World Trade Organization: Ensuring China's Compliance Requires a Sustained and Multifaceted Approach

Published by the Government Accountability Office on 2003-10-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                               United States General Accounting Office

GAO                            Testimony
                               Before the Committee on Ways and
                               Means, House of Representatives

For Release on Delivery 

Expected at 2:00 p.m., EST 


October 30, 2003

                               WORLD TRADE 


                               Ensuring China’s
                               Compliance Requires a
                               Sustained and Multifaceted
                               Statement of Loren Yager, Director
                               International Affairs and Trade


                                                 October 30, 2003

                                                 WORLD TRADE ORGANIZATION

                                                 Ensuring China's Compliance Requires a
 Highlights of GAO-04-172T, a testimony          Sustained and Multifaceted Approach
 before the Committee on Ways and
 Means, House of Representatives

China’s accession to the World                   The scope and complexity of China’s WTO commitments present two
Trade Organization (WTO) in                      main challenges to verifying China’s compliance with its WTO accession
December 2001 created                            agreement. First, the agreement is very broad: It encompasses more than
substantial opportunities for U.S.               800 pages, spans eight broad areas, and sets forth hundreds of individual
companies seeking to expand into                 commitments on how China’s trade regime will adhere to the WTO’s
China’s market. In joining the                   agreements, principles, and rules and allow greater market access.
WTO, China agreed to liberalize                  Second, the agreement is complicated: Interrelated parts will be phased
its trade regime and open its                    in at different times, and some commitments are so general in nature that
markets to foreign goods and                     it may not be immediately clear whether China has fully complied with
services. However, the U.S.                      its obligations.
government has become
concerned about ensuring that                    Each of the key players involved in ensuring China’s compliance—the
China honors its commitments to                  executive branch, Congress, the private sector, and the WTO and its
offer a more predictable                         members--has made efforts to ensure China’s compliance. However, the
environment for trade.                           first-year experience in this regard has demonstrated that these efforts
                                                 will need to be sustained over a long period. The executive branch has
GAO was asked to describe (1)                    applied additional resources and new intra-agency teams to these efforts,
the monitoring of compliance                     but it takes time to organize these activities. Congress has enacted
challenges associated with the                   legislation and established new entities to increase oversight of China’s
scope and complexity of China’s                  compliance. The private sector also has provided information to the
WTO commitments and (2) the                      executive branch and to Congress on the status of China’s compliance
efforts to date of the key players               efforts. And, within the WTO, a China-specific mechanism was
involved in ensuring China’s                     established as a means for WTO members to annually review China’s
compliance: the executive branch,                implementation of its commitments. Nonetheless, GAO’s analysis
Congress, the private sector, the                indicates that a sustained approach is needed to ensure China’s
WTO and its other members.                       compliance.
                                                 Multifaceted Approach Essential to Ensuring China’s WTO Compliance
GAO’s observations are based on
its prior analysis of China’s WTO
commitments, its previous survey
of and interviews with private
sector representatives, and its
examination of first-year efforts
to ensure China’s WTO


 To view the full product, including the scope
 and methodology, click on the link above.
 For more information, contact Loren Yager at
 (202) 512-4347 or YagerL@gao.gov.
Mr. Chairman and Members of the Committee:

I am pleased to be here today to discuss our observations on the
challenges involved in ensuring that China honors its commitments to the
World Trade Organization (WTO). This hearing takes place not only at a
time of increasing trade between the United States and China, but also at a
time of increasing concern about broader aspects of the U.S.-China
relationship. Although China’s implementation of its WTO commitments
cannot fully eliminate those concerns, compliance with its WTO
obligations is a central feature of China’s economic relationship with the
United States and other WTO members. However, as we have found in our
analysis of the first year’s efforts to monitor and enforce China’s
compliance with its WTO commitments, the scope and complexity of the
agreement indicate that ensuring compliance will be difficult and will
require sustained efforts from all the key players to be successful.

