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USTRNonrulemakingUSTR-2015-0014

National Trade Estimate Report on Foreign Trade Barriers

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Information Technology Industry Council filings
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Information Technology Industry Council filed 1 comment on this docket between Nov 6, 2015 and Nov 6, 2015. 39 other organizations filed here. The comment window closed 3926d ago.

What Information Technology Industry Council filed (1)

Nov 6, 2015· Information Technology Industry Council (ITI)· USTR-2015-0014-0055

October 28, 2015 USTR Request for Public Comments to Compile the National Trade Estimate Report (NTE) on Foreign Trade Barriers The Information Technology Industry Council (ITI) is pleased to respond to the Trade Policy Staff Committee's (TPSC) request that interested persons submit comments to assist in identifying significant barriers to U.S. exports of goods, services, and U.S. foreign direct investment for inclusion in the NTE. ITI's comments cover a wide range of measures that impact trade in goods and services in the information and communications technology sector. Many of our comments focus on governments employing forced localization measures, also known as "localization barriers to trade." ITI's members and companies of all sizes in all sectors have experienced a significant increase in the use of these measures across the globe. This dynamic has forced them to make costly adjustments to their operations on the ground, regionally or globally, in order to comply with these measures. Data localization requirements in particular are in vogue in many large emerging markets. While our comments include information on data localization requirements in six different markets (China, Indonesia, Nigeria, Russia, Turkey, and Vietnam), it is possible that additional governments will consider or implement similar requirements by the time the 2016 NTE is published. ITI is greatly concerned about the impact of such digital protectionism on international trade and investment, innovation, and the ability of people and businesses all over the world to benefit from free and open flows of information and data through the Internet and Internet-based technologies. With eliminating localization barriers to trade now a prominent negotiating objective in the Bipartisan Trade Priorities and Accountability Act of 2015, ITI requests that the 2016 NTE place specific emphasis on the increase in these barriers around the globe. Ideally, this emphasis would be placed in a separate section to underscore the seriousness of this disturbing trend. ITI also underscores the importance of promoting greater regulatory coherence in priority foreign markets. Regulations developed within silos without input from other ministries and a wide range of foreign and domestic stakeholders tend to produce inefficient outcomes that distort trade and investment. The U.S. government's ongoing efforts to ensure that governments coordinate regulatory work internally, assess the trade and investment impacts of regulation, and conduct open and transparent public consultation is of significant benefit to technology firms, whose products and services are often subject to wide array of overlapping and onerous regulation. ITI requests that the NTE include a section that examines how governments in priority markets are performing with respect to regulatory coherence, perhaps using the work of the OECD and APEC on good regulatory practices as benchmarks. We look forward to engaging further with the TPSC staff on the issues contained in our comments and appreciate the opportunity to submit comments. See attached file.

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