REPORT
WORKSHOP ON Transparency
MONDAY, 12 OCTOBER – tuesday, 13 october 2015
WTO, CENTRE WILLIAM RAPPARD, GeNEVA
Note by the secretariat[1]
The
Secretariat of the World Trade Organization organized a workshop on the transparency
provisions of the Agreement on the Application of Sanitary and Phytosanitary
Measures (SPS Agreement) in Geneva, Switzerland, on 12 and 13 October 2015.
This was the sixth SPS workshop on transparency organized by the
Secretariat, the first five having been held in 1999, 2003, 2007, 2010 and
2012.[2]
The
workshop was open to all Members, Observer governments and organizations with
observer status in the SPS Committee. Various funding arrangements made it
possible for a large number of developing country and least developed country (LDC)
participants to not only attend the workshop but also the subsequent Committee
meeting.[3]
Approximately
150 participants received hands-on training on how to access and use
SPS-related information and how to notify their SPS measures. Participants
also shared national experiences and debated how to further improve
transparency in this area.
The programme[4]
and presentations of the workshop are available from the "Events,
workshops and training" section under the WTO SPS Gateway
(http://www.wto.org/english/tratop_e/sps_e/events_e.htm).
1 background of the workshop
1.1. The workshop programme was developed in light of the SPS Committee's
recent discussions on transparency, following a joint proposal for actions
related to the fulfilment of transparency obligations[5],
submitted in the context of the Fourth Review of the Operation and
Implementation of the SPS Agreement. The analysis of the replies to the transparency
questionnaire circulated to assess the needs and difficulties of Members[6]
provided further input, as well as specific suggestions from Members. In
addition, the workshop provided an occasion to present the on-going project to
improve and modernize the SPS IMS and NSS applications.
2 Objective of the workshop
2.1. The objective of the workshop was to bring together officials from
Members' SPS Enquiry Points, National Notification Authorities and other
relevant authorities for an exchange of experiences and for hands-on training
on the online SPS tools. More specifically, the workshop aimed to:
§ Improve participants' knowledge on how to implement and benefit from
the transparency provisions and procedures of the SPS Agreement, in particular
through the sharing of national experiences;
§ Enhance participants' knowledge of the SPS Information Management
System (IMS) and the new Notification Submission System (NSS) through the use
of practical exercises geared at preparing notifications using the NSS and
searching for information using the IMS; and
§
Identify possible
actions on ways to address issues related to the implementation of the
transparency provisions.[7]
2.2. Overall, the workshop focused on Members' experiences in complying
with the transparency provisions of the SPS Agreement, such as filling in
notifications, tracking notifications, handling comments, and obtaining
translations. Participants also received information on WTO sources of SPS-related
information, and the updates already made and currently under way to the SPS
IMS and SPS NSS. Presentations were made by the WTO Secretariat, the United Nations Department of
Economic and Social Affairs (UN-DESA), and developed
and developing country Members. The workshop provided an open platform for
discussion and sharing of national experiences as well as best practices
concerning the implementation of the transparency provisions. A summary of the
various sessions of the workshop is provided below.
3 workshop sessions
3.1 Session 1: Introduction
3.1. The Secretariat provided an overview
of the transparency provisions of the SPS Agreement included in Article 7 and
Annex B, and of relevant Committee and Ministerial Decisions, in particular the
Recommended Transparency Procedures (G/SPS/7/Rev.3) and the Doha Ministerial
Decision on Implementation-Related Issues and Concerns (WT/MIN(01)/17).
3.2. The Secretariat outlined why transparency was important, for
instance for bringing clarity and predictability to the trading system, for providing
advance warning, or for improving accountability and responsiveness of the
regulatory framework. The main transparency obligations of the SPS Agreement are
to: (i) notify draft SPS regulations; (ii) designate a National Notification
Authority; (iii) establish an Enquiry Point; and (iv) publish SPS regulations. Beyond
obligations, Members can benefit and take advantage of a transparent system,
for example by screening other Members' notifications, as was illustrated in
subsequent sessions of the workshop.
3.3. The Secretariat also provided details on the notification of SPS
regulations, specifically on what to notify, when to notify, which notification
formats to use and the main recommended transparency procedures as outlined in
G/SPS/7/Rev.3. In addition, the institutional arrangements for notifications
were described, specifically the duties and obligations of the National
Notification Authority (NNA) and the Enquiry Point (EP). Lastly, the
Secretariat provided an overview of the transparency timeline, from the
drafting of a regulation to its entry into force.
