May 01, 2005

ASTM International is pleased to take this opportunity to comment on United States - China economic relations and China’s role in the world economy. As the largest U.S. domiciled international standards developing organization, we are particularly interested in commenting on China’s progress and the U.S. response in the implementation of China’s World Trade Organization (WTO) accession commitments to remove non-tariff barriers to trade such as standards and technical regulations. Standards are vital to everyday commerce and trade as they effectively provide for a level playing field and ensure that two parties involved in a contract or two nations involved in trade are able to communicate clearly, in a common language.

ASTM International’s Role in International Trade

ASTM International facilitates the development of technical standards for about 90 industrial sectors including steel, copper, plastics, building construction, roads, petroleum, textiles, adhesives, medical devices, sports equipment, air quality, water quality, consumer product safety, nuclear energy, industrial chemicals, etc. With 30,000 individual technical experts from 118 countries - including China - participating in the drafting of ASTM standards, ASTM International is truly a global forum for the development of consensus standards. ASTM standards and technical documents serve as the basis for manufacturing, management, procurement, codes, and regulations worldwide.

ASTM International Agreements with Chinese Standards Bodies

ASTM International has a long history of participation in Chinese standardization activities and many deep and mutually productive relationships. Activities include the recent signing of an agreement with the Standardization Administration of the People’s Republic of China, and agreements with other standards organizations including the Chinese National Institute of Standardization and the Shanghai Institute of Standardization.

Through our agreements with China’s leading standards bodies, ASTM International provides access to all ASTM standards; jointly sponsors standards and training programs; provides participating membership to Chinese representatives on ASTM technical committees; and provides internship programs for Chinese experts to come to ASTM International’s Global Headquarters in Pennsylvania for extended study of the ASTM International standards development process. In return, the Chinese standards bodies promote the acceptance and use of ASTM standards in China; utilize the resources of ASTM International to develop Chinese National Standards and reference ASTM standards where applicable in Chinese National Standards (China currently uses over 500 ASTM standards as the basis oftheir national standards); and facilitate connections between Chinese technical experts and ASTM International technical committees to ensure that the standards meet the needs of Chinese industry.

ASTM International’s Presence in China

ASTM International is one of four U.S.-based international standards development organizations that have jointly established the Consortium for Standards and Conformity Assessment (CSCA) and that has opened a new China office to establish a much-needed presence in China for U.S.-based standards and conformity assessment organizations. Located in Beijing, the office will help to build cooperative and enduring relationships with Chinese governmental and industry standards associations. It will also help promote the acceptance and use of ASTM International standards and of other U.S.-domiciled standards developing organizations in China. Part of the funding for the office was awarded through the U.S. Commerce Department’s Market Development Cooperator Program. The other members of the consortium are the American Petroleum Institute, ASME International (formerly known as the American Society of Mechanical Engineers), and CSA America.

China’s Obligations Under the WTO TBT Agreement

With China’s accession to the WTO comes an obligation for China to comply with the World Trade Organization’s Technical Barriers to Trade (TBT) Agreement. The WTO TBT Agreement has established certain rules and procedures that pertain to the development, adoption and application of mandatory technical regulations, voluntary product standards, and the procedures used to determine compliance with those standards and regulations. Under the WTO TBT Agreement, international standards are recognized based on the transparency, openness and impartiality in their development process rather than the label they bear or their source.

While ASTM standards are accepted and used throughout the world as the basis for contracts, codes, and regulations, access to global markets increasingly depends on standards being set by other countries and international organizations. Some nations have government policies or laws that prohibit the use of de facto international standards, including those developed by ASTM International. Of particular concern, the implementation document (Document #10) of China’s Law of Standards states in chapter 1, section 3;

"International Standards are the standards issued by the International Standard Organization (ISO), International Electrotechnical Commission (IEC), International Telecommunication Union (ITU) and other international organizations recognized and publicized by ISO."

China’s definition of "international standards" appears to be inconsistent with the definitions and principles of the WTO TBT Agreement. This definition can also be disadvantageous to the efforts of many businesses to compete in China’s emerging marketplace.

Through the CSCA office and other contacts, ASTM International will continue to engage in an open dialogue with Chinese governmental and enterprise representatives so they might better understand the multiple paths to international standardization and conformity assessment. While we are encouraged by efforts to date, continued attention from the U.S. government officials and Congress would be welcomed to ensure that a market-oriented, enterprise-centered standards development system develops in China that is consistent with the WTO TBT Agreement obligations. The U.S. government should communicate a clear and concise statement of U.S. trade policy as it relates to the WTO TBT Agreement and its obligations to accept and use "international standards" based on the transparency, openness and impartiality in their development process rather than the label they bear or their source.

Because voluntary consensus standards developed under the auspices of ASTM International incorporate various aspects of current market practice for example safety, quality, efficiency, or the implementation of new materials China will benefit from the application of these standards in improving the quality of its goods, advancing the health and safety of its people and environment, and enhancing its competitiveness in a global marketplace.

China Launches Aggressive Standards Strategy

Recognizing that standards will continue to be a key success factor in the expansion of its economy and manufacturing base, and because of its accession to the WTO, China launched two research programs in September 2002. The programs, on the technical standards development strategy in China and the establishment of a national technical standards system, established strategic goals to be accomplished in three phases by 2050.

By 2010, form a new voluntary technical standards system and enhance the market adaptability of technical standards;
By 2020, perfect the technical standards system and raise the level of Chinese technical standards development; and
By 2050, ensure that Chinese technical standards hold a pre-eminent and prominent international status.

This strategy has created a demand for the development of technical standards across a wide range of industry sectors.

Conclusion

In conclusion, the standards of ASTM International are widely applied in various industries in China. With China’s accession to the WTO comes an obligation for China to comply with the WTO TBT Agreement. We expect that with China’s entry into the WTO and the expansion of international communication and international trade, the standards of ASTM international will most likely increase in popularity as more and more enterprises will adopt them. While we are pleased with our agreements and relationships with the Chinese standards community, we welcome the interest and attention from Congress and would benefit from a clear and concise statement of U.S. trade policy as it relates to the WTO TBT Agreement and its obligations to accept and use "international standards" based on the transparency, openness and impartiality in their development process rather than the label they bear or their source.

Thank you for the opportunity to comment and please feel free to contact ASTM International’s office in Washington, D.C., at 202/223-8505, or our Global Headquarters in Pennsylvania at 610/832-9687, if we can provide additional information.