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Issues for Discussion

Definition of the Problem

         Defending Indian access for bed linen to the EU market, curtailed by various antidumping procedures and rulings, by using the procedures of the DSU.

Analysis

         Economic — dumping and market access

         Political — India, EU, other WTO members

         Commercial — Indian suppliers, EU distributors and customers, EU competitors

         Policy — India, EU, other WTO members

Alternative Solutions

Preferred Solution

Required Means

         Who does what

         Who makes decisions

         Who influences those decisions and how

The players and their perspectives

         Complaining parties — EU producers of bed linen

         Defending parties — Indian suppliers of bed linen

         EU Commission officials

         Indian government officials

         WTO members and officials, particularly third parties to dispute

         Intermediaries: shippers, brokers, etc.

         EU consumers

  

Background Issues for Discussion

Object and purpose of GATT/WTO

         Role and interests of developing countries

Market access

         Economics                                         Politics

         Gaining and keeping it

‘Low-cost’ imports, particularly textiles

Dumping and anti-dumping measures

         Economic issues                                 Legal issues

         Procedural issues                               Challenges for developing countries

Dispute settlement

         Who and what’s involved

         The record under GATT and the WTO

         What’s required to initiate or defend a case

         Particular problems for developing countries
 
  


Exhibit 1

Trade in textiles and the WTO[1]
Multifibre Arrangement (MFA) 1974-94
Up to the end of the Uruguay Round, textile and clothing quotas were negotiated bilaterally and governed by the rules of the Multifibre Arrangement (MFA). This provided for the application of selective quantitative restrictions when surges in imports of particular products caused, or threatened to cause, serious damage to the industry of the importing country. The Multifibre Arrangement was a major departure from the basic GATT rules and particularly the principle of non-discrimination. On 1 January 1995 it was replaced by the WTO Agreement on Textiles and Clothing which sets out a transitional process for the ultimate removal of these quotas. 

The WTO Agreement on Textiles and Clothing (ATC) 1995-2004
The ATC is a transitional instrument, built on the following key elements: (a) the product coverage, basically encompassing yarns, fabrics, made-up textile products and clothing; (b) a programme for the progressive integration of these textile and clothing products into GATT 1994 rules; (c) a liberalization process to progressively enlarge existing quotas (until they are removed) by increasing annual growth rates at each stage; (d) a special safeguard mechanism to deal with new cases of serious damage or threat thereof to domestic producers during the transition period; (e) establishment of a Textiles Monitoring Body (“TMB”) to supervise the implementation of the Agreement and ensure that the rules are faithfully followed; and (f) other provisions, including rules on circumvention of the quotas, their administration, treatment of non-MFA restrictions, and commitments undertaken elsewhere under the WTO's agreements and procedures affecting this sector.

The product coverage, listed in the Annex to the ATC, covers all products which were subject to MFA or MFA-type quotas in at least one importing country.

The integration process is laid down in ATC Article 2 and stipulates how Members shall integrate the products listed in the Annex into the rules of GATT 1994 over the 10-year period. This process is to be carried out progressively in three stages (3 years, 4 years, 3 years) with all products standing integrated at the end of the 10-year period. The first stage began on 1 January 1995 with the integration by Members of products representing not less than 16 per cent of that Member's total 1990 imports of all the products in the Annex. At stage 2, on 1 January 1998, not less than a further 17 per cent was integrated. At stage 3, on 1 January 2002, not less than a further 18 per cent will be integrated. Finally at the end, on 1 January 2005, all remaining products (amounting up to 49 per cent of 1990 imports into a Member) will stand integrated and the Agreement terminates. Each importing Member decides itself which products it will integrate at each stage to reach these thresholds. The only constraint is that the integration list must encompass products from each of the four groupings: tops and yarns, fabrics, made-up textile products and clothing.

The four WTO Members which maintained import restrictions under the former MFA (Canada, EC, Norway and the US) were required to undertake this integration process and to notify to the TMB the first phase of their programmes of integration by 1 October 1994. Other WTO Members were required, first, to notify the TMB if they wished to retain the right to use the transitional safeguard mechanism in the ATC (Article 6.1) and, if so, to provide their first stage integration lists. Fifty-five Members chose to retain this right and most of them provided lists of products for integration. Nine Members, Australia, Brunei Darussalam, Chile, Cuba, Hong Kong, Iceland, Macau, New Zealand and Singapore decided not to maintain the right to use the ATC safeguard mechanism. They are deemed to have integrated 100 per cent at the outset.