3.2 Session 2: WTO Sources of Information
3.4. Session 2 provided
participants with a detailed overview of different sources of SPS-related
information. These sources were presented by four speakers from the WTO
Secretariat and one from UN-DESA.
3.5. Mr Stephen Cooper, WTO
Secretariat, presented the new WTO Members' website as a "one-stop
shop" for all the relevant information. Mr Cooper provided a detailed
explanation of how delegates could access and use the website, as well as an
outline of the information available. In particular, delegates could find information
on upcoming SPS Committee meetings and related documents, on any Committee document
and decision, and on other bodies through search and filter functions.
Participants were advised to request login names and passwords from their
respective Members' missions to the WTO in order to access all documents,
including restricted ones.
3.6. Mr John Dickson, WTO Secretariat, provided an
overview of the Documents Online application,
which provides access to all official documentation circulated by the WTO since
1995. The database is updated daily and contains over 100,000 documents in the
three official languages. Different search interfaces allow retrieving any
document, including SPS-related ones. All information is public, except for restricted
documents, which can be accessed with the Members' login names and passwords.
3.7. Mr
Jürgen Richtering, WTO Secretariat, outlined SPS-related information
available at the WTO Integrated Trade Intelligence Portal (I-TIP). Mr
Richtering introduced it as a "one-stop shop" for all trade policy
measure notifications: it was a comprehensive, analytical and easy to use
online tool, which was publically available and provided a unified point of
access to all relevant WTO trade policy information on goods, including tariffs
and non-tariff measures (NTMs). Users could view SPS measures in the context of
other tariff and NTM measures, which could be filtered through specific
criteria, viewed and downloaded.
3.8. Mr
Roland Mollerus, UN-DESA, presented the ePing Toolkit project for
accessing SPS & TBT notifications and alerts. The project had been initiated
after a needs identification study of LDCs had concluded that one of the
existing gaps was the lack of a system to receive alerts of SPS and TBT
notifications relevant to their exports. Users can sign up on the pilot platform
to receive filtered SPS and TBT notifications via emails alerts, sorting
notifications according to specific products or markets of interest. The
platform is accessible to all stakeholders, from government agencies to private
companies. Mr Mollerus highlighted that the benefits of using ePing included
its user-friendly format, the ability to narrow the notifications down
according to areas of interest, the option to export search results, and the
opportunity to discuss notifications at the national level on the platform's
forum.
3.9. Mr
Rolando Alcala, WTO Secretariat, presented the SPS gateway[8]
and the new version of the SPS Information Management System (IMS), currently
under development. The SPS gateway includes information on Committee meetings,
events, training activities etc. It includes information on how to subscribe to
receive document alerts for all unrestricted SPS documents by email. The
gateway also contains a link to the Members' transparency toolkit, which
includes notification templates, and SPS transparency-related documents and
materials.
3.10. Mr Alcala
also introduced the SPS IMS[9],
which aims to help enquiry points and notification authorities, as well as
other interested stakeholders, to keep abreast of new or modified SPS measures.
Since 1995, over 19,000 SPS notifications had been submitted along with over
2,500 other SPS documents and over 390 specific trade concerns (STCs). The SPS
IMS facilitates searching and reporting on SPS notifications, SPS documents,
and STCs according to a wide range of criteria. It also includes the most
up-to-date information available to the Secretariat on the contact details of
Members' Enquiry Points and Notification Authorities. It is publicly available in
English, French and Spanish.
3.11. Mr Alcala
also provided details on the development of the new SPS IMS system, which would
replace the current one. The new system would be more user-friendly and would have
enhanced functionalities. In addition to fixing existing "bugs", it would
be aligned and harmonized with other in-house systems, have streamlined menus,
more intuitive search functionalities, new statistical and graphing functions
and new reporting feature. It was expected that the new IMS platform would be
available for testing during the first semester of 2016.
3.3 Session 3: Practical Session on the Use of the SPS IMS
3.12. Working sessions were organised in English, French and Spanish
during which participants were able to use the current SPS IMS system. In these
groups, participants were able to familiarize themselves with the different
functions of the system by being given a hypothetical scenario of a cocoa
exporting country wishing to obtain relevant information. This included
conducting searches of:
a.
SPS
notifications. Participants learned how to look for a specific notification;
how to find notifications made by a specific country; how to find notifications
covering a specific product; how to find notifications relating to a specific
issue (e.g. contaminants); and how to customize a search;
b.
SPS documents.
Participants learned how to find documents produced by the WTO Secretariat; how
to find documents submitted by Members and Observer Organizations; and how to
find documents concerning a specific issue (e.g. private standards);
c.
Specific trade concerns
(STCs). Participants learned how to access information related to an STC; how
to identify STCs raised in relation to specific Members or products; and
d.
Information on
Enquiry Points and Notification Authorities. Participants learned how to create
contact lists of EPs and NNAs with the use of the predefined reports function;
and how to find their contact details (e.g. address and phone number).
3.4 Session 4: Sharing of National Experiences
3.13. Ms Kimberly Redden,
Analyst at the Canadian Food Inspection Agency, presented on Canada's
experience in tracking, sorting and distributing SPS notifications. Ms Redden
noted that the increased volume of WTO notifications over the past 20 years made
sorting through notifications and disseminating key information to relevant
stakeholders more challenging. To tackle this, Canada used a two-phased
approach: immediate outreach, followed by targeted consultations for government
and industry. This entailed first a daily distribution of notifications by
email to all stakeholders, followed by a weekly distribution of targeted
notifications grouped according to recipients' subjects of interest.
3.14. Ms Mariam Somé Damoué,
Responsible for phytosanitary controls and SPS National Enquiry Point of
Burkina Faso, shared her country's experience with phytosanitary notifications.
Ms Somé described the institutional arrangement in Burkina Faso, where the
national SPS committee is the relevant platform for discussing SPS-related
matters, including notifications. Then Ms Somé presented the phytosanitary
notification process: (i) proposal of the draft text of a measure for
subsequent review and validation by a working group; and (ii) submission of the
measure to the NNA for its notification to the WTO. Ms Somé also explained the
process of managing notifications received from the WTO, citing the specific
examples of mangoes and sesame seeds. Notifications were typically transferred
to relevant focal points, for sorting and distribution. At the end, Ms Somé presented
some recommendations, specifically highlighting the importance of: (i) notifying
all regulatory requirements for agricultural products; (ii) conforming to
international standards, or basing regulations on science where relevant standards
are absent; and (iii) improving access of the private sector to SPS-related
information.
3.15. Ms Virginie Spits,
Member of the EU SPS Team, detailed the European Union's coordination practices
in handling the life cycle of SPS notifications. Ms Spits remarked that
recently the European Union had been looking at whether any changes were
necessary with regards to improving its member States' level of implementation
of the SPS Agreement and the transparency obligations. The presentation began
with an overview of relevant EU authorities for SPS notifications. There is one
central EU SPS Notification Authority and Enquiry Point, which acts on behalf
of the 28 member States. It is the point of reference for coordinating and
monitoring SPS notifications as well as for receiving questions. To better cope
with the increased flow of SPS notifications and their distribution to
relevant stakeholders, the European Union established its own notification database,
which is managed by one person. The database is operated manually, but also
functions automatically by downloading WTO notifications twice a day and
immediately sending out alerts to a mailing list of experts and stakeholder
associations, providing them with more time to comment. Moreover, comments can be
received from experts, European member States and stakeholders. They are then
transferred to the relevant agency for analysis, and subsequent submission to
the issuing Member. Ms Spits finished the presentation by thanking the Members
who play an active role in transparency activities and remarked that the European
Union firmly believed that collaboration was the best way to make the SPS world
more transparent.
3.16. Ms Roxana Inés Vera Muñoz, Coordinator Agreements Unit,
Subdepartment of Negotiations, International Affairs Division, presented on the
functioning of Chile's National Notification Authority. Ms Muñoz explained that
the Chilean system was relatively simple and did not require extensive
resources, yet it enabled its NNA to fully comply with SPS obligations. The
main tools used to manage notifications are well-trained staff, and a computer
with internet access. Four professionals and one coordinator are in charge of
managing incoming information and issuing notifications by email. The team uses
a shared Excel database with notification lists. Ms Muñoz emphasized that the
staff received regular training and that a guidebook on the NNA's operation was
available. The NNA receives information on possible notifications from the
relevant authorities, which are registered in an internal database. Similarly,
notifications received are immediately analysed and circulated through different
lists to a wide range of public and private stakeholders. Lastly, Ms Muñoz
highlighted that the increase in staff and time spent on notifications was a
good indicator of improved transparency, and reiterated the importance of
operational manuals.
