Indonesia's Comments to Brazilian Proposal on Revision of Certain Notifications Format Within Article 12.1a (Initiations)
and Article 9 Footnote 2 of Agreement on Safeguard

Due to technical difficulties during the Committee on Safeguards April 2021 meeting, the following statement could not be provided or read by the delegation of Indonesia at that meeting. Thus, Indonesia asks that this document be circulated to the Members.

1)   Additional data on disaggregated import volume by exporting countries (Art. 12.1(a) notification):

Indonesia is of the view that the valid import volume data can only be collected during, and used for, the investigation. Thus, it is not possible to be provided, especially in the form of disaggregated volume, at the beginning of investigation. In addition, requiring this information to be notified will surely create additional burden for WTO members that will notify the initiation of investigation.

2)   Additional information on list of excluded developing members pursuant to Art. 9 AoS (Art. 12.1(a) notification):

Indonesia believes it is too premature to provide this information when the investigating authority initiate the investigation. The final findings of the investigation will provide the complete information which include whether all conditions to impose safeguard measure have been satisfied and, therefore, some developing members will be excluded from the measures.

3)   Additional data on the import volume of each country, collective data for developing countries and the total volume of imports (Art. 9 Notification):

Indonesia believes that data on import share has sufficiently represented the information needed as stipulated in or required by Art. 9 of the AoS.

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