U.S. DEPARTMENT OF
COMMERCE
Office
of Environmental Technologies Industries
www.environment.ita.doc.gov
Survey
of Non-Tariff Trade Barriers to the U.S. Environmental Industry
The
U.S. Department of Commerce seeks your assistance in identifying
non-tariff trade
barriers (NTBs)
that affect U.S. exports of environmental goods and services. The
information you provide will be used to seek the elimination of
these barriers. NTBs occur in many forms; examples include:
quotas, licensing requirements, customs procedures, and limits on
delivery of professional services.
Name:
Title:
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Company Name:
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Address:
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City:
State:
Zip:
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Phone Number:
Fax:
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E-mail:
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Regions of
Interest:
Is
the information supplied in this survey business confidential?
Yes
No
Freedom
of Information Act: Information submitted to the government
may be subject to disclosure pursuant to the Freedom of
Information Act. However, all confidential commercial information
will be protected from disclosure to the extent permitted by law.
You will be notified in advance if any such information submitted
by you becomes subject to release pursuant to a Freedom of
Information Act request.
Type
of Company (check all that apply):
Architectural
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Construction
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Consulting
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Distributor
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Engineer
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Federal
Agency
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Finance
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Legal
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Manufacturer
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Media
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Minority/Female
Owned
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Service
Provider
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State
Agency
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State
Enviro Bus Assoc
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Trade
Association
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Trade
Center
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Trade
Show Firm
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University/Academic
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U.S.
NGO
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Utility
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Other
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Industry
(check all that apply):
Air
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All
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Energy
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Finance
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Hazardous
Waste
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Incineration
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Instrumentation/Monitoring
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Medical
Waste
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Oil
Cleanup
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Pollution
Prevention
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Recycling
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Remediation
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Sanitation
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Services
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Solid
Waste Eqp.
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Solid
Waste Serv.
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Water/Wastewater
Eqp.
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Water/Wastewater
Serv.
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Other
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Annual Sales (check
one):
Under
$1 million
$1-$5
million
$6-$50
million
$51-$75
million
Over
$75 million
Unknown
Non - Tariff
Barriers Survey
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Please
check the non-tariff trade barriers (NTBs) that your company has
experienced. Provide as much information as possible for each
barrier cited. Following each item checked, please include
specific laws, regulations, etc... of the country that adversely
affect the importation of your products and services, and in each
instance, name specific countries. For example: “In country
X, regulations (cite regulations) do not allow the establishment
of foreign owned engineering companies. For every construction
project in country Y, it is necessary to get design approval from
local institutes that do not publish transparent design
specifications.”
1.)
Subsidies:
Internal
subsidies for local producers or service providers
Cheap
financing and tax holidays for local
manufacturers
Other
Explain:
Specific Examples-
2.)
Quotas and Quantitative Restrictions:
Limits
on number of service suppliers in a market
Limits
on how many units/dollars of products can be imported
Cut-off
dates during calendar year for entry of products
Other
Explain:
Specific Examples-
3.)
Sanitary and Phythosanitary (SPS) Measures:
Onerous
licensing procedures
non
Science-base regulations
Other
Explain:
Specific Examples-
4.)
Restrictions on Who Can Import:
Only
state sanctioned trading companies may import
Govt./Quasi
Govt. organizations only are permitted to import
Govt.
organizations are sometimes/always exonerated from paying
duties
Govt.
organizations can have preferential access to foreign
exchange
Private
firms with accumulated "export credits" can have
preferential access to foreign exchange/import
permits
Other
Explain:
Specific Examples-
5.)
Labeling, Packaging, & Documentation Requirements
Date
of expiration of chemical requirements
Pallet/packaging
fumigation requirements
Conflicting
hazardous material labeling requirements and packaging between
countries of origin & destination
Conflicting
requirements of support documentation for hazardous materials
(i.e.- MSDS documentation)
Labeling
indicating certification of requirements of importing
country
Other
Explain:
Specific Examples-
6.)
Standards
ISO
certifications required to supply products or services- ISO 14000
environmental standards must be met
Requirements
for periodic proof of instrument calibration
Emissions
compliance requirements
Safety
requirements for grounding and other hazards
Off-standard
electrical requirements (90-120 VAC/60hz etc )
Unclear
quality regulations or those based on unique or outdated
standards
Use
of metrological certification boards to determine if
instrumentation is designed to standard(s)
Milling
mixing or other processing regulations
Other
Explain:
Specific Examples-
7.)
Intellectual Property Requirements
Inadequate
protection
Inadequate
enforcement
Arbitrary
rulings on patent or trademark rights forcing time consuming
court reviews
Other
Explain:
Specific Examples-
8.)
Harassment of Imports:
Onerous
licencing or qualification requirements
Embargoes
(political or economic)
Arbitrary
values on goods for duty purposes including shipping
charges
National
boycotts
Currency
fluctuations adversely affecting importers
Delays
resulting from competitor's influence on susceptible officials
(corruption/bribery)
Cumbersome
customs formalities/requirements
Restrictive
customs procedures that promulgate complexities and regulations
for classifying and valuing commodities making compliance
difficult and expensive
Other
Explain:
Specific Examples-
9.)
Restrictions on Distribution, Logistics, and Banking
Services:
Foreign
exchange restrictions
Access
to hard currency
Advanced
deposit on import requirements
National
carrier preferences
Foreign
carrier restrictions
Prohibition
of collection-basis sales
Govt
requirements to withhold/reduce commission payments to
distributors
Arbitrarily
short periods in which to apply for import licenses
Pre-shipment
inspections required prior to exportation from source
country
Other
Explain:
Specific Examples-
10.)
Restrictions on Marketing:
Advertising
restrictions
Complicated
bidding requirements
Requirements
for local surety and performance bonds
Proof
of % of national content requirements
Letters
of authorization to sell (or resell) product or service
requirements
Requirements
for extended or extraordinary warranty coverage for product or
service
Arbitrary
rulings on patent or trademark rights forcing time consuming
court reviews
National
state or municipal requirements to use specific distribution
channels at the wholesale and retail level
Other
Explain:
Specific Examples-
11.)
Restrictions on Investment & Nature of Commercial
Relationships
Restrictions
on foreign ownership of companies
Restrictions
on foreign management of companies
Commercial
relationships such as partnerships are not permitted
Percentage
of local workforce required
Percentage
of local content required
Better
treatment provided to home country investors or third party
investors
Other
Explain:
Specific Examples-
12.)
Discriminatory Devices:
Unfair
competition from local state-owned enterprises
Competition
from third-country exporters who enjoy subsidies monopolies or
state-organization status
Discriminatory
government purchasing practices
Discrimination
resulting from bilateral trade agreements or barter
agreements
Discrimination
arising from special relationships including ex-colonial status
customs unions commonwealth preferences or currency
areas
Disguised
tariffs such as "surcharges" revenue duties and
consumption taxes levied against only imported goods
Turnover
equalization taxes ostensibly to put imports on the footing as
local products
Countervailing
duties (offsets to subsidies)
Arbitrary
interpretations of anti-dumping laws
Impact
psychological or direct of "buy home products"
policies
Other
Explain:
Specific Examples-
13.)
Restrictions on the Cross-Border Supply of a
Service:
Limitations
on movement of personnel to supply a service
Restrictions
on what services can be sold cross-border
Local
presence requirements that must be met before service can be
supplied cross-border
Other
Explain:
Specific Examples-
14.)
Transparency:
Non-transparent
regulations
Unequal
enforcement of regulations
Regulations
imposed without prior notice or input from interested
parties
Other
Explain:
Specific Examples-
15.)
Recognition:
Licencing
or certification requirements unevenly applied to
professionals
Other
Explain:
Specific Examples-
Privacy
Statement
Burden Statement
Public
reporting for this collection of information is estimated to be
10 minutes per response, including the time for reviewing
instructions, and completing and reviewing the collection of
information. All responses to this collection of information are
voluntary, and will be provided confidentially to the extent
allowed under the Freedom of Information Act. Notwithstanding any
other provision of law, no person is required to respond to nor
shall a person be subject to a penalty for failure to comply with
a collection of information subject to the requirements of the
Paperwork Reduction Act unless that collection of information
displays a current valid OMB Control Number. Send comments
regarding the burden estimate or any other aspect of this
collection of information, including suggestions for reducing
this burden, to the Reports Clearance Officer, International
Trade Administration, Department of Commerce, Room 4001, 14th and
Constitution Avenue, N.W., Washington, D.C. 20230.
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