To provide you with an update on these issues, today I will discuss (1) the
compliance challenges associated with the scope and complexity of
China’s WTO commitments and (2) the efforts to date of each of the key
players involved in ensuring China’s compliance with its WTO obligations:
the executive branch, Congress, the private sector, and the WTO and its
members. My observations are based on a series of studies that we
initiated at the request of this Committee and of the Senate Committee on
Finance. That work has included a comprehensive analysis of China’s
commitments,1 our survey and interviews with the private sector
representatives,2 and our examination of first-year U.S. compliance
efforts.3 Before I turn to the specifics on these issues, let me provide a
brief summary.

See U.S. General Accounting Office, World Trade Organization: Analysis of China’s
Commitments to Other Members, GAO-03-4 (Washington, D.C.: Oct. 3, 2002).
 See U.S. General Accounting Office, World Trade Organization: Selected U.S. Company
Views About China’s Membership, GAO-02-1056 (Washington, D.C.: Sept. 23, 2002).
See U.S. General Accounting Office, World Trade Organization: First-Year U.S. Efforts to
Monitor China’s Compliance, GAO-03-461 (Washington, D.C.: Mar. 31, 2003).

Page 1                                                                    GAO-04-172T
             The comprehensive scope and complexity of China’s WTO accession
Summary      agreement present two main challenges for successfully monitoring and
             enforcing China’s compliance with its obligations. First, the broad scope
             of the agreement, which covers numerous aspects of China’s trade regime
             and market access commitments for goods and services, makes it difficult
             to determine if each commitment has been fully implemented. Similarly,
             the complexity of the agreement also presents challenges for assessing
             compliance. Specifically, some interrelated commitments are phased in at
             different times, and many commitments are so general in nature that it will
             be difficult to immediately assess compliance.

             A sustained approach from several key players, including the executive
             branch, Congress, the private sector, and the WTO and its members, is
             essential to ensuring China’s compliance. Since China’s accession to the
             WTO, these actors have undertaken a range of efforts to ensure China’s
             compliance: the executive branch has ramped up its resources for China
             monitoring and enforcement; Congress has enacted legislation focusing on
             China’s adherence to its obligations; the private sector has continued to
             monitor China’s progress and provide input on compliance priorities; and
             the WTO and its members have conducted an initial review of China’s
             implementation. These compliance efforts encountered various challenges
             in the first year, thus demonstrating the need for a sustained approach to
             successfully ensure that China lives up to its WTO obligations.

             China became the 143rd member of the WTO on December 11, 2001, after
Background   almost 15 years of negotiations. These negotiations resulted in China’s
             commitments to open and liberalize its economy and offer a more
             predictable environment for trade and foreign investment in accordance
             with WTO rules. The United States and other WTO members have stated
             that China’s membership in the WTO provides increased opportunities for
             foreign companies seeking access to China’s market. The United States is
             one of the largest sources of foreign investment in China, and total
             merchandise trade between China and the United States exceeded $145
             billion in 2002, according to U.S. trade data. However, the United States
             still maintains a trade deficit with China: Imports from China totaled
             $124.8 billion, while exports totaled $20.6 billion in 2002. Through the first
             half of 2003, exports to and imports from China grew about 25 percent
             compared to same period in the previous year.

             Page 2                                                            GAO-04-172T
                        The U.S. government’s efforts to ensure China’s compliance with its WTO
                        commitments are part of an overall U.S. structure to monitor and enforce
                        foreign governments’ compliance with existing trade agreements.4 At least
                        17 federal agencies, led by the Office of the U.S. Trade Representative
                        (USTR), are involved in these overall monitoring and enforcement
                        activities. USTR and the departments of Agriculture (USDA), Commerce,
                        and State have relatively broad roles and primary responsibilities with
                        respect to trade agreement monitoring and enforcement. Other agencies,
                        such as the departments of the Treasury and Labor, play more specialized
                        roles. Federal monitoring and enforcement efforts are coordinated
                        through an interagency mechanism comprising several management- and
                        staff-level committees and subcommittees. The congressional structure for
                        funding and overseeing federal monitoring and enforcement activities is
                        similarly complex, because it involves multiple committees of jurisdiction.
                        Congressional agencies, including GAO, and commissions also support
                        Congress’s oversight on China-WTO trade issues. In addition to the
                        executive branch and congressional structures, multiple private sector
                        advisory committees exist to provide federal agencies with policy and
                        technical advice on trade matters, including trade agreement monitoring
                        and enforcement.