Concurrent with the integration process, there is a programme for liberalizing the existing restrictions, that is, for enlarging the bilateral quotas carried over from the former MFA on 1 January 1995 (Article 2.1) until such time as the products are integrated into GATT, at which time the quotas terminate. These former MFA quotas, when carried over into the ATC on 1 January 1995, represented the starting point for an automatic liberalization process set out in Article 2, paragraphs 12-16. The former MFA growth rates applicable to each of these quotas were increased on 1 January 1995 by a factor of 16 per cent for the first stage of the Agreement and the new growth rate was applied annually. The stage 1 growth rate was further increased by a factor of 25 per cent for the second stage on 1 January 1998; and will be increased by a further 27 per cent for the last stage beginning 1 January 2002. To illustrate this process, a 6 per cent growth rate under the MFA in 1994 became 6.9 per cent under the ATC and applied each year 1995/96/97; then it was increased to 8.7 per cent for each year 1998/99/2000/01; and then will be increased to 11.05 per cent for 2002/3/4. For small suppliers (as defined in Article 2.18) the growth factors (16 per cent, 25 per cent, 27 per cent) are to be advanced by one stage. Quotas will be eliminated either when the products concerned are integrated into GATT at one of the stages or at the end of the transition on 1 January 2005. There are additional provisions in Article 2 for early removal of quotas and integration of products.

Article 3 deals with quantitative restrictions (or measures with similar effect) other than those under the MFA. Members which had such restrictions in place, which could not be justified under a GATT provision, were required either to bring them into conformity with GATT rules or phase them out within the ten year transitional period, according to a plan to be submitted by the restraining Member to the Textiles Monitoring Body. There is no obligation to eliminate restrictions that are permitted under GATT rules. 

A key aspect of the ATC is the provision in Article 6 for a special transitional safeguard mechanism intended to protect Members against damaging surges in imports during the transition period from products which have not yet been integrated into GATT and which are not already under quota. This clause is based on a two-tiered approach - first, the importing Member must determine that total imports of a specific product are causing serious damage, or actual threat thereof, to its domestic industry and second, it must then decide to which individual Member(s) this serious damage can be attributed. Specific criteria and procedures are set out for each step. The importing Member must then seek consultations with the exporting Member(s). Such safeguard measures may be applied on a selective, country-by-country basis by mutual agreement or, if agreement is not reached through the consultation process within 60 days, by unilateral action. The quota may not be lower than the actual level of imports for that exporting country during a recent 12 month period, and the action taken may remain in place for up to three years only. If the measure is in place for more than one year, growth shall, with one exception, be no less than 6 per cent. In practice, the special safeguard was invoked on 24 occasions in 1995 by the United States, 8 times in 1996 (Brazil 7, US 1), 2 times in 1997 by the United States, and 10 times in 1998 (Colombia 9, US 1).

Article 5 of the ATC contains rules and procedures concerning circumvention of the quotas through transshipment, re-routing, false declaration of origin, or falsification of official documents. These require, inter alia, consultation and full cooperation in the investigation of such practices by Members concerned. When sufficient evidence is available, possible recourse might include the denial of entry of goods. There is also a provision whereby all Members should establish, consistent with their domestic laws and procedures, the necessary legal provisions and/or administrative procedures to address and take action against circumvention.

Administration of restrictions during the transition period will remain with the exporting Members and any changes in practices, rules or procedures shall be subject to consultations with a view to reaching mutually acceptable solutions (Article 4). 

Provisions relating to the commitments undertaken in all areas of the Uruguay Round as they relate to textiles and clothing require that all Members “shall take such actions as may be necessary” to abide by these rules and disciplines so as to achieve improved market access, to ensure the application of fair and equitable trading conditions and to avoid discrimination against textiles and clothing imports (Article 7). If an exporting Member is found not to be complying with its obligations, the Dispute Settlement Body or the Council for Trade in Goods may authorize an adjustment to the quota growth for that country which is otherwise an automatic growth.

The Textiles Monitoring Body has been established to supervise the implementation of the ATC and to examine all measures taken under it, to ensure that they are in conformity with the rules. It is a quasi-judicial, standing body which consists of a Chairman and ten TMB members, discharging their function on an ad personam basis and taking all decisions by consensus. The ten members are appointed by WTO Member governments according to an agreed grouping of WTO Members into constituencies. There can be rotation within the constituencies. These characteristics make the TMB a unique institution within the WTO framework. In January 1995, the General Council decided upon the composition for the TMB for the first stage. In December 1997, the General Council decided upon the composition for the second stage (1998-2001) with TMB members to be appointed by WTO Members designated from the following constituencies: (a) the ASEAN Member countries; (b) Canada and Norway; (c) Pakistan and China (after accession); (d) the European Communities; (e) Korea and Hong Kong, China; (f) India and Egypt/ Morocco/ Tunisia; (g) Japan; (h) Latin American and Caribbean Members; (i) the United States; and (j) Turkey, Switzerland and Bulgaria/Czech Republic/Hungary/ Poland/Romania, Slovak Republic/Slovenia. Provisions were made for alternates to be appointed by the members in each of the constituencies and in some cases second alternates; there are also two non-participating observers from Members not already represented in this structure, one from Africa and one from Asia.
   


Exhibit 2

EU trade policy instruments: Anti-dumping[2]
Protection against dumped imports
European Community rules to deal with dumping date back to the organisation’s earliest days. They are targeted at dumped imports which cause significant injury to Community producers. If left unchallenged, dumping gives the third country exporter an unfair competitive advantage which could be exploited with considerable negative consequences for Community industry.

