Guidance on Comment Submissions by U.S. Industry on Notifications by WTO Members to the TBT Committee
HOW TO PREPARE AND SUBMIT COMMENTS
The following guidance is provided by the National Institute of Standards and Technology to assist U.S. industry in the preparation of comments in response to notifications of proposed foreign technical regulations and conformity assessment procedures made under the World Trade Organization's (WTO) Agreement on Technical Barriers to Trade (TBT). Non-US entities who wish to submit comments on non-US notifications can submit their comments directly to the appropriate WTO Member Enquiry Point.
We suggest that U.S. industry adhere to the following guidelines to prepare and submit comments through the USA WTO TBT Enquiry Point on notifications made by members of the World Trade Organization (WTO) to the TBT Committee. If after reviewing these guidelines you have further questions about submitting comments or the commenting process, please contact us using our contact information below.
submitting comments to the USA TBT Enquiry Point on the date they are due. We request that you submit your comments three (3) business days prior to the posted comment deadline due to global time differences and the time needed for processing comments in the USA TBT Enquiry Point, and in the receiving national TBT Enquiry Point. Our Enquiry Point processes comments from US interests within 24 hours of receipt.
Do NOT address the comments to the USA TBT Enquiry Point and/or a staff member in the USA TBT Enquiry Point.
- Do address them to appropriate national TBT Enquiry Point or the agency responsible as provided in the notification in Box #2 and/or Box #11. Notifications are accessible from the WTO TBT Information Management System (TBT IMS). Contact information for all national WTO TBT Enquiry Points is also available from the TBT IMS.
Do NOT submit comments directly to the other national TBT Enquiry Point.
- Each TBT Enquiry Point is authorized to accept comments and official communications from other TBT Enquiry Points. Members are not obligated to and may not consider comments that are conveyed outside official Enquiry Point channels.
- The title and notification symbol which they concern;
- Complete contact information of the commenter and/or commenting organization, e.g., organization/company name, contact name, email, etc. (please use letterhead if possible);
- Issue statement, e.g., the reason for submitting comments. Focus on technical aspects of the proposed regulation or regulations with which possible issues have been identified;
- Supporting rationale statement, again focusing on technical aspects of the proposed regulation or regulations with which potential issues have been identified by the commenter(s).
- In case of a problem meeting proposed date of entry into force: If the commenter believes that compliance with the proposed regulation or conformity assessment procedure cannot or is unlikely to be achieved by the proposed date of entry into force as indicated in the notification (in Box #9), it would be helpful to include a suggested date by which compliance could be achieved.
- Address your comments to the receiving WTO member’s national TBT Enquiry Point and/or the responsible agency (as listed in Box #2 and/or Box #11 of a regular notification; mailing addresses or regulator contact information may or may not be listed in an addendum – use the Enquiry Point address if no contact information is included).
- Please include in the comments the relevant notification symbol and title.
- Submit your comments on company / organization letterhead in PDF to the USA WTO TBT Enquiry Point by email at email@example.com.
- Submit comments to arrive in the USA WTO TBT Enquiry Point AT LEAST three (3) days prior to the comment deadline date.
- Please do not submit comments directly to the other WTO member or their national TBT Enquiry Point (see above for information on addressing comments).
- Within 24 hours of receipt, the USA TBT Enquiry Point will review comments received from US interests to make sure the basic guidance above has been followed (i.e., comments are addressed to the correct contact(s), and the WTO notification symbol is included);
- If comments do not meet the basic guidance, our staff will follow up with the submitter / submitting organization to suggest essential updates;
- If / once comments meet the basic guidance, our staff will transmit them to the relevant national TBT Enquiry Point by e-mail and follow up with the submitter / submitting organization to confirm submission;
The USA WTO TBT Enquiry Point shares with commenters / commenting organizations responses to comments provided by the other WTO member’s national TBT Enquiry Point or relevant authority.
Please contact us if you have questions; do not address comments to the USA WTO TBT Enquiry Point (see above for information on addressing comments)
USA WTO TBT Enquiry Point Telephone 301-975-2918 firstname.lastname@example.org
Please note that any comments submitted may be made publicly available.