3.17. Ms Julia Doherty, Senior Director of SPS &
Agricultural Affairs at the Office of the US Trade Representative, shared the
US experience in implementing the SPS obligation to take comments into account.
Ms Doherty reminded the participants that according to paragraph 5 of Annex B
of the SPS Agreement, Members "shall take the comments and the results of
the discussions into account". This ensured accountability, made
regulations more secure and accessible, reduced the influence of special
interests and thereby created an environment more open to competitive trade and
investment. Ms Doherty shared the US definition for "meaningful
opportunity to comment", as one where the public was able to critique the
proposal and formulate an alternative, and for "significant comments",
as relevant points which might require a change in the proposed rule. The
internal process for taking comments into account is generally the same for all
agencies and provides for good governance by explaining rationale and substance
of final rules in light of comments and by providing step-by-step explanations
for why comments are consequently accepted or rejected. Lastly, Ms Doherty
underscored the need for qualified staff – officials, economists, lawyers – and
the utility of spreadsheets for categorising and grouping.
3.18. Ms Sally Jennings, Senior Policy Analyst at the
Ministry for Primary Industries in New Zealand, highlighted the importance
of communication in ensuring transparency. Ms Jennings accentuated three
specific points in this regard. First was the importance of inter-agency
communication on SPS policy, and the need for staff to be trained on the SPS Agreement
obligations. The second point related to the absence of translations – sometimes
a major inhibition to communication and thus transparency. Members should work
together to share translations of regulations. The last point was on the
utility of the internet in facilitating compliance with transparency
obligations, by making documents easily accessible. Ms Jennings also provided
some tips on how to best include SPS information on government websites by
showcasing the practices in New Zealand. The key messages of the presentation
were: to make sure that SPS regulations were published, provide training on SPS
and transparency, share translations among Members, and use the internet where
possible.
3.19. Morocco took the floor to share
its experience in handling SPS notifications. Morocco highlighted that the creation
of a single national agency responsible for SPS matters, including the NNA and
NEP, made coordination much easier and faster. Morocco also gave an overview of
how notifications were handled in the country and offered to provide assistance
in this regard to other French-speaking African countries.
3.20. Côte d'Ivoire highlighted that
the main problem in Africa was the lack of ownership of SPS measures. It was
important to have motivated and committed individuals to overcome the lack of
political will and to raise awareness among the general public of the
importance of SPS measures.
3.21. Belize shared its experience in establishing the Belize Agricultural
Health Authority (BAHA), which is one body responsible for plant health, animal
health, food safety and quarantine.
3.5 Session 5: 20 Years of Transparency
3.22. The second day of the workshop began with the Secretariat's Overview
Regarding the Level of Implementation of the Transparency Provisions of the SPS
Agreement, based on the latest annual report circulated in document
G/SPS/GEN/804/Rev.8. Since in 2015 the WTO was celebrating its 20-year
anniversary, charts, graphics and statistics reflected information from 1995
until 2015, when possible.
3.23. As of mid-September 2015, 153 of the 161 WTO Members had informed
the Secretariat of their designated SPS National Notification Authority (NNA)
and 157 Members of their SPS National Enquiry Point (NEP). 119 Members out of
161 had submitted at least one SPS notification to the WTO. There were eight Members
who had notified for the first time in 2015: Burkina Faso, Central African
Republic, Guinea, Haiti, Kyrgyz Republic, Nigeria, Togo and Tunisia.
3.24. Since 1995, there had been a general upward trend in the number of
notifications. Considering all types of notifications together, as of
mid-September 2015, Members had submitted a total of 19,062 notifications to
the WTO. In 2014, the number of notifications had reached a new annual peak of
1,633 and the number of notifications continued to be on the rise in 2015.
