twentieth
aNNUAL
REVIEW OF THE IMPLEMENTATION AND
OPERATION OF THE TBT AGREEMENT
Note by the Secretariat[1]
The WTO Committee on Technical Barriers to
Trade (the Committee) will conduct its Twentieth Annual Review of the
Implementation and Operation of the WTO Agreement on Technical Barriers to
Trade (the TBT Agreement) under Article 15.3 at its next meeting on 18-19
March 2015. This document contains information on developments in the Committee
relating to the implementation and operation of the TBT Agreement from
1 January to 31 December 2014.
_______________
TABLE OF CONTENTS
1 Meetings of the committee. 3
2 mechanisms for Review of TBT measures. 3
2.1
Notifications of technical regulations and conformity assessment procedures. 3
2.1.1
Trends in new notifications and follow-up (addenda, corrigenda, revision) 3
2.1.2
Members' engagement in notifications. 6
2.1.3
Notifications by region and development status. 7
2.1.4
Comment period provided in notifications. 9
2.1.5
Online submission of notifications (TBT NSS) 10
2.1.6
Stated objectives of notifications. 11
2.1.7
Other TBT Notifications. 12
2.2
Specific Trade Concerns (STCs) 13
2.2.1
Trends in STCs. 13
2.2.2
Members' engagement in STCs. 15
2.2.3
STCs by region and development status. 17
2.2.4
Types of concerns raised in STCs. 20
2.2.5
Stated objectives of measures subject to STCs. 21
2.2.6
Frequency – the number of times a given STC is raised in the Committee. 22
2.2.7
Relationship between notifications and STCs. 23
3 Disputes Involving Provisions of the TBT
Agreement. 24
4 Technical assistance. 24
ANNEXES. 27
A.
Notifications by Member, 1995-2014. 27
B.
Summary of STCs Raised in 2014. 33
C.
Overview of new STCs raised in 2014. 40
1.1. The Committee elected[2] Mr. Filipe Ramalheira (Portugal) as
its Chairperson for 2014.
1.2. Three regular meetings were held (19-20 March, 18-19 June and 5‑6 November 2014).[3] There was record
engagement of Members in the review of TBT measures during the year, with the
highest number of TBT notifications submitted (2,239) and new specific trade
concerns (STCs) raised (47) in any given year since 1995.[4] Developing Members notified 80% of new
notifications in 2014, and raised more STCs than developed Members during the
year (contrary to the general trend since 1995).
1.3. Back-to-back with the regular meetings, the Committee held thematic
sessions on various cross-cutting issues related to the operation and
implementation of the Agreement, including: Standards[5], Good Regulatory Practice[6], Transparency[7], Conformity Assessment
Procedures[8], and Technical Assistance
and Special and Differential Treatment.[9]
1.4. On 19-20 March 2014, the Committee adopted its report of the Nineteenth
Annual Review of the Implementation and Operation of the TBT Agreement under
Article 15.3.[10] At the same meeting, the
Committee carried out the Nineteenth Annual Review of the Code of Good Practice
for the Preparation, Adoption and Application of Standards (hereafter 'the
Code').
1.5. At the meeting of 18-19 June 2014, the Committee adopted a recommendation
on coherent use of notification formats (G/TBT/35).
1.6. At the 5-6 November 2014 meeting, the Committee granted ad hoc
observer status to the Gulf Cooperation Council (GCC) Standardization
Organization (GSO).[11]
1.7. Representatives of the BIPM, Codex, IEC, ISO, ITC, UNECE and WHO updated
the Committee on activities relevant to the work of the TBT Committee,
including on technical assistance.
2.1 Notifications of technical regulations and conformity
assessment procedures
2.1. In 2014, Members submitted 1,535 new notifications (including 29
revisions) of technical regulations and conformity assessment procedures. 619
addenda and 56 corrigenda to notifications were also submitted (Chart 1).[13]
In total, 2,239 TBT notifications were submitted in 2014, the most in a single
year since the entry into force of the Agreement on 1 January 1995. Since 2007,
Members have submitted more than 1,000 notifications annually with that figure increasing
to 1,500 since 2012 (Chart 2). Since the entry into force of the Agreement up
to 31 December 2014, 18,886 new notifications, 4,379 addenda and
corrigenda, and 148 revisions have been submitted by 126 Members.