Existing Community rules were replaced by a new Anti-Dumping regulation which came into force on 1 January 1995. This in turn was updated by Regulation 384/96, which came into force on 6 March 1996. This Regulation incorporates measures agreed in the Uruguay Round of the GATT. It also imposes strict time limits for the completion of investigations and decision-making to ensure that complaints are dealt with rapidly and efficiently.

Dumping is often seen to relate to any cheap or below-cost imports, but the reality is more complicated. The 1996 Anti-Dumping Regulation provides for the imposition of anti-dumping duties, but only when the following conditions are met:

     a finding of dumping: the export price at which the product is sold on the Community market is shown to be lower than the price on the producer’s home market;

     a material injury to Community industry: the imports have caused or threaten to cause damage to a substantial part of the industry within the EC, such as loss of market share, reduced prices for producers and resulting pressure on production, sales, profits, productivity etc.;

     the interests of the Community: the costs for the Community of taking measures must not be disproportionate to the benefits.

The European Commission is responsible for investigating complaints and assessing whether they are justified. The Commission can also impose provisional measures, and definitive measures for coal and steel products. In all other cases, it is the Council of Ministers which imposes definitive anti-dumping duties.

When an industry in the Community considers that dumped imports from non-EU countries are causing it material industry, it may submit a complaint to the European Commission, either directly or through its national government. The Commission then has 45 days to examine the complaint, consult the member states (represented on an Advisory Committee) and decide whether or not there is enough evidence to merit a formal investigation. The case will be rejected if there is not enough evidence or if the complainants do not represent at least 25 % of the total EC production of the product in question.

The Commission’s investigation will cover whether or not dumping is taking place, which can be a complex calculation, and also whether dumped imports are causing material industry to Community industry. Measures may also be imposes if imports are hindering the establishment of a new industry within the Community, or there is a clear and imminent threat of material injury. The investigation normally takes no more than a year, and in any case must be completed within 15 months.

Anti-dumping measures will only take place if they are shown to be in the broader Community interest. Producers, importers, users and consumers are able to present their views. The member states must then be consulted, and then the Commission may, within 60 days to nine months, impose provisional duties. They must not exceed the dumping margin (the difference between the price on the home market and the price charged on the EC market). These may last for six to nine months. After that, when the Commission has completed it’s full investigation, it may, after further consultation with the member states, impose definitive duties. Only the Council of Ministers has the authority to decide upon these. Definitive duties are valid for five years before they expire. If, however, Community producers demonstrate that removal of duties is likely to lead to renewed duties and dumping, the Commission may reopen its investigation. This may also happen if the imposition of duties does not have the desired effect of removing the injury, for example because the exporter has absorbed the extra costs, or the pattern of trade has changed. This may result in changes in the level of duties. A Regulation imposing anti-dumping duties may be challenged in the European Court of First Instance, and the WTO dispute settlement procedure may be used to settle disputes between WTO signatories.

  
How to introduce an anti-dumping complaint
The anti-dumping legislation of the EU exists to counteract unfair dumping practices by third-country exporters. The EU legislation is based on an agreement reached in 1994 between all members of World Trade Organisation. This agreement condemns dumping as an unfair trade practice and allows remedial action to be taken.

If the Community industry feels injured by dumped imports, it can present an anti-dumping complaint to the Commission’s Anti-dumping Service.

A “complaint” is a document which contains information showing that a certain product originating in a third country is being exported to the European Community at dumped prices, and that this dumped product is causing injury to the Community industry. Evidence (e.g. invoices, price offers, publications in specialised press, official statistics, etc..) will support the allegations made in the complaint.

Export prices are “dumped” when they are at a level below the domestic price in the exporting country. In other words, there is price discrimination: for similar products, a producer charges higher prices on his domestic market than for export sales to the EU. Export prices are also dumped when the exporter sells at a loss.

“Injury” (a deterioration in the state of the industry) can be shown in many ways (loss of market share, drop in prices, worsening financial results, etc). This deterioration must be material, i.e., not simply of a temporary or negligible nature (for example, sales at a loss by the Community industry for end-of-year stocks). Furthermore, the dumped imports must be a cause of this injury.

“Community industry” refers to European Community producers of the particular product being dumped that are being injured by this dumping. A complaint must be supported by a significant amount of European Community producers. Collectively, these companies must produce at least 25% of the total European Community production of the product being dumped. In general, complainants would contact the producers in other Member States to seek support before filing the complaint.

In principle, any “product” can be the subject of a complaint. Anti-dumping legislation, however, does not include services.

In general, the dumped products may originate in any country outside the European Community. The only exceptions are Iceland, Liechtenstein and Norway, who, for most products, are excluded from the application of anti-dumping legislation1. If exports from several “third countries” are being dumped, all of the relevant third countries are normally examined in the complaint.

  
Confidentiality
Information can be provided to the Commission on a confidential basis. The Commission will not reveal any confidential information without specific permission from its supplier.

  
The investigation
If a complaint is deemed admissible, an investigation will be initiated 45 days after the complaint is formally lodged with the Commission. The investigation will establish whether remedial action should be taken.

The investigation may take up to a maximum of 9 months to come to a provisional determination (if warranted, provisional anti-dumping duties) and up to a further 6 months to come to a definitive determination (if warranted, definitive anti-dumping duties). Definitive anti-dumping measures normally have a duration of five years.