                        China’s accession agreement is the most comprehensive of any WTO
Scope and               member’s to date, and, as such, verifying China’s WTO compliance is a
Complexity of China’s   challenging undertaking for two main reasons. The first reason is the
                        scope of the agreement: The more than 800-page document spans eight
WTO Commitments         broad areas and sets forth hundreds of individual commitments on how
Present Challenges      China’s trade regime will adhere to the organization’s agreements,
                        principles, and rules and allow greater market access for foreign goods
for Ensuring            and services. The second reason is the complexity of the agreement:
Compliance              Interrelated parts of the agreement will be phased in at different times,
                        and some commitments are so general in nature that it will not be
                        immediately clear whether China has fully complied with its obligations in
                        some cases.

                         For more information on the overall roles and responsibilities of U.S. government agencies
                        in monitoring and enforcing trade agreements, see U.S. General Accounting Office,
                        International Trade: Strategy Needed to Better Monitor and Enforce Trade Agreements,
                        GAO/NSIAD-00-76 (Washington, D.C.: Mar. 14, 2000).

                        Page 3                                                                      GAO-04-172T
Scope of Commitments   The comprehensive scope of China’s WTO accession agreement represents
Poses Inherent         a challenge for the U.S. government’s compliance efforts. The
Compliance Issues      commitments cover eight broad areas of China’s trade regime, including
                       import regulations, agriculture, services, and intellectual property rights.
                       Within these eight broad areas, we identified nearly 700 individual
                       commitments that China must implement to comply with its WTO
                       obligations. China has also committed to lower a variety of market access
                       barriers to foreign goods. These obligations include commitments to
                       reduce or eliminate tariffs on more than 7,000 products and eliminate
                       nontariff barriers on about 600 of these products. Additionally, China
                       made commitments to allow greater market access in 9 of 12 general
                       services sectors, including banking, insurance, and telecommunications.

                       The scope of compliance problems raised in the first year of China’s
                       membership reflects the scope of the agreement itself. Although the
                       executive branch’s first-year assessment of China’s implementation of its
                       WTO commitments acknowledged China’s effort and progress in some
                       areas, the assessment also noted compliance problems in all eight broad
                       areas of China’s trade regime.5 In particular, the executive branch
                       emphasized problems in agriculture, services, and intellectual property
                       rights, as well as a crosscutting concern about transparency. Some
                       preliminary assessments of China’s second-year implementation from the
                       private sector suggest that many of those problems persist and that
                       concern about the number and scope of compliance issues continues to

                        See U.S. Trade Representative, 2002 Report to Congress on China’s WTO Compliance
                       (Washington, D.C.: Office of the U.S. Trade Representative, Dec. 11, 2002).

                       Page 4                                                                 GAO-04-172T
Complexity of Agreement    While many of China’s commitments were due to be phased in upon
Presents Additional        China’s accession to the WTO in 2001, a number of interrelated
Challenges for Assessing   commitments are scheduled to be implemented over extended time
                           frames. For example, commitments on trading rights and distribution are
Compliance                 not scheduled to be fully phased in until the end of 2004 and 2006,
                           respectively. As a result, foreign businesses will be unable to fully
                           integrate import, export, and distribution systems until that time.
                           Additionally, although market access for most goods and services will be
                           phased in by 2007, some tariffs will not be fully liberalized until 2010. (See
                           fig. 1.)