Chart 1: Total TBT notifications, 1995-2014
Chart 2: New notifications, 1995-2014
2.2. Over the last ten years there has been a marked growth in the use of
addenda and corrigenda, with a record 675 notified in 2014 (Chart 3). The US (1,027), Brazil
(462), Ecuador (435), Colombia (310)
and the EU (303) have notified the most addenda and corrigenda since 1995.
Chart 3: Addenda and corrigenda notified,
1995-2014
2.3. While the number of revisions has also grown, this format is used
infrequently (Chart 4). China
(25), Brazil (17), Canada (14), the Dominican
Republic (10) and Korea (9) have notified most
revisions since 1995.
Chart 4: Revisions notified, 1995-2014
2.4. The share of new notifications to which one (or more) addendum,
corrigendum, or revision was submitted increased by around 25% over the years
2008-2011 (Chart 5). More recently (2012-2014), this share decreased from
around 15% to 13%. Since follow-up notifications (addenda, corrigenda and revisions)
are counted in the year which their parent notification was issued, this
decrease may reflect a time lag between a new notification and subsequent
follow-up, according to the lifecycle of measures within Members' domestic
regulatory processes.
Chart 5: Share of TBT notifications subject
to follow-up notifications (Addenda, Corrigenda, or Revisions), 1995-2014[14]
2.5. The ten Members that submitted the most TBT notifications in 2014
(Chinese Taipei and Kuwait both notified 62 measures) are shown in Chart 6.
Some Members were more active in submitting follow-up to previous
notifications, while others submitted more new notifications.
Chart 6: Most active notifying Members, 2014
2.6. From a historical perspective, the most active notifying Members in
2014 contrast with the trends observed over the period 1995-2013 (Chart 7).
Some Members were particularly active in 2014; For example, Ecuador, the United
Arab Emirates, Chinese Taipei, and Kuwait do not figure in the most active
notifying Members since 1995. Other Members that have historically been the most
active were less so in 2014 (e.g. China and Japan did not figure amongst the
most active notifying Members in 2014).
Chart 7: Most active notifying Members, 1995-2013,
and 2014
2.7. The number of new notifications submitted by Members grouped by
region is presented in Charts 8 and 9. More than half the new notifications in
2014 were submitted by Members from Middle East and South and Central America
and Caribbean regions (Chart 8). Compared to previous years, Members in the
South and Central America and Caribbean region increased their level of new
notifications in 2014 (Chart 8). Growth in the number of new notifications
submitted by Members in the Middle East region is one driver of the overall
increase in new notifications since 2009 (Chart 8).
Chart 8: Distribution of new notifications by region, 2014
Chart 9: Number of new notifications by region, 1995-2014
2.8. Developing Members continued to submit significantly more new
notifications in 2014 than developed Members (Chart 10). In 2014, new
notifications from developing Members represented 80% of the total (Chart 11).
Least-developed country Members (LDCs) notified less frequently and in 2014
notifications from this group declined.[15]
Chart 10: New notifications by development status, 1995-2014
Chart 11: New notifications, by development status, 2014
2.9. The Committee has recommended that the normal time-limit for
presentation of comments on notified technical regulations and conformity
assessment procedures should be 60 days, and that any Member able to
provide more than 60 days (such as 90 days) is encouraged to do so.[16]
In 2014, Members on average provided 60 days for comments in the 1,345 cases
where notifications specified a comment period (Chart 12). In total,
190 notifications did not specify a comment period, stated it as
non-applicable, or had a comment period which had lapsed.
Chart 12: Average number of days allowed for comments, 1995-2014[17]
2.10. The TBT Committee formally launched the online TBT notification
submission system (TBT NSS) at the 30-31 October 2013 TBT Committee meeting.[18]
In 2014, a total of 779 notifications were submitted through the TBT NSS by
23 Members (Chart 13), representing 35% of the annual notification volume.
Online submission has facilitated the submission and processing of
notifications, leading to more rapid circulation and increasing the time
available to Members to submit comments on notifications of interest. The
Secretariat continued to prioritize processing of notifications received
through the TBT NSS during 2014.