In addition, the Commission has prepared a “Guide on How to Draft an Anti-dumping Complaint”, which provides detailed explanations and insights into the contents of anti-dumping complaints. The guide exists in all official Community languages. If you wish to consult this guide, go to: europa.eu.int/comm/trade/policy/dumping/compl.htm.  
  


Exhibit 3

WTO Agreement on Implementation of Article VI (Anti-Dumping) — Description[3]
Article VI of the GATT provides for the right of contracting parties to apply anti-dumping measures, i.e. measures against imports of a product at an export price below its “normal value” (usually the price of the product in the domestic market of the exporting country) if such dumped imports cause injury to a domestic industry in the territory of the importing contracting party. More detailed rules governing the application of such measures are currently provided in an Anti-Dumping Agreement concluded at the end of the Tokyo Round. Negotiations in the Uruguay Round have resulted in a revision of this Agreement which addresses many areas in which the current Agreement lacks precision and detail.

In particular, the revised Agreement provides for greater clarity and more detailed rules in relation to the method of determining that a product is dumped, the criteria to be taken into account in a determination that dumped imports cause injury to a domestic industry, the procedures to be followed in initiating and conducting anti-dumping investigations, and the implementation and duration of anti-dumping measures. In addition, the new agreement clarifies the role of dispute settlement panels in disputes relating to anti-dumping actions taken by domestic authorities. 

On the methodology for determining that a product is exported at a dumped price, the new Agreement adds relatively specific provisions on such issues as criteria for allocating costs when the export price is compared with a “constructed” normal value and rules to ensure that a fair comparison is made between the export price and the normal value of a product so as not to arbitrarily create or inflate margins of dumping. 

The agreement strengthens the requirement for the importing country to establish a clear causal relationship between dumped imports and injury to the domestic industry. The examination of the dumped imports on the industry concerned must include an evaluation of all relevant economic factors bearing on the state of the industry concerned. The agreement confirms the existing interpretation of the term “domestic industry”. Subject to a few exceptions, “domestic industry” refers to the domestic producers as a whole of the like products or to those of them whose collective output of the products constitutes a major proportion of the total domestic production of those products. 

Clear-cut procedures have been established on how anti-dumping cases are to be initiated and how such investigations are to be conducted. Conditions for ensuring that all interested parties are given an opportunity to present evidence are set out. Provisions on the application of provisional measures, the use of price undertakings in anti-dumping cases, and on the duration of anti-dumping measures have been strengthened. Thus, a significant improvement over the existing Agreement consists of the addition of a new provision under which anti-dumping measures shall expire five years after the date of imposition, unless a determination is made that, in the event of termination of the measures, dumping and injury would be likely to continue or recur. 

A new provision requires the immediate termination of an anti-dumping investigation in cases where the authorities determine that the margin of dumping is de minimis (which is defined as less than 2 per cent, expressed as a percentage of the export price of the product) or that the volume of dumped imports is negligible (generally when the volume of dumped imports from an individual country accounts for less than 3 per cent of the imports of the product in question into the importing country). 

The agreement calls for prompt and detailed notification of all preliminary or final anti-dumping actions to a Committee on Anti-Dumping Practices. The agreement will afford parties the opportunity of consulting on any matter relating to the operation of the agreement or the furtherance of its objectives, and to request the establishment of panels to examine disputes.

  
The WTO Anti-dumping Agreement — Explanatory Notes[4]
The Agreement on Implementation of Article VI of the General Agreement on Tariffs and Trade 1994 (the “AD Agreement”) governs the application of anti-dumping measures by Members of the WTO. Anti-dumping measures are unilateral remedies which may be applied by a Member after an investigation and determination by that Member, in accordance with the provisions of the AD Agreement, that an imported product is “dumped” and that the dumped imports are causing material injury to a domestic industry producing the like product.

The AD Agreement sets forth certain substantive requirements that must be fulfilled in order to impose an anti-dumping measure, as well as detailed procedural requirements regarding the conduct of anti-dumping investigations and the imposition and maintenance in place of anti-dumping measures. A failure to respect either the substantive or procedural requirements can be taken to dispute settlement and may be the basis for invalidation of the measure. Unlike the Agreement on Subsidies and Countervailing Measures, the AD Agreement does not establish any disciplines on dumping itself, primarily because dumping is a pricing practice engaged in by business enterprises, and thus not within the direct reach of multilateral disciplines.

  
Substantive rules
Article 1 of the AD Agreement establishes the basic principle that a Member may not impose an anti-dumping measure unless it determines, pursuant to an investigation conducted in conformity with the provisions of the AD Agreement, that there are dumped imports, material injury to a domestic industry, and a causal link between the dumped imports and the injury.

  
Determination of dumping
Article 2 contains substantive rules for the determination of dumping. Dumping is calculated on the basis of a “fair comparison” between normal value (the price of the imported product in the “ordinary course of trade” in the country of origin or export) and export price (the price of the product in the country of import). Article 2 contains detailed provisions governing the calculation of normal value and export price, and elements of the fair comparison that must be made.