                           Page 5                                                            GAO-04-172T
Figure 1: Summary of Key Phase-in Dates for China’s WTO Commitments, 2001-2016


NTM: nontariff measure 

TBT: technical barriers to trade 

TRQ: tariff-rate quota 

TRM: transitional review mechanism

                                      Page 6                                     GAO-04-172T
                         The varying nature of China’s commitments also complicates U.S.
                         government compliance efforts. On the one hand, some of China’s WTO
                         obligations require specific actions from China, such as reporting
                         particular information to the WTO, or lowering a tariff on a product.
                         Assessing compliance with these specific types of commitments is
                         relatively easy. On the other hand, a significant number of commitments
                         are more general in nature and relate to systemic changes in China’s trade
                         regime. For example, some commitments of this type require China to
                         adhere to general WTO principles of nondiscrimination and transparency.
                         Determining compliance with these more general types of commitments is
                         more difficult and can complicate the dialogue over achieving compliance.

                         It is useful to note that many private sector representatives told us that
                         implementing these general types of commitments, such as those that
                         relate to the rule of law, was relatively more important than carrying out
                         specific commitments to increase market access and liberalize foreign
                         investment in China. Specifically, China’s commitments in the areas of
                         transparency of laws, regulations, and practices; intellectual property
                         rights; and consistent application of laws, regulations, and practices
                         emerged as the most important areas of China’s accession agreement in
                         our September 2002 survey of and interviews with U.S. companies
                         operating in China. 6 However, private sector representatives also
                         indicated that they thought these rule-of-law-related commitments would
                         be the most difficult for China to implement.

                         Because China is such an important trading partner, ensuring China’s
Sustained Effort from    compliance with it s commitments is essential and requires a sustained
Key Players Required     effort on the part of the executive branch, Congress, the private sector,
                         and the WTO and its other members. (See fig. 2.) For example, the
to Ensure China’s        executive branch has extensive involvement in monitoring and enforcing
Compliance, but First-   China’s commitments, and additional resources and new structures have
                         been applied to these tasks. However, the U.S.’s first-year experience
year Experience          showed that it takes time to organize these structures to effectively carry
Demonstrates             out their functions and that progress on the issues can be slow. In addition
Challenges               to the executive branch’s efforts, Congress has enacted legislation,
                         provided resources, and established new entities to increase oversight of
                         China’s compliance. The private sector also has undertaken a wide range
                         of efforts that provide on-the-ground information on the status of China’s

                         For a further description of our results, see GAO-02-1056.

                         Page 7                                                          GAO-04-172T
                             compliance efforts and input to the executive branch and to Congress on
                             priorities for compliance efforts. Finally, the WTO has existing
                             mechanisms as well as a new, China-specific mechanism created as a
                             means for WTO members to annually review China’s implementation of its
                             commitments. Nonetheless, despite the involvement of all of these players
                             in the first year, the United States will need a sustained—and cohesive—
                             approach to successfully carry out this endeavor.

                             Figure 2: Multifaceted Approach Essential to Ensuring China’s WTO Compliance

Key Executive Branch         China’s accession to the WTO has led to increased monitoring and
Agencies Have Increased      enforcement responsibilities and challenges for the U.S. government. In
Focus on China’s             response to these increased responsibilities, USTR and the departments of
                             Commerce, Agriculture, and State have undertaken various efforts to
Compliance, but First-Year   enhance their ability to monitor China’s compliance with its WTO
Efforts Demonstrate          commitments. Agencies have reorganized or established intra-agency
Challenges                   teams to improve coordination of their monitoring and enforcement
                             efforts. Additionally, the agencies have added staff in Washington, D.C.,
                             and overseas in China to carry out these efforts. For example, estimated
                             full-time equivalent staff in key units that are involved in China monitoring
                             and enforcement activities across the four agencies increased from about
                             28 to 53 from fiscal years 2000 to 2002, with the largest increases at the
                             Department of Commerce. On a broader level, USTR has established an
                             interagency group to coordinate U.S. government compliance activities.
                             The interagency group, which utilizes the private sector to support its
                             efforts, was very active in monitoring and responding to issues during the

                             Page 8                                                             GAO-04-172T
                               first year of China’s membership. Nevertheless, it took some time for
                               agencies to work out their respective roles and responsibilities in the
                               interagency group.