Chart 13: Members submitting notifications
through TBT NSS, 2014
Member
|
Total TBT notifications submitted through
TBT NSS
|
United States
|
176
|
Brazil
|
120
|
European Union
|
87
|
Canada
|
61
|
Israel
|
50
|
Kenya
|
37
|
Korea
|
35
|
Indonesia
|
32
|
Rwanda
|
30
|
South Africa
|
29
|
Japan
|
26
|
Uganda
|
19
|
Chile
|
17
|
Turkey
|
17
|
United Arab Emirates
|
15
|
Malaysia
|
10
|
Czech Republic
|
5
|
Georgia
|
5
|
Ireland
|
2
|
Sweden
|
2
|
Ukraine
|
2
|
Germany
|
1
|
United Kingdom
|
1
|
Total
|
779
|
2.11. Chart 14 shows that amongst the 1,535 new notifications received in
2014, the objective of protection of human health or safety was predominately
cited by Members, followed by: prevention of deceptive practices and consumer
protection; protection of the environment; and quality requirements. These main
objectives are consistent with the overall trend since 1995 (Chart 15).
Chart 14: Notifications by objective, 2014[19]
Chart 15: Notifications by objective, 1995-201419
2.12. In 2014, one agreement was notified under Article 10.7 between the
Slovak Republic and Ukraine. Since the entry into force of the TBT Agreement,
Members have submitted 140 notifications under Article 10.7 along with 6
corrigenda.
2.1.7.2 Notifications under Article 15.2
2.13. In 2014, five notifications were made under Article 15.2 of the TBT
Agreement of changes in measures to ensure the implementation and
administration of the TBT Agreement. Mali and Tajikistan notified for the first
time under Article 15.2, while Canada, Switzerland and Ukraine submitted revised
statements.[20]
2.1.7.3 Notifications under the Code of Good Practice for the preparation,
adoption and application of standards ("Code of Good Practice")
2.14. In 2014, The Gambia notified acceptance of the Code of Good
Practice, and no standardizing body withdrew. Since the entry into force of the
Agreement and through December 2014, 164 standardizing bodies from 125 Members
have notified acceptance of the Code of Good Practice.[21] Document
G/TBT/CS/2/Rev.21 contains a list, by Member, of standardizing bodies that have
accepted the Code of Good Practice since 1 January 1995 through
December 2014.[22]
2.15. Since its first meeting, Members have used the TBT Committee as a
forum to discuss trade issues related to technical regulations, conformity assessment
procedures and standards maintained by other Members. These discussions are
referred to as "specific trade concerns" (STCs) and relate either to
proposed measures, or to measures currently in force. TBT Committee meetings
afford Members the opportunity to review STCs in a multilateral setting, to seek
further clarification on the measures in question, and to work towards mutually
acceptable solutions.
2.16. In 2014 a record of 47 new STCs were raised, the most in any given
year since 1995 (Chart 16).[23] In
addition, 38 previously raised STCs were discussed during the year. (Annex B contains
a full list, Annex C provides details on new STCs raised in 2014).
Chart 16: STCs raised, 1995-2014[24]
2.17. Chart 17 illustrates, in a different way, the number of STCs
discussed at each Committee meeting over the past ten years. The figures
in Chart 17 are greater than those in Chart 16, since the latter only counts a
"previously raised" STC once even
though it may have been raised at all three regular meetings of any given year.[25] This
shows that the total number of STCs discussed annually has grown significantly
between 2005 and 2014 (from 33 to 148). This upward trend has meant that the
Committee has used an increased amount of meeting time discussing STCs (only
around 11 STCs were discussed per meeting in 2005 while that figure was 49 in 2014).
Chart 17: STCs discussed per committee
meeting, 2005-2014
2.18. The Members that most frequently raised STCs in 2014 were the EU,
the US and Canada, following the general trend since 1995 (Charts 18 and 19).
Ukraine was particularly active in 2014, raising six specific trade concerns in
just one year, whereas it had only raised five STCs before 2014.
Charts 18: Members most frequently raising STCs,
2014[26]
Charts 19: Members most frequently raising STCs,
1995-2013[27]
2.19. Between the years 1995-2013, measures of the EU, China and the USA
have been most frequently subject to concerns raised by other Members. In 2014,
Ecuador and the Russian Federation were subject to a significant number of
STCs, marking a break in the trend since 1995 (Charts 20 and 21). In six of the
eleven new STCs raised against Ecuador, transparency-related issues were cited
as a concern. The majority (five of six) of the STCs with measures maintained
by the Russian Federation were raised by Ukraine.