  
Determination of injury
Article 3 of the AD Agreement contains rules regarding the determination of material injury caused by dumped imports. Material injury is defined as material injury itself, threat of material injury, or material retardation of the establishment of a domestic industry. The basic requirement for determinations of injury, is that there be an objective examination, based on positive evidence of the volume and price effects of dumped imports and the consequent impact of dumped imports on the domestic industry. Article 3 contains specific rules regarding factors to be considered in making determinations of material injury, while specifying that no one or several of the factors which must be considered is determinative. Article 3.5 requires, in establishing the causal link between dumped imports and material injury, known factors other than dumped imports which may be causing injury must be examined, and that injury caused by these factors must not be attributed to dumped imports.

A significant new provision, Article 3.3, establishes the conditions in which a cumulative evaluation of the effects of dumped imports from more than one country may be undertaken. Under the rules, authorities must determine that the margin of dumping from each country is not de minimis, that the volume of imports from each country is not negligible, and that a cumulative assessment is appropriate in light of the conditions of competition among the imports and between the imports and the domestic like product.

  
Definition of industry
Article 4 of the AD Agreement sets forth a definition of the domestic industry to be considered for purposes of assessing injury and causation. The domestic industry is defined as producers of a “like product”, which term is defined in Article 2.6 as a product that is identical to, or in the absence of such a product, one that has characteristics closely resembling those of, the imported dumped product under consideration. Article 4 contains special rules for defining a “regional” domestic industry in exceptional circumstances where production and consumption in the importing country are geographically isolated, and for the evaluation of injury and assessment of duties in such cases. Article 4 also establishes that domestic producers may be excluded from consideration as part of the domestic industry if they are “related” (defined as a situation of legal or effective control) to exporters or importers of the dumped product.

  
Procedural requirements

Overview
A principal objective of the procedural requirements of the AD Agreement is to ensure transparency of proceedings, a full opportunity for parties to defend their interests, and adequate explanations by investigating authorities of their determinations. The extensive and detailed procedural requirements relating to investigations focus on the sufficiency of petitions (through minimum information and “standing” requirements) to ensure that meritless investigations are not initiated, on the establishment of time periods for the completion of investigations, and on the provision of access to information to all interested parties, along with reasonable opportunities to present their views and arguments. Additional procedural requirements relate to the offering, acceptance, and administration of price undertakings by exporters in lieu of the imposition of anti-dumping measures. The AD Agreement requires investigating authorities to give public notice of and explain their determinations at various stages of the investigative process in substantial detail. It also establishes rules for the timing of the imposition of anti-dumping duties, the duration of such duties, and obliges Members to periodically review the continuing need for anti-dumping duties and price undertakings. There are detailed provisions guiding the imposition and collection of duties under various duty assessment systems, intended to ensure that anti-dumping duties in excess of the margin of dumping are not collected, and that individual exporters are not subjected to anti-dumping duties in excess of their individual margin of dumping. Article 13 of the AD Agreement requires Members to provide for judicial review of final determinations in anti-dumping investigations and reviews. Other provisions establish that Members may, at their discretion, take anti-dumping actions on behalf of and at the request of a third country, and recognise that “special regard” must be given by developed country Members to the situation of developing country Members when considering the application of anti-dumping duties.

  
Specific Provisions

Initiation and conduct of investigations
Article 5 establishes the requirements for the initiation of investigations. The AD Agreement specifies that investigations should generally be initiated based on a written request submitted “by or on behalf of” a domestic industry. This “standing” requirement is supported by numeric limits for determining whether there is sufficient support by domestic producers to conclude that the request is made by or on behalf of the domestic industry, and thereby warrants initiation. The AD Agreement establishes requirements for evidence of dumping, injury, and causality, as well as other information regarding the product, industry, importers, exporters, and other matters, in written applications for anti-dumping relief, and specifies that, in special circumstances when authorities initiate without a written application from a domestic industry, they shall proceed only if they have sufficient evidence of dumping, injury, and causality. In order to ensure that meritless investigations are not continued, potentially disrupting legitimate trade, Article 5.8 provides for immediate termination of investigations in the event the volume of imports is negligible or the margin of dumping is de minimis, and establishes numeric thresholds for these determinations. In order to minimize the trade disruptive effect of investigations, Article 5.10 specifies that investigations shall be completed within one year, and in no case more than 18 months, after initiation.

Article 6 sets forth detailed rules on the process of investigation, including the collection of evidence and the use of sampling techniques. It requires authorities to guarantee the confidentiality of sensitive information and verify the information on which determinations are based. In addition, to ensure the transparency of proceedings, authorities are required to disclose the information on which determinations are to be based to interested parties and provide them with adequate opportunity to comment, and establishes the rights of parties to participate in the investigation, including the right to meet with parties with adverse interests, for instance in a public hearing.

  
Imposition of provisional measures
Article 7 relates to the imposition of provisional measures. Article 7 includes the requirement that authorities make a preliminary affirmative determination of dumping, injury, and causality before applying provisional measures, and the requirement that no provisional measures may be applied sooner than 60 days after initiation of an investigation.

  
Price undertakings
Article 8 establishes the principle that undertakings to revise prices or cease exports at dumped prices may be entered into to settle an investigation, but only after a preliminary affirmative determination of dumping, injury, and causality has been made. It also establishes that undertakings are voluntary on the part of both exporters and investigating authorities. In addition, an exporter may request that the investigation be continued after an undertaking has been accepted, and if a final determination of no dumping, no injury, or no causality results, the undertaking shall automatically lapse.

  
Imposition and collection of duties
Article 9 establishes the general principle that imposition of anti-dumping duties is optional, even if all the requirements for imposition have been met, and establishes the desirability of application a “lesser duty” rule. Under a lesser duty rule, authorities impose duties at a level lower than the margin of dumping but adequate to remove injury. Article 9.3 establishes that anti-dumping duties may not exceed the dumping margin calculated during the investigation. In order to ensure that anti-dumping duties in excess of the margin of dumping are not collected, Article 9.3 requires procedures for determination of the actual amount of duty owed, or refund of excess duties paid, depending on the duty assessment system of a Member, normally within 12 months of a request, and in no case more than 18 months. Article 9.4 establishes rules for calculating the amount of duties to be imposed on exporters not individually examined during the investigation. Article 9.5 provides for expedited reviews to calculate individual margins of dumping for exporters or producers newly entering the market of the importing Member.

Article 10 establishes the general principle that both provisional and final anti-dumping duties may be applied only as of the date on which the determinations of dumping, injury, and causality have been made. However, recognizing that injury may have occurred during the period of investigation, or that exporters may have taken actions to avoid the imposition of an anti-dumping duty, Article 10 contains rules for the retroactive imposition of dumping duties in specified circumstances. If the imposition of anti-dumping duties is based on a finding of material injury, as opposed to threat of material injury or material retardation of the establishment of a domestic industry, anti-dumping duties may be collected as of the date provisional measures were imposed. If provisional duties were collected in an amount greater than the amount of the final duty, or if the imposition of duties is based on a finding of threat of material injury or material retardation, a refund of provisional duties is required. Article 10.6 provides for retroactive application of final duties to a date not more than 90 days prior to the application of provisional measures in certain exceptional circumstances involving a history of dumping, massive dumped imports, and potential undermining of the remedial effects of the final duty.

  
Duration, termination, and review of anti-dumping measures
Article 11 establishes rules for the duration of anti-dumping duties, and requirements for periodic review of the continuing need, if any, for the imposition of anti-dumping duties or price undertakings. These requirements respond to the concern raised by the practice of some countries of leaving anti-dumping duties in place indefinitely. The “sunset” requirement establishes that dumping duties shall normally terminate no later than five years after first being applied, unless a review investigation prior to that date establishes that expiry of the duty would be likely to lead to continuation or recurrence of dumping and injury. This five year “sunset” provision also applies to price undertakings. The AD Agreement requires authorities to review the need for the continued imposition of a duty upon request of an interested party.

  
Public notice
Article 12 sets forth detailed requirements for public notice by investigating authorities of the initiation of investigations, preliminary and final determinations, and undertakings. The public notice must disclose non-confidential information concerning the parties, the product, the margins of dumping, the facts revealed during the investigation, and the reasons for the determinations made by the authorities, including the reasons for accepting and rejecting relevant arguments or claims made by exporters or importers. These public notice requirements are intended to increase the transparency of determinations, with the hope that this will increase the extent to which determinations are based on fact and solid reasoning.

  
The committee and dispute settlement

Article 16 establishes the Committee on Anti-Dumping Practices, and sets forth requirements for Members to notify without delay all preliminary and final actions taken in anti-dumping investigations, and notify semi-annually all actions taken during the relevant reporting period.

Article 17 establishes that the Dispute Settlement Understanding is applicable to disputes under the AD Agreement. However, Article 17.6 establishes a special standard of review to be applied by panels in examining disputes in anti-dumping cases with regard both to matters of fact and questions of interpretation of the Agreement. This standard gives a degree of deference to the factual decisions and legal interpretations of national authorities, and is intended to prevent dispute settlement panels from making decisions based purely on their own views. A Ministerial Decision, which is not part of the AD Agreement, regarding this provision establishes that its operation will be reviewed after three years with a view to consideration whether it is capable of general application.

  
Final provisions
Article 18.3 establishes the effective date of the AD Agreement, providing that it is applicable to investigations and reviews of existing measures initiated pursuant to applications made on or after the entry into force of the AD Agreement. Article 18.4 requires Members to bring their laws into conformity with the AD Agreement by the date of entry into force of the AD Agreement. Under Article 18.5, Members are required to notify their anti-dumping laws and regulations to the Committee.

Annex I to the AD Agreement establishes procedures for “on-the-spot” investigations, which are generally undertaken in the territory of an exporting Member to verify information provided by foreign producers or exporters. Annex II to the AD Agreement sets forth provisions on the use of “best information available” in investigations, specifying the conditions under which investigating authorities may rely on information from a source other than the person concerned.