3.25. Considering notifications by developing country Members (including
LDCs), a similar trend could be observed with a new peak reached in 2014,
surpassing for the first time the 1,000 mark. In terms of the share of total notifications
by developing country Members, it had consistently been higher than 50% since
2007. As of mid-September 2015, it had reached its highest peak of 73%.
3.26. Looking at the geographic regions from which the notifications
originated, the Secretariat noted that over the past 20 years the majority of
notifications had come from the North American region, followed by Asia, and
then South and Central America and the Caribbean.[10]
3.27. Considering relevance of international standards, the Secretariat
recalled that the Recommended Transparency Procedures encouraged Members to
notify all regulations that were based on, conformed to, or were substantially
the same as an international standard, guideline or recommendation, if they were
expected to have a significant impact on trade of other Members. The
Secretariat noted that it was reassuring to observe that the relevant
international standards addressed many emergency situations. Indeed, from 15
September 2014 to 15 September 2015, 95% of emergency notifications had
identified a relevant international standard, out of which 99% had indicated
that the measure conformed to the relevant international standard. For regular
notifications, 53% had identified a relevant international standard, of which
64% had indicated that the proposed regulation conformed to that relevant
standard.
3.28. During the past year, the majority of regular notifications had not
provided specific dates in the fields "proposed date of publication",
"proposed date of adoption" and "proposed date of entry into
force". The recommended 60-day comment period checkbox had been selected
in 58% of regular notifications.[11]
3.6 Session 6: Overview of the SPS NSS
3.29. This session focused on the
fulfilment of one of the obligations contained in the transparency provisions:
notifying SPS measures, whether new or modified. The Secretariat recalled that
notifications could be submitted via email, fax or mail, with the notification
formats provided on the WTO website. However, they could also be submitted
online through the SPS Notification Submission System (SPS NSS). The
system made the processing of notifications easier and substantially faster for
both, Members and the Secretariat. Notifications were also more accurate and
complete. As of October 2015, 66 Members had been given access and 37 had used
it at least once.
3.30. The Secretariat also presented the
new, improved SPS NSS. The new system is more user-friendly, corrects
"bugs" in the current system, and is based on updated technology in
line with other in-house applications such as I-TIP and the TBT NSS. It also
supports rich text format, which was a major limitation in the current system
for some Members. The Secretariat thanked the Members who had participated in
the testing of this pilot platform made available after the 2015 March meeting.
Testing and development of the new platform would continue after the October
meeting. The Secretariat confirmed that an updated procedural manual would be
needed and welcomed any volunteers, thanking Sally Jennings from New Zealand
for writing the old guide with contributions from other Members.
3.31. Several Members highlighted the
advantage of using the online notification system. It reduced errors and time
required to fill in and submit notifications. The new SPS NSS application was expected
to be finalized and launched during the first semester of 2016, in parallel
with the new SPS IMS.
3.7 Session 7: Practical Session on How to Prepare Notifications (SPS
NSS)
3.32. As with the SPS IMS system,
participants had the opportunity to use the new SPS NSS system in a hands-on
exercise in three language groups. Participants used the test site of the new
system to produce a fictional regular notification based on the information
provided.
3.8 Session 8: Improving the Implementation and Benefits of SPS
Transparency Provisions
3.33. Participants engaged in group discussions based on issues that
emerged from the Analysis of the Replies to the Questionnaire on transparency under
the SPS Agreement[12],
and how these could be addressed. These discussions proceeded in four groups (two
in English, one in French and one in Spanish).
3.34. From the transparency questionnaire the following topics emerged:
a.
Difficulties in
filling in notifications;
b.
Identifying trade
facilitating measures;
c.
Identifying and
targeting interested stakeholders;
d.
Handling comments;
e.
Dealing with, and
obtaining translations for, notified documents not in one of the WTO languages.
3.35. Each group was assigned two topics for discussion, the first of
which was the priority, while the second was to be addressed if there was spare
time. Rapporteurs from each group reported on the main issues identified and
possible solutions to the plenary.
3.36. English-speaking group A discussed identifying
and targeting interested stakeholders. The group agreed that bringing
stakeholders together was challenging due to a lack of formal organizations, limited
participation, difficulties to reach outliers and a lack of SPS knowledge and
awareness. Some of the solutions proposed included the development of: (i)
criteria for stakeholder engagement; (ii) global to local engagement; (iii) an
institutional support structure; (iv) a consumer-based advocacy; and (iv) a
legislative framework.
3.37. English-speaking group B first discussed the handling comments.
The group identified some of the main issues, including how to prioritize and
deal with a large volume of comments, how to obtain the opinions of all
relevant stakeholders and how to deal with a lack of resources and political
will. Possible solutions included holding regular public consultations,
developing contact lists of relevant stakeholders, and developing operational
manuals for improving coordination. Secondly, the group discussed difficulties
in dealing with, and obtaining translations for,
notified documents not in one of the WTO languages, including the lack
of human and financial resources. It was suggested that countries cooperate and
share translations, for instance through an informal online platform, akin to
the IPPC ePhyto resource page. Additionally, a register of experts available to
translate documents pro bono (i.e. retired professionals) could be created.
3.38. The French-speaking group discussed the difficulties
in filling in notifications, including collecting relevant data, absence
of legislation, limited access to internet, and lack of collaboration between
the NNA and other competent authorities. Another issue highlighted was the high
turnover of staff in charge of notifications. Solutions proposed included: (i) raising
awareness and links between political and technical authorities; (ii) training
for new staff, including with e-learning modules on notifications; or (iii) South-South
technical assistance (as offered by Morocco).
3.39. The Spanish-speaking group first discussed identifying
trade facilitating measures. A key issue seemed to be the lack of a definition,
and possible restrictive measures being notified as trade facilitating,
obviating the comment period. Possible solutions put forward by the group were
to: (i) request, in accordance with Article 11, a brief justification on the
trade facilitating nature of a measure to be included in the notification; (ii)
organize a thematic sessions to exchange experiences on trade facilitating
measures; and (iii) offer a comment period of 10-15 days for other Members to
comment on the trade-facilitating nature of the notified regulation.[13]
Secondly, the group discussed the difficulties in dealing
with, and obtaining translations for, notified documents not in one of the WTO
languages. Possible solutions identified by the group were to
recommend and encourage Members to use the supplement notification format, to
provide longer comment periods for measures in non-WTO languages (more than 60
days), to ask other developed Members for unofficial translations, and to share
these translations in a more informal way, for example by posting them on a
website.
3.40. The group presentations were followed by questions and comments
which generated interesting discussions on some of the possible solutions
identified.
3.41. In his concluding remarks, the Chairperson highlighted the high
level of participation and interaction in all sessions of the workshop. He
announced his intention to provide a brief report of the workshop to the SPS
Committee. He invited participants to reflect on the suggestions made, which
could inform future discussions in the Committee.
__________
[1] This document has been prepared under the Secretariat's own responsibility
and is without prejudice to the positions of Members or to their rights and
obligations under the WTO.
[2] The reports of these workshops are contained in documents G/SPS/R/16,
G/SPS/R/32, G/SPS/R/47, G/SPS/R/60 and G/SPS/R/68 respectively.
[3] The WTO funded, through assistance from the Doha Development Agenda
Global Trust Fund (DDAGTF), the participation of 51 governmental officials from
developing country Members and Observers. Sponsored
participants were selected from 328 applications. In addition, the African Union made it possible for 25 participants
from French- and English-speaking Africa to participate in the workshop while
12 delegates from Caribbean countries attended with assistance from the Inter-American Institute for Cooperation on
Agriculture (both groups used EU funding).
[5] Joint proposal submitted by Chile, the European Union, Morocco and
Norway (G/SPS/W/278), which built on two former proposals regarding
transparency (G/SPS/W/274 and G/SPS/W/277).
[6] Questionnaire circulated in document G/SPS/GEN/1382, and analysis
of the replies to the questionnaire in document G/SPS/GEN/1402.
[7] These issues emerged from the document on the Analysis of the
Replies to the Questionnaire on Transparency under the SPS Agreement (G/SPS/GEN/1402).
[10] The geographical groupings used rely on WTO working definitions as
identified in the Integrated Database (IDB) for analytical purposes (idb@wto.org). The same groupings are used in the
WTO Annual Reports. They can be consulted through the SPS IMS by clicking on
"definitions of groups" on the left-hand side menu bar.
[11] Annex B, paragraph 5 of the SPS Agreement provides that
notifications should take place at an early stage, when amendments can still be
introduced and comments taken into account. The Recommended Transparency
Procedures state that a 60-day comment period should be provided.
[13] Paragraph 13 of G/SPS/7/Rev.3 encourages Members to allow a period
of at least 60 calendar days for comments, except for proposed measures which
facilitate trade and those which are substantially the same as an international
standard, guideline, or recommendation.