Chart 20: Members most frequently subject to
STCs, 2014[28]
Chart 21: Members most frequently subject to
STCs, 1995-2013[29]
2.20. Members that have raised or been subject to STCs in the TBT
Committee grouped by region and development status are presented in Charts 22
to 25. Members from the Asia, Europe and the North American regions raise most
STCs, and are also most often subject to STCs (Chart 22 and 23). Members from
South and Central America and the Caribbean region are also subject to, and
have raised, a notable number of STCs since 1995. In 2014, Members in South and
Central America, and the Caribbean region were subject to 15 STCs, the most of
any regional group (Chart 22). Members from Africa, Commonwealth of Independent
States (CIS) and Middle East regions are less frequently subject to and active
in raising STCs.
Chart 22: STCs by region, 2014[30]
Chart 23: STCs by region, 1995-2013[31]
2.21. Since 1995, developed Members
have raised the majority of STCs. However, in 2014, developing countries raised
more concerns than developed Members (Chart 24). Since 1995, as well as in
2014, developing Members were more frequently subject to STCs (Chart 25). No
measures of LDC Members have been subject to STCs (Chart 25).
Chart 24: STCs raised, by development status,
1995-2014[32]
Chart 25: Subject to STCs, by development
status, 1995–2014[33]
2.22. In 2014 the most frequently invoked concerns were those relating to
the avoidance of unnecessary barriers to trade, slightly different from the
long term trend (Chart 26). Issues relating to further information or
clarification about the measure at issue and to transparency (or lack thereof)
were also frequent, as were concerns about the rationale for measures or the
use of relevant international standards.
Chart 26: Types of concerns raised, 1995-2013,
and 2014[34]
2.23. Information about the stated objective of measures subject to STCs
may be derived from the notification itself, or through the discussion of the
particular measure in the Committee. Since 1995, the most commonly stated
objectives of measures raised as STCs relate to the protection of human health
and safety. This was also valid for 2014 (see Chart 27). Protection of the
environment, an objective cited in many measures raising concern since 1995,
was cited less frequently in 2014. The category 'other' (in Chart 27) covers a
wide range of stated objectives including trade facilitation, enhancing the
effectiveness of conformity assessment, or avoiding entry of illegal products.
For some STCs, the objective is not readily apparent from discussions and there
is no notification; these stated objectives have been classified as "not
specified".
Chart 27: Stated objectives for
the measures raised as STCs, 1995-2013, and 2014[35]
2.24. Most STCs (61%) have been raised at one or two Committee meetings.
Some (25%) have been raised between three and five times in Committee meetings,
while a small number (14%) have been raised at 6 or more meetings (Chart 28),
and have been the agenda of the Committee for several years.
Chart 28: Frequency of STCs (number of meetings raised), 1995-2014
2.25. Chart 30 illustrates the relationship between the number of new
notifications and new STCs raised each year. In 2014, 62% of STCs discussed
relate to notified measures, slightly lower than the overall share since 1995
of 66%.[36]
Chart 30: Trends in notifications and STCs
2.26. Of those STCs that relate to notified measures, measures notified as
technical regulations (Article 2.9.2) have been most frequently discussed
(Chart 31).
Chart 31: Measures raised in STCs, 1995-2014,
by frequency[37]
3.1. Since 1995, 50 disputes have cited the TBT Agreement in their
respective requests for consultations, the first formal step to initiate a WTO
case. In 2014, one such request was lodged concerning certain Indonesian
measures affecting exports of chicken meat and products. Other developments during the year included:
the circulation of the appellate body report in two disputes involving EU
measures regulating seal products; the circulation of a compliance panel ruling
with respect to the original dispute over US country of origin labelling
regulations for meats (still under appeal); the establishment of a panel to
decide about the compliance with ruling on US measures on canned tuna
labelling; the settlement ending compliance panel proceedings with respect to a
ruling on a US tobacco control measure banning flavoured cigarettes; and the
establishment of a single panel to decide on five disputes launched in 2013
against Australia's tobacco control measures ("plain packaging").[38]
4.1. The Secretariat significantly increased its TBT-related technical
assistance activities in 2014. A total of 14 workshops were organized
specifically on the TBT Agreement. Four of these were Regional[39]
Workshops (beneficiaries appear in green in Chart 32) and ten were national[40]
events (red) of which one was related to an accession process and three of
which were joint TBT-SPS events. The programme of these events was designed to
assist participating economies from the region – or individual economies (for
the national events) – to consolidate knowledge of the principles and disciplines
of the TBT Agreement, discuss implementation-related challenges and better
engage in the work of the TBT Committee. In the national workshops, emphasis
was put on transparency and national coordination. In total, participants from 80
developing country Members or Observers benefited from TBT-specific technical
assistance activities in 2014.
