in this area over the past five years. Most notably, these have involved U.S.-EU trade in agricultural products and the EU's Third Country Meat Directive and Beef Hormones Directive, outlined above. At a minimum, a transparent, multilateral framework through the TBT agreement now exists to address these procedures.

Coverage of Conformity Assessment

Technical regulations for oversight of testing and certification represent one of the fastest-growing segments of the industrialized nations' standards systems. Although most of the attention in trade policy discussions has addressed harmonization of differing national standards, expansion of national regulations on conformity to standards is where costs to manufacturers and exporters are likely to grow in the future. In the United States, as discussed in Chapter 3, the independent testing industry represented approximately $10 billion in revenue in 1993, with average annual growth rates of 13.5 percent from 1985 to 1992.29 The growth in third-party testing, moreover, stimulates the growth of added layers of complexity, reflected in public and private programs to accredit testing laboratories and government mechanisms for oversight of both laboratories and accreditors.

In the developing nations, continued industrialization and competition for access to global export markets will likely contribute to expansion in testing and accreditation systems over the next decade. Manufacturers in developed and industrializing nations will be subject to the full range of conformity assessment steps in export markets. Third-party firms that perform these tasks are already displacing the use of manufacturers' self-declarations of conformity in a number of sectors, most notably capital goods.30 Protocols at the international level to bring clarity and foster acceptance of these systems across national borders will be increasingly important to trade.

The Tokyo Round Standards Code applied the principles of national treatment and nondiscrimination only to product testing and certification programs. These principles require that the treatment of imports by a GATT member country be no less favorable than the treatment of domestic products or imports from other GATT members. Articles 5 through 9 of the Uruguay Round TBT agreement extend the basic obligation of national treatment and nondiscrimination to laboratory accreditation, recognition, and quality system registration programs, such as ISO 9000 registration requirements. Extension of the coverage in the Uruguay Round to all forms of conformity assessment, therefore, sets in place a framework that can serve to protect against their future use as barriers to trade.

Although progress was made in extending national treatment and nondiscrimination to a wider range of conformity assessment, the TBT agreement provides only a limited basis to encourage acceptance of the results of tests or laboratory accreditation across national borders. Article 6 of the TBT code



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