                               Monitoring and enforcing compliance with WTO requirements is a
                               complex and challenging task, as shown by our 2002 assessment of the
                               U.S. government’s efforts to ensure China’s compliance with commitments
                               regarding administration of tariff-rate quotas (TRQ)7 for certain bulk
                               agricultural commodities.8 TRQ implementation problems in 2002 included
                               concerns about Chinese authorities missing deadlines for issuing TRQs on
                               certain bulk agricultural commodities; disagreement over whether China’s
                               interpretation of its commitments met WTO requirements; and questions
                               about whether China’s administrative practices were in keeping with its
                               obligations. The United States has undertaken both bilateral and
                               multilateral efforts to settle these complex issues. The large number of
                               U.S. government activities on these issues alone, which still are not fully
                               resolved, included at least monthly engagements with China and illustrates
                               the extensive effort agencies must undertake to identify problems, gather
                               and analyze information, and respond to some issues.

Congressional Focus on         Congress has had an active role in overseeing trade relations between the
China Compliance Issues        United States and China and in setting expectations for vigilant monitoring
Has Increased                  and enforcement of China’s WTO commitments. In the U.S.-China
                               Relations Act of 2000,9 Congress found that for the trade benefits with
Substantially                  China to be fully realized, the U.S. government must effectively monitor
                               and enforce its rights under China’s WTO agreements. To accomplish this,

                          •	   authorized additional resources at USTR and the departments of
                               Commerce and Agriculture;

                          •    called for an annual review of China’s compliance in the WTO;

                                Under China’s TRQ commitments, a specific quantity of certain agricultural bulk
                               commodities is to be allowed in at a low duty, while imports above that quota face higher
                               See GAO-03-461.
                                This constituted a major part of the legislation that led to China’s receiving permanent
                               normal trade relations status. See Pub. L. No. 106-286, 114 Stat. 880.

                               Page 9                                                                         GAO-04-172T
                             •	   established the Congressional-Executive Commission on the People’s
                                  Republic of China to monitor China’s compliance with human rights and
                                  the development of the rule of law in China;

                             •	   established a Task Force on the Prohibition of Importation of Products of
                                  Forced Prison Labor from China;

                             •	   authorized a program to conduct rule of law training and technical
                                  assistance in China; and

                             •	   enacted legislation implementing China’s WTO commitment allowing WTO
                                  members to apply a product-specific safeguard when increases in Chinese
                                  imports threaten or cause injury to domestic industry.

                                  Congress also required that the executive branch issue several China
                                  trade-related reports to assist its continuing oversight. These requirements
                                  included USTR’s annual report on China’s compliance, which is based in
                                  part on input from the general public. In addition, this Committee,
                                  together with the Senate Finance Committee (on a bipartisan basis),
                                  requested that we continue our work on China-WTO issues and report on
                                  China’s compliance, executive branch efforts, and U.S. business views
                                  over 4 years. Finally, congressional committees and commissions have
                                  held at least 35 China-focused hearings since 2001—a further indication of
                                  congressional involvement in U.S.-China issues.

Private Sector Plays Key          U.S. businesses operating in China provide valuable assistance in
Role in Monitoring China’s        monitoring the status of China’s implementation of its WTO commitments,
Compliance                        and, as such, effective coordination between the U.S. government and the
                                  private sector is essential. For example, industry-specific expertise and
                                  input from within the private sector are indispensable components for
                                  determining whether the scores of highly technical laws and regulations
                                  that the Chinese government issues are WTO compliant and being
                                  implemented. Further, private sector industry and business associations
                                  are active in conducting their own analyses and issuing reports on China’s
                                  WTO compliance, providing input to congressional committees and
                                  commissions, engaging the Chinese on specific WTO issues, and
                                  representing their members’ interests to the U.S. government in order to
                                  inform the U.S.’s compliance priorities.