Chart 32:
TBT-specific Technical Assistance in 2014[41]
4.2. In addition to the TBT-specific activities illustrated above (Chart
32), the Secretariat provided training on the TBT Agreement at three
Geneva-based Advanced Trade Policy Courses as well as at seven regional trade
policy courses. This is illustrated in Chart 33 (host
countries in dark blue and beneficiaries in light blue). In total, participants
from 112 developing country Members or Observer benefited from these activities
in 2014.
Chart 33: Regional and
Advance Trade Policy Courses with a TBT Component in 2014[42]
4.3. Also, in 2014, three distance learning courses specifically on the
TBT Agreement were held. A total of 222
participants successfully completed these courses (95 participants in English, 86
participants in French, and 41 participants in Spanish).[43]
[1] This document has been prepared under the Secretariat's own
responsibility and is without prejudice to the position of Members or to their
rights and obligations under the WTO.
[2] Pursuant to Article 13.1 of the TBT Agreement and to its Rules of
Procedure.
[5] The Chairman's report is contained in G/TBT/GEN/144/Add.1.
[6] The Chairman's report is contained in G/TBT/GEN/143/Add.2.
[7] The Chairman's report is contained in G/TBT/GEN/167.
[8] The Chairman's report is contained in G/TBT/GEN/174.
[9] The Chairman's report is contained in G/TBT/GEN/174.
[12] The data for the graphs in this section are drawn from the TBT IMS,
more detail is contained in Annex A.
[13] This document uses the terminology adopted by the TBT Committee in
the recommendation on "Coherent use of notification formats",
G/TBT/35, 18 June 2014.
[14] Follow-up notifications (addenda, corrigenda and revisions) are
counted in the year that their parent new notification was issued, not the year
in which they were issued.
[15] The LDC which has notified most since 1995 is Uganda (456). Other
LDCs notify much less frequently: Tanzania (44), Zambia (44) and Rwanda (36).
All other LDCs have submitted 12 or fewer new notifications since 1995.
[16] G/TBT/1/Rev.12, Section
4.3.1.6, page 23-24.
[17] This chart covers only those notifications that specify a comment
period. The chart does not take into account notifications where the comment
period was not specified, was stated as non-applicable, or had lapsed at the time
of circulation ("lapsed" means that the deadline for comments stated
on the notification was earlier than the date of circulation of the
notification).
[18] G/TBT/M/61, Section 2.3.3.2, page 49.
[19] The objectives as indicated by Members in Item 7 of the new
notification template. Note that notifications may cite to multiple objectives.
[20] The full list of statements of Members having submitted a
statement on implementation and administration of the TBT Agreement under
Article 15.2 (since January 1995) is contained in document G/TBT/GEN/1/Rev.13.
The new statements were received from Tajikistan (G/TBT/2/Add.112) and Mali (G/TBT/2/Add.113).
Ukraine (G/TBT/2/Add.100/Rev.3), Switzerland (G/TBT/2/Add.7/Rev.2) and Canada
(G/TBT/2/Add.6/Rev.3) submitted a revision to their statements.
[21] Notifications of acceptance of the Code by standardizing bodies of
Members are contained in
documents
G/TBT/CS/N/1-183.
[23] More detail on specific trade concerns raised in the TBT Committee
is available through the TBT IMS (http://tbtims.wto.org).
[24] New STCs are those which are raised for the first time in a given
year. Previous STCs are those which were first raised in any past year, and
were re-raised in the year in question.
[25] In other words, in Chart 16 if the same STC is raised at multiple
Committee meetings during the year, it is counted as only one STC. In
Chart 17, an STC is counted each time it is raised at a Committee meeting –
this figure thus more accurately reflects the time used by the Committee to
discuss STCs.
