This initiative was designed to help government
officials understand the requirements of the SCM Agreement and to provide
practical support in drafting and submitting their notifications.
3.15. The project consisted of three phases to be completed over approximately six
months:
Phase 1 - Interactive Training and Peer Exchange: This phase consisted of lectures
and presentations by Secretariat staff, offering a comprehensive overview of
the relevant provisions of the SCM Agreement and guidance on using the _G/SCM/6/Rev.1 format. To enhance practical
understanding, the Secretariat also invited officials from other WTO
Members—both developed and developing—to share their experiences and approaches
on preparing subsidy notifications.
Phase 2 - Drafting of Subsidy Notifications: Participants were expected to
prepare a draft new and full subsidy notification based on actual data. During
this phase, Secretariat staff provided personalized, one-on-one support through
virtual meetings and written feedback.
Phase 3 - Peer Presentation and Review: The final phase provided a
platform for participating officials to present their draft notifications to
their peers and discuss lessons learned. This peer exchange helped participants
refine their submissions and reinforced a shared understanding of good
practices across a diverse group of participating Members.
3.16. The first round of the project, launched in June 2023, extended invitations
to 43 Members, prioritizing LDCs that had not submitted their 2021
notifications and other developing Members with no notifications over the
previous five notification cycles. 23 Members participated actively across all
three phases, and 11 of them subsequently submitted their 2023 subsidy
notifications. These submissions represented approximately 13% of the total
notifications received for that cycle, demonstrating the concrete results of
the initiative.
3.17. The 2024–25 round of the project was launched in December 2024 with
invitations extended to 29 Members, including 16 LDCs. Participation to date
has been limited, with only 10 Members engaging and just two of them having
submitted their 2025 new and full notifications.
3.18. In the context of the reform of the functioning of the SCM Committee
conducted in 2023, training sessions on the functioning of the Committees and
the Members' notifications obligations are being held twice a year. The
presentations made and the audio recording of those sessions have been made
available on the SCM Committee's webpage in three WTO languages for Members to
consult.
3.19. In addition, in response to requests raised during the October 2024
meeting of the SCM Committee, the Secretariat organized a dedicated
training session on 21 January 2025 focused on the preparation and submission
of subsidy notifications. This session was recorded and published in three WTO
languages on the SCM Committee webpage, making it accessible to a wide audience
of officials.
3.20. Moreover, the Secretariat maintains a Technical Cooperation Handbook and sample notifications on its dedicated webpage in all three WTO
languages. These resources, along with the instructions integrated into the Trade Remedies Data
Portal,
provide continuous support for Members outside of the scheduled technical
assistance events.
4.1. At every regular meeting of the SCM Committee, the Chair raises the issue
of missing notifications under each agenda item pertaining to different
notification obligations and strongly urges Members to fulfil their
notification obligations. The Chair's call for notifications and the subsequent
discussions are reflected in both the minutes of the meetings and the annual
reports of the SCM Committee. This call to action is reiterated across
all notification categories: new and full subsidy notifications, legislative
notifications, semi-annual reports, and ad hoc notifications of
countervailing duty actions.
4.2. Since Spring 2009, pursuant to the request of the Chair of the Trade Policy Review Body, the SCM Committee has
discussed, at formal and informal meetings, "ways to improve the
timeliness and completeness of notifications and other information flows on
trade measures". Under this agenda
item, the Chairs provide a status report on the new and full subsidy
notifications and invite Members with pending notifications to update the
Committee about their progress in preparing subsidy notifications. Under
this agenda item, the Chairs regularly remind Members of the assistance offered
by the Secretariat regarding the notification obligations and invite Members
that are having difficulties in complying with their obligations to request
assistance from the Secretariat. The substance of those discussions is
reflected in the minutes of the SCM Committee meetings.
5.1. During the informal consultations held on 29 September 2025,
concerns were raised regarding operational challenges in the subsidy
notification review process, in particular the time lag between subsidy
implementation and subsequent review, as well as the limited time available to
Members for analysing circulated notifications. It was suggested that a balance
should be sought between administrative processing and the need for timely and
meaningful review.
5.2. One delegation shared its initial experience in testing the use of
artificial intelligence (AI) to facilitate the preparation of subsidy
notifications. It emphasized that AI would complement, rather than replace,
expert judgement, and noted the potential benefits of such tools in reducing
administrative burdens, supporting Members with limited resources, enhancing
compliance, and improving the accessibility of subsidy-related data. The
delegation expressed its willingness to share its experience further with
interested Members and the Secretariat.
5.3. It was suggested that the issue of the time lag between the
submission of subsidy notifications and their review by the Committee be
further discussed at the regular meetings under the standing agenda item on
"Improving the Timeliness and Completeness of Notifications and Other
Information Flows on Trade Measures under the SCM Agreement." Members were
also encouraged to exchange experiences that could assist in facilitating the
preparation of notifications, including through the use of technological tools
such as AI.
__________
[2] _G/SCM/M/131,
paras. 164 – 167.
[3] _G/SCM/2/Rev.1
and _G/SCM/3/Rev.1.
[4] _G/SCM/M/71,
para. 129.
[7] _G/SCM/M/30, para. 6.
[8] _G/SCM/M/46, para. 43; _G/SCM/M/53, para. 35.
[10] _G/SCM/M/48, para. 212.
[11] _G/SCM/M/1, para. 84.
[12] _G/SCM/M/131, paras. 118 – 119.