                                  Page 10                                                         GAO-04-172T
WTO Has General and         The WTO’s framework of more than 20 multilateral agreements covers
China-specific Mechanisms   various aspects of international trade and sets forth the rules by which
to Ensure Compliance        China and other members must abide. Notably, the WTO’s dispute
                            settlement mechanism is intended to give all WTO members access to a
                            formal mechanism for pursuing and resolving WTO-related compliance
                            issues with other members, including China. Thus far, no WTO member
                            has initiated a dispute settlement case against China, although some
                            Members of Congress and private sector groups have urged the U.S.
                            government to initiate a case related to China’s administration of TRQs.

                            Another WTO mechanism relates specifically to China. China’s accession
                            commitments created a Transitional Review Mechanism (TRM), as a
                            means for WTO members to annually review China’s implementation of its
                            commitments for 8 years, with a final review in the 10th year following
                            China’s accession.10 Just as establishing the TRM was one of the more
                            challenging issues to negotiate with China, implementing the TRM process
                            during the first year (2002) also proved challenging. Disagreement among
                            WTO members, including China, over the form, timing, and thoroughness
                            of the TRM led to a limited initial review of China’s trade practices. The
                            review did not meet U.S. expectations and illustrated the challenges of
                            gaining consensus with China and other members within this multilateral
                            forum over implementation issues. Although U.S. officials cited benefits
                            from participating in the initial review, they expressed disappointment
                            over the first-year results. U.S. officials are hopeful that future reviews will
                            be more comprehensive. The second-year TRM is under way, but it is still
                            too early to determine if the current review will meet U.S. and other WTO
                            members’ expectations.

                            In assessing China’s first-year implementation efforts, the executive
Concluding                  branch, other WTO member government officials, and many private sector
Observations                representatives observed that, despite several first-year compliance
                            problems, China had demonstrated a willingness to implement its WTO
                            commitments. For example, the executive branch noted China’s progress
                            in revising the framework of laws and regulations governing various
                            aspects of China’s trade regime. In the second year of China’s
                            membership, however, concerns about the number of compliance

                             The TRM is additional to WTO’s trade policy review mechanism, which provides for a
                            broad review of the trade regimes of all WTO members on a scheduled basis. However,
                            WTO members viewed the trade policy review mechanism as insufficient to oversee
                            China’s implementation of its commitments and pursued the TRM.

                            Page 11                                                                  GAO-04-172T
                  problems have grown, as well as the number of events that have
                  potentially interfered with China’s implementation of its commitments.
                  Specifically, some observers have noted events such as changes in China’s
                  central government leadership, reconfigurations of key ministries, a
                  growing concern about unemployment and labor unrest, and the SARS
                  outbreak as possibly temporarily interrupting progress on implementation.

                  In closing, Mr. Chairman, the theme of my testimony is that a cohesive and
                  sustained approach is necessary to monitor and enforce China’s
                  commitments to the WTO. I believe that this hearing that focuses on the
                  key elements of the U.S.-China economic relationship and brings together
                  three of the key players is exactly the kind of oversight that is necessary to
                  ensure that a cohesive and sustained approach is actually carried out.

                  Mr. Chairman and Members of the Committee, this concludes my prepared
                  statement. I would be happy to answer any questions on my testimony that
                  you may have.

                  For further information regarding this testimony, please contact Adam
Contacts and 	    Cowles at (202) 512-9637. Matthew Helm, Rona Mendelsohn, Richard
Acknowledgments   Seldin, and Kim Siegal also made key contributions to this testimony.

                  Page 12                                                          GAO-04-172T
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