[26] This chart indicates the number of new STCs in respect of which a
Member has expressed concern (e.g. the EU expressed concern with respect to 16
different new STCs in 2014). This chart includes only those Members that have
raised concern with respect to three or more new STCs during the year.
[27] This chart indicates the number of STCs in respect of which a
Member has expressed concern (e.g. the US expressed concern with respect to 172
different STCs from 1995-2013). This chart includes only those Members that
have raised concern with respect to thirty-two or more STCs during the period
in question.
[28] This chart indicates the number of times that a Member was subject
to a STC raised by one or more Member(s). This chart includes only those
Members subject to two STCs or more during 2014.
[29] This chart indicates the number of times that a Member was subject
to a STC raised by one or more Member(s). This chart includes only those
Members subject to ten STCs or more between 1995-2013.
[30] "Subject to STCs" indicates that a measure of a Member in
a given region has been subject to a STC raised by one or more Member(s). Note
that this category totals to 47, reflecting the breakdown of the 47 new STCs
raised in 2014, by region of the Member that was subject to the STC. "STCs
Raised" indicates the number of times that a Member in a given region
raised concern with respect to a STC in 2014. A given STC may be raised by
several Members.
[31] "Subject to STCs" indicates that a measure of a Member in
a given region has been subject to a STC raised by one or more Member(s). Note
that this category totals to 47, reflecting the breakdown of the 47 new STCs
raised in 2014, by region of the Member that was subject to the STC. "STCs
Raised" indicates the number of times that a Member in a given region
raised concern with respect to a STC in 2014. A given STC may be raised by
several Members.
[32] "STCs Raised" indicates the number of times that a Member
of a given development status raised a concern with respect to a STC. A given
STC may be raised by several Members.
[33] "Subject to STCs" indicates that a measure of a Member of
a given development status has been subject to a STC raised by one or more
Member(s). Note that this category totals 47, reflecting the breakdown of the
47 new STCs raised in 2014 by development status of the Member subject to the
STC.
[34] For each specific trade concern covered there may be more than one
type of concern raised.
[35] For each specific trade concern there may be more than one stated
objective.
[36] Eight specific trade concerns discussed in the TBT Committee were
also notified to the SPS Committee.
[37] Some measures have been notified both as technical regulations and
conformity assessment procedures, and some concerns have been raised against
multiple notified measures. Chart 31 counts each time an Article cited in a
notified measures is raised as an STC.
[39] These regional workshops were held in: Brazil (for the Latin
American Region), Namibia (for English-speaking African Region), Austria (for
the Central and Eastern Europe, Central Asia and the Caucasus Region) and UAE
(for the Arab and Middle East Region).
[40] These national workshops were held in: Brazil, Chile, Chinese
Taipei, Ecuador, El Salvador (joint TBT and SPS), Lao (PDR), Kingdom of Saudi
Arabia (joint TBT and SPS), Seychelles (accession related), Tanzania (joint TBT
and SPS) and Uruguay.
[41] The colours, boundaries and names shown and the designations used
on these maps do not imply and judgment, official endorsement or acceptance by
the World Trade Organization as to the legal status or frontier of any
territory. This map intends to make information on WTO Members more accessible
by organizing such information visually. The map does not intend to show WTO
Members' non-metropolitan/overseas territories or the status of such
territories in regard to the WTO Agreement. A full disclaimer is available at: http://www.wto.org/english/info_e/disclaimer_e.htm.
[42] The colours, boundaries and names shown and the designations used
on these maps do not imply any judgment, official endorsement or acceptance by
the World Trade Organization as to the legal status or frontier of any
territory. This map intends to make information on WTO Members more accessible
by organizing such information visually. The map does not intend to show WTO
Members' non-metropolitan/overseas territories or the status of such
territories in regard to the WTO Agreement. A full disclaimer is available
here: http://www.wto.org/english/info_e/disclaimer_e.htm.
[43] The TBT-online course is addressed to government officials from
Members and Observers and covers all aspects of the TBT Agreement. The TBT
online course is available throughout the year in all three languages. While
the WTO E-Learning material is freely available in the WTO E-Learning website,
participants have to register and submit a nomination form in order to
participate in a monitored course, access the exam module and obtain a WTO
certificate. More information can be
obtained at http://ecampus.wto.org/.
[45] Listed in alphabetical order.