The U.S. Negotiating Objectives for a Trade Agreement with the EU

POSITION PAPER | FOREIGN TRADE

The U.S. Negotiating Objectives for a Trade Agreement with the EU

12 March 2019 Background On 11 January 2019, the Office of the United States Trade Representative (USTR) presented its specific negotiating objectives for a trade agreement with the EU 1. The USTR thereby fulfilled his obligations under the Bipartisan Congressional Trade Priorities and Accountability Act of 2015. The negotiating objectives for individual agreements have to be in line with the overall trade negotiating objectives enshrined in that law. The U.S. Congress had 30 days to comment on the negotiating objectives but did not have to confirm them officially. Thus the United States would have been able to begin official negotiations with the EU on 11 February 2019 at the earliest. In November 2018, the USTR had called on stakeholders to submit written proposals, and in December 2018, a public hearing took place.

The BDI assessment of the USTR negotiating objectives is to be read as complementary to the BDI position paper of 9 January 2019 titled “Negotiations with the United States on a Transatlantic Trade Agreement.”2

General Remarks ▪

The overall negotiating objective of the United States is to improve the U.S. trade balance and reduce the trade deficit with the EU (and not, as for past negotiations, to expand bilateral trade).

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Unlike in the joint Juncker-Trump statement released at the end of July 2018, the automobile sector is not explicitly excluded, neither with regard to tariffs on industrial goods nor with regard to provisions on regulatory cooperation and the elimination of non-tariff trade barriers.

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The scope of the agenda is very broad – much broader than that of the two EU negotiating mandates. The negotiating objectives cover all issues usually covered by modern free trade agreements (FTAs).

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The objectives provide for a step-by-step approach to the negotiations, albeit in close coordination with Congress (“We may seek to pursue negotiations with the EU in stages, as appropriate, but we will only do so based on consultations with Congress.”). Such an approach would be compatible with the EU strategy. To date, the European Commission has emphasized that the negotiations

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Updated translation of BDI, Die US-Verhandlungsziele für ein Handelsabkommen mit der EU, März 2019, 2BDI, Negotiations with the United States on a Transatlantic Trade Agreement, 9.1.2019.

Dr. Stormy-Annika Mildner, Julia Howald, Valerie Ross | Außenwirtschaftspolitik | www.bdi.eu

The U.S. Negotiating Objectives for a Trade Agreement with the EU

should not be based on the principle of a “single undertaking,” which means no single comprehensive agreement is to be negotiated.

Summary of the Negotiating Objectives Trade in Goods (Industrial and Agricultural Goods) ▪

In contrast with the EU, the United States wants to negotiate market access not only for industrial goods but also for agricultural goods. Both EU tariffs and non-tariff barriers are to be dismantled.

Unnecessary differences in regulations on agricultural goods are to be eliminated, where possible, through regulatory cooperation.

Sanitary and Phytosanitary Measures (SPS) ▪

SPS commitments should be binding and build on WTO obligations. The USTR stresses that the scientific principle and risk analysis are to be thereby taken into account. But each side should be able to maintain the level of protection that it deems appropriate.

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The negotiation partners are to agree upon new rules that encourage a stricter implementation of international standards.

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The United States wants to oblige the EU to make draft regulations available to international stakeholders and enable the latter to comment on those regulations. During the TTIP negotiations, the United States had called upon the EU to adopt the U.S. “notice and comment” system.

Customs and Trade Facilitation ▪

Agreements should build on the relevant WTO treaties. The transparency of all laws and regulations should be enhanced by publishing those documents on the Internet and providing information about points of contact to which traders can address questions.

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Digital customs clearance systems should be promoted in general and eventually be integrated into businesses processes.

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Customs procedures should be more closely harmonized.

Rules of Origin ▪

Rules of origin should create incentives for production on the territory of FTA partners, “specifically in the United States.”

Technical Barriers to Trade (TBTs) ▪

Here, too, the United States wants to oblige the EU to make draft regulations available to international stakeholders and enable the latter to comment on those regulations.

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The national treatment of conformity assessment bodies should be ensured without any limitations.

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A TBT Chapter Committee should be established to discuss, among other things, regulatory cooperation and the implementation of good regulatory practices.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

Good Regulatory Practices as well as Transparency, Publication, and Administrative Measures ▪

Here, too, the stated objective is to increase transparency in setting of new regulations and create better opportunities for commenting on draft regulations.

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The United States would like to promote the use of impact assessments in the drawing up of regulations.