The Ministerial Decision on Anti-Circumvention, which is not part of the AD Agreement, noted that the negotiators had been unable to agree on a specific text dealing with the problem of anti-circumvention, recognized the desirability of applying uniform rules in this area as soon as possible, and referred the matter to the Committee for resolution. The Committee has established an Informal Group on Anti-Circumvention, which is open to participation by all Members, to carry out the task assigned by the Ministers.
  


Exhibit 4

Dispute Settlement: the WTO’s ‘most individual contribution’[5]
Without a means of settling disputes, the rules-based system would be worthless because the rules could not be enforced. The WTO’s procedure underscores the rule of law, and it makes the trading system more secure and predictable. The system is based on clearly-defined rules, with timetables for completing a case.

First rulings are made by a panel and endorsed (or rejected) by the WTO’s full membership. Appeals based on points of law are possible.

However, the point is not to make rulings. The priority is to settle disputes, through consultations if possible. By July 2000, 32 out of 203 cases had been settled “out of court”, without going through the full panel process.

  
Principles: equitable, fast, effective, mutually acceptable
WTO members have agreed that if they believe fellow-members are violating trade rules, they will use the multilateral system of settling disputes instead of taking action unilaterally. That means abiding by the agreed procedures, and respecting judgements.

Typically, a dispute arises when one country adopts a trade policy measure or takes some action that one or more fellow-WTO members considers to be breaking the WTO agreements, or to be a failure to live up to obligations. A third group of countries can declare that they have an interest in the case and enjoy some rights.

A procedure for settling disputes existed under the old GATT, but it had no fixed timetables, rulings were easier to block, and many cases dragged on for a long time inconclusively. The Uruguay Round agreement introduced a more structured process with more clearly defined stages in the procedure. It introduced greater discipline for the length of time a case should take to be settled, with flexible deadlines set in various stages of the procedure. The agreement emphasizes that prompt settlement is essential if the WTO is to function effectively. It sets out in considerable detail the procedures and the timetable to be followed in resolving disputes. If a case runs its full course to a first ruling, it should not normally take more than about one year — 15 months if the case is appealed. The agreed time limits are flexible, and if the case is considered urgent (e.g. if perishable goods are involved), then the case should take three months less.

The Uruguay Round agreement also made it impossible for the country losing a case to block the adoption of the ruling. Under the previous GATT procedure, rulings could only be adopted by consensus, meaning that a single objection could block the ruling. Now, rulings are automatically adopted unless there is a consensus to reject a ruling — any country wanting to block a ruling has to persuade all other WTO members (including its adversary in the case) to share its view.

Although much of the procedure does resemble a court or tribunal, the preferred solution is for the countries concerned to discuss their problems and settle the dispute by themselves. The first stage is therefore consultations between the governments concerned, and even when the case has progressed to other stages, consultation and mediation are still always possible.

  
How long to settle a dispute?
These approximate periods for each stage of a dispute settlement procedure are target figures — the agreement is flexible. In addition, the countries can settle their dispute themselves at any stage. Totals are also approximate.

60 days           Consultations, mediation, etc

45 days           Panel set up and panelists appointment

6 months         Final panel report to parties

3 weeks           Final panel report to WTO members

60 days           Dispute Settlement Body adopts report (if no appeal)

    Total = 1 year          (without appeal)

60-90 days      Appeals report

30 days           Dispute Settlement Body adopts appeals report

Total = 1year 3months          (with appeal)

How are disputes settled?
Settling disputes is the responsibility of the Dispute Settlement Body (the General Council in another guise). The Dispute Settlement Body has the sole authority to establish “panels” of experts to consider the case, and to accept or reject the panels’ findings or the results of an appeal. It monitors the implementation of the rulings and recommendations, and has the power to authorize retaliation when a country does not comply with a ruling.

     First stage: consultation (up to 60 days). Before taking any other actions the countries in dispute have to talk to each other to see if they can settle their differences by themselves. If that fails, they can also ask the WTO director-general to mediate or try to help in any other way.

     Second stage: the panel (up to 45 days for a panel to be appointed, plus 6 months for the panel to conclude). If consultations fail, the complaining country can ask for a panel to be appointed. The country “in the dock” can block the creation of a panel once, but when the Dispute Settlement Body meets for a second time, the appointment can no longer be blocked (unless there is a consensus against appointing the panel).

Officially, the panel is helping the Dispute Settlement Body make rulings or recommendations. But because the panel’s report can only be rejected by consensus in the Dispute Settlement Body, its conclusions are difficult to overturn. The panel’s findings have to be based on the agreements cited.

The panel’s final report should normally be given to the parties to the dispute within six months. In cases of urgency, including those concerning perishable goods, the deadline is shortened to three months.

The agreement describes in some detail how the panels are to work. The main stages are:

     Before the first hearing: each side in the dispute presents its case in writing to the panel.

     First hearing: the case for the complaining country and defence: the complaining country (or countries), the responding country, and those that have announced they have an interest in the dispute, make their case at the panel’s first hearing.

     Rebuttals: the countries involved submit written rebuttals and present oral arguments at the panel’s second meeting.

     Experts: if one side raises scientific or other technical matters, the panel may consult experts or appoint an expert review group to prepare an advisory report.

     First draft: the panel submits the descriptive (factual and argument) sections of its report to the two sides, giving them two weeks to comment. This report does not include findings and conclusions.

     Interim report: The panel then submits an interim report, including its findings and conclusions, to the two sides, giving them one week to ask for a review.

     Review: The period of review must not exceed two weeks. During that time, the panel may hold additional meetings with the two sides.

     Final report: A final report is submitted to the two sides and three weeks later, it is circulated to all WTO members. If the panel decides that the disputed trade measure does break a WTO agreement or an obligation, it recommends that the measure be made to conform with WTO rules. The panel may suggest how this could be done.

    The report becomes a ruling: The report becomes the Dispute Settlement Body’s ruling or recommendation within 60 days unless a consensus rejects it. Both sides can appeal the report (and in some cases both sides do).

Appeals
Either side can appeal a panel’s ruling. Sometimes both sides do so. Appeals have to be based on points of law such as legal interpretation — they cannot reexamine existing evidence or examine new evidence.

Each appeal is heard by three members of a permanent seven-member Appellate Body set up by the Dispute Settlement Body and broadly representing the range of WTO membership. Members of the Appellate Body have four-year terms. They have to be individuals with recognized standing in the field of law and international trade, not affiliated with any government.

The appeal can uphold, modify or reverse the panel’s legal findings and conclusions. Normally appeals should not last more than 60 days, with an absolute maximum of 90 days.

The Dispute Settlement Body has to accept or reject the appeals report within 30 days — and rejection is only possible by consensus. 

  
The case has been decided: what next?
Go directly to jail. Do not pass Go, do not collect .... Well, not exactly. But the sentiments apply. If a country has done something wrong, it should swiftly correct its fault. And if it continues to break an agreement, it should offer compensation or suffer a suitable penalty that has some bite.

Even once the case has been decided, there is more to do before trade sanctions (the conventional form of penalty) are imposed. The priority at this stage is for the losing “defendant” to bring its policy into line with the ruling or recommendations. The dispute settlement agreement stresses that “prompt compliance with recommendations or rulings of the DSB [Dispute Settlement Body] is essential in order to ensure effective resolution of disputes to the benefit of all Members”.

If the country that is the target of the complaint loses, it must follow the recommendations of the panel report or the appeals report. It must state its intention to do so at a Dispute Settlement Body meeting held within 30 days of the report’s adoption. If complying with the recommendation immediately proves impractical, the member will be given a “reasonable period of time” to do so. If it fails to act within this period, it has to enter into negotiations with the complaining country (or countries) in order to determine mutually-acceptable compensation — for instance, tariff reductions in areas of particular interest to the complaining side.

If after 20 days, no satisfactory compensation is agreed, the complaining side may ask the Dispute Settlement Body for permission to impose limited trade sanctions (“suspend concessions or obligations”) against the other side. The Dispute Settlement Body should grant this authorization within 30 days of the expiry of the “reasonable period of time” unless there is a consensus against the request.

In principle, the sanctions should be imposed in the same sector as the dispute. If this is not practical or if it would not be effective, the sanctions can be imposed in a different sector of the same agreement. In turn, if this is not effective or practicable and if the circumstances are serious enough, the action can be taken under another agreement. The objective is to minimize the chances of actions spilling over into unrelated sectors while at the same time allowing the actions to be effective.

In any case, the Dispute Settlement Body monitors how adopted rulings are implemented. Any outstanding case remains on its agenda until the issue is resolved.
 


Suggestions for Further Reading

Dam, Kenneth W., The Rules of the Global Game: A New Look at US International Economic Policymaking (Chicago: University of Chicago Press, 2001).

Dinan, Desmond, Ever Closer Union? An Introduction to the European Community (Boulder, CO: Lynne Riener, 1994).

Finger, J. Michael, Antidumping: How it Works and Who Gets Hurt (Ann Arbor, MI: University of Michigan Press, 1993).

Jackson, John H., and Edwin Vermulst, Antidumping Law and Practice: A Comparative Study (Ann Arbor, MI: University of Michigan Press, 1989).

Jackson, John H., The World Trading System: Law and Policy of International Economic Relations 2nd edition (Cambridge: MIT Press, 1997).

Lash, William H. III, U.S. International Trade Regulation: A Primer (Washington: AEI Press, 1998).

Michalopolous, Constantine, Developing Countries in the WTO (London: Palgrave 2001).

Porter, Roger et. al., eds., Efficiency, Equity, Legitimacy: The Multilateral Trading System at the Millennium (Washington: Brookings Institution, 2001).

Quershi, Asif H., The World Trade Organization: Implementing International Trade Norms (Manchester: Manchester University Press, 1996).

Trebilcock, Michael J. and Robert Howse, The Regulation of International Trade, 2d edition (London and New York: Routledge, 2000).



[2]       Source: europa.eu.int/comm/trade/policy/dumping/compl.htm.

[3]     Source: www.wto.org/english/docs_e/legal_e/ursum_e.htm#fAgreement

  

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