Trade in Services ▪

Access for U.S. services to the EU market should be improved not only through regulations that apply to all services sectors (e.g., prohibiting discrimination against foreign suppliers) but also through sector-specific regulations. In the case of any exceptions, a negative list approach should be adopted with the narrowest possible exceptions to ensure the least possible impact on U.S. suppliers.

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For the United States, flexibility for exceptions from market access is be guaranteed, including in relation to maritime transport. This suggests that the United States wants to adhere to the Jones Act, which requires all ships transporting goods between U.S. ports to have been built in the United States, to be owned by U.S. citizens, and to be operated by U.S. citizens.

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The telecommunications and financial services sectors are singled out. In the case of financial services, it is to be ensured that the EU does not introduce any measures that restrict cross-border data flows or require local computing facilities to be used or installed.

Digital Trade and Cross-border Data Flows ▪

Both sides should commit not to impose customs duties on digital goods (software, music, e-books etc.).

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The EU is not to introduce any measures that restrict cross-border data flows or require local computing facilities to be used or installed.

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Non-discriminatory treatment of digital products transmitted electronically is to be ensured. The USTR wants guarantees that these products will not be subject to discrimination based on the territory on which the product was produced.

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Moreover, rules are to be agreed upon that will prevent governments from being able to order the disclosure of computer source codes or algorithms.

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The USTR calls for the establishment of rules that limit the civil liability (excluding copyright) of online platforms for third-party content, subject to the EU’s right to take measures for legitimate purposes (such as protecting public morals).

Investment and Investment Protection ▪

The negotiating objectives contain very cautious comments on investment protection: important rights of U.S. investors in the EU are to be secured, while EU investors are not to be granted further-reaching rights than domestic investors.

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EU barriers to U.S. investments are to be reduced or eliminated in all sectors.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

Intellectual Property ▪

The European system of geographical designations of origin is rejected.

Pharmaceuticals and Medical Devices ▪

Full market access for U.S. products is to be secured.

State-owned Enterprises (SOEs) and Subsidies ▪

States should continue to be able to support SOEs that provide public services for the domestic market.

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Subsidy related disciplinary measures should go beyond those provided by the WTO Agreement on Subsidies and Countervailing Measures (SCM Agreement).

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Agreements between the EU and the United States should build on the transparency principles of the SCM Agreement.

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SOEs should not cause harm to U.S. industry either through the awarding of subsidies or through subsidized investments by SOEs.

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Subsidy-related issues affecting both sides should be discussed via a consultative mechanism.

Competition Policy ▪

Rules are to be maintained that prohibit anti-competition behavior and protect consumers from deceptive commercial acts and practices; at the same time, it is to be ensured that these rules are transparent.

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Basic rules are to be established and confirmed for procedural fairness in the enforcement of competition law. This includes guaranteeing non-discriminatory treatment of the other party, allowing legal representation, recognizing privileged communications, protecting confidential and privileged information and communications, ensuring access to information required to prepare an adequate defense, allowing the opportunity to submit evidence and cross-examine witnesses, providing for rulings by impartial administrative authorities or courts, ensuring that revenues or profits are taken into account in the calculation of a fine relating to the territory or commerce of the party to the agreement.

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Remedial measures related to anti-competition behavior outside the territory of the party are to be limited to situations in which there is an appropriate connection to the party’s territory.

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Cooperation between the relevant authorities with regard to the enforcement of competition and consumer protection, including investigative assistance, notification, consultation, and exchange of information, is to be promoted.

Labor and Environmental Standards ▪

The EU and its Member States are to be obliged to adopt and implement the core labor standards of the ILO Declaration and to have laws on acceptable working conditions (with respect to minimum wages, working hours, safety at the workplace etc.).

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The EU and its Member States are to be obliged to adopt and implement selected multilateral environmental agreements that the EU and the United States have joined.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

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The obligations regarding labor and environmental standards are to be enforceable and subject to the dispute settlement mechanism of the agreement.

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Stakeholder participation should be made possible, including through public advisory committees.

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An Environmental Committee to oversee the implementation of the chapter on environment should be established.

Anti-Corruption ▪

The United States demands that the EU and its Member States fight and sanction corruption in all areas. Corruption at the level of government should be punishable, and in the public sector high ethical standards in general should be ensured through codes of conduct and other tools. The public should be more actively involved in fighting corruption too. In the private sector, accounting should be designed to enable the detection and tracing of corrupt payments. Moreover, the deduction of corrupt payments for tax purposes is to be prevented.

Trade Remedies ▪

The United States should continue to be in a position to enforce rigorously its trade laws (including legislation on antidumping, countervailing duties, and safeguards).

Government Procurement ▪

The access of U.S. enterprises to the EU market (with regard both to contracts awarded by the EU itself and to the procurement markets of its Member States) should be improved.

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Reciprocity in market access for U.S. goods, services, and suppliers in the EU, including in the EU Members States, is to be guaranteed.

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Fair, transparent, predictable, and non-discriminatory rules are to be developed for the public procurement system of the EU and its Member States in order to ensure that:

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Information on tenders is made available in a timely manner;

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Sufficient time exists for bidders to obtain tender documents and submit bids;

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Fair procedures are used in the procurement system;

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Contracts are awarded solely on the basis of evaluation criteria specified in the tender notices and documents; and

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An impartial administrative or judicial review body exists to deal with problems and complaints.

Sub-federal coverage (that is, state and local governments) is to be excluded from the pledges or commitments discussed during the negotiations. Various domestic preferential purchasing programs are to be maintained, including: -

Preferential programs or exclusion rules for small businesses, women, minority-owned businesses, and disabled war veterans;

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“Buy America” rules on state assistance for projects at the state and local levels, transport services, and so forth; and

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Key procurement by the Department of Defense.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

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Furthermore, far-reaching exceptions are to be maintained in the areas of national security, measures to protect public morals, order, and safety, the protection of human, animal, and plant life as well as the protection of intellectual property.

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In addition, it should be possible to include criteria related to labor law, the environment, and other areas in the contracting requirements.

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Finally, requirements should be introduced that promote transparency in procurement statistics.

Small and Medium-sized Enterprises (SMEs) ▪

The parties should commit themselves to improving information for SMEs on exporting to each other’s markets.

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An SME Committee composed of government representatives who take into account the interests of SMEs during the implementation of the agreement is to be established.

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The U.S.-EU SME Workshops, which were established under the Transatlantic Economic Council, are to be incorporated into a bilateral SME dialogue under the agreement in which industry, NGOs, and other stakeholders can exchange views and which will serve as a source of information for the SME Committee.

Dispute Settlement ▪

An effective and transparent dispute settlement mechanism is to be established. Complaints are to be made publicly available and hearings are to be open to the public. Rulings are to be made publicly available, too. Non-governmental entities are to have the right to request making written submissions.

General Provisions ▪

Mechanisms for terminating the agreement under appropriate circumstances should be provided.

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The United States should be able to respond appropriately if the EU negotiates an FTA with a nonmarket country.

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Politically motivated trade discrimination against Israel is to be prevented.

Currency ▪

It should be ensured that the EU and its Member States avoid manipulating exchange rates.

Assessment In general, a comprehensive approach to trade agreements is positive. Through multistage negotiations, the U.S. negotiating objectives and the EU mandates can be aligned.

However, in some areas of particular importance to the EU (especially regarding government procurement), the U.S. objectives are anything but ambitious and are unlikely to satisfy either industry or the European Commission. In all areas, market liberalization must be based on reciprocity. The formulation

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

of the USTR negotiating objectives is conspicuously one-sided, which will make it difficult for the EU to adopt an accommodating stance.

The objective to discuss the agricultural sector during the negotiations, including SPS standards, harbors the potential for considerable conflict with the EU. According to the Commission, there is no consensus among the EU Member States on discussing these issues, which proved very tough to tackle in the TTIP negotiations and which Member States like France reject outright.3 Another potential major source of conflict is the rejection of the European system of geographical indications of origin for food products.

The objective to be able to respond appropriately if the EU negotiates an FTA with a non-market economy is unacceptable. This objective is also found in the United States-Mexico-Canada Agreement (USMCA).4 German industry recommends the elimination of all industrial goods tariffs, including tariffs on automotive and automotive parts. An industrial goods agreement that excludes trade in automotive would be unacceptable. Transition periods – if needed – should be short.

Detailed Assessment of Selected Areas

Trade in Goods For German industry, it is important not only that access for U.S. exporters to the EU market is improved but that industrial goods tariffs are eliminated by both sides. German industry recommends the removal of all industrial goods tariffs. Transition periods – if needed – should be short.

BDI also supports the objective of eliminating non-tariff trade barriers. The goal of regulatory cooperation should be the simplification of procedures, while maintaining the level of protection.

Customs Facilitation Stepping up the digitization of customs procedures under a possible agreement is in the interest of German industry. This approach could give new impetus to the digitization of the Union Customs Code (UCC). Moreover, pressure within the Union to apply the UCC in a unified way throughout Europe would grow if an agreement were to be reached with the United States in this area.

Technical Barriers to Trade The transatlantic relationship demands not only the elimination of all tariffs but also the harmonization of technical market access conditions, including in the area of product conformity assessment .

This would benefit, in particular, SMEs, for which the various requirements pose a huge obstacle.

In order to ensure that regulatory cooperation is as binding as possible, the EU and the United States should establish an institutional framework for transatlantic regulatory cooperation as well as a clear agenda and a fixed timetable. Otherwise, there is a danger that regulatory cooperation

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Beyond this, the EU is seeking to reach an agreement with the United States on the import of non-hormone treated beef. To accommodate the position of the United States, Commission President Juncker promised in summer 2018 that the EU would import more soya and LNG from the United States.

4 The following was agreed in the USMCA: If one of the three countries negotiates an FTA with a country that is regarded by one of the parties to be a non-market economy or with which none of the USMCA countries currently has an FTA, consultations are to be held. On being presented the text of the FTA, the other USMCA countries have the right to leave the USMCA. The remaining USMCA parties would then negotiate a bilateral agreement. This can be seen as a signal that the United States would punish an FTA concluded by Canada or Mexico with China, for example.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

will fail to yield satisfactory results, as has been the case under the Transatlantic Economic Council.

The negotiating parties should not exclude any sector from regulatory cooperation .

The objective of national treatment of conformity assessment procedures should be bilateral mutual recognition of product inspections and certificates of the inspection bodies of both parties to the agreement. To this end, the recognition of conformity assessments should take place in two stages.

On one hand, bilateral mutual recognition of product inspections and certificates of inspection bodies in the EU and the United States must be achieved, for which the prerequisite is the authorization or accreditation of the inspection bodies in the economic area of each party. In the long-term, the parties to the agreement should make more use of the existing international systems of the International Laboratory Accreditation Cooperation and the International Accreditation Forum, which are not only coherent accreditation systems for conformity assessments but also laboratories and inspection bodies. On the other hand, mutual recognition of test and inspection results of the inspection bodies within the economic area must be clearly regulated.

The inclusion of all affected interest groups in the drafting of regulation would help ensure that all participants are better informed. Moreover, all affected groups should have the opportunity to comment or adopt a position on published draft legal provisions.

Rules of Origin Trade agreements must be of use to industry. Very strict and complicated rules of origin lead to low usage rates. For this reason, BDI recommends simple and liberal rules of origin as well as a return to proof of origin provided by the approved exporter. From BDI’s point of view, cross-industry rules are key to increasing the usage rates of FTAs and simplifying market access, especially for SMEs. Such an approach does not exclude sector-specific regulation.

Digital Trade and Cross-border Data Flows Smooth cross-border data flows are of central importance for the German and European digital economy. BDI believes that the transnational access, transfer, and storage of data must be fundamentally guaranteed in trade agreements. At the same time, a high level of data protection is a basic prerequisite for digital trade. Trade agreements offer an opportunity to export the high data protection standards of the EU. They make it possible to commit trade partners to an adequate level of data protection. European provisions on data protection – for example, the EU’s General Data Protection Regulation – should be neither undermined nor circumvented by trade agreements.

State-enforced restrictions with regard to the localization of data and ICT infrastructure should be prohibited. However, exceptions to data and ICT infrastructure localization prohibitions aimed at protecting privacy and national security must be safeguarded in order to ensure that the EU’s General Data Protection Regulation is neither underminded nor circumvented by such a trade agreement.

In narrowly defined, non-arbitrary, non-discriminatory, and transparent exceptions, the dispensing with a free data exchange should be provided for on a case-by-case basis.

Pharmaceuticals and Medical Devices The opening of markets in the area of pharmaceuticals and medical devices must be based on reciprocity as well. German industry regards the U.S. negotiating objectives as too one-sided in this sector.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

Building on the progress made during the TTIP negotiations, the mutual recognition agreement on good manufacturing practice inspections of pharmaceutical manufacturers, concluded by the U.S. Food and Drug Administration and the European Medicines Agency, entered into force late 2017.

In the coming years, this agreement could be expanded to include inspections of manufacturers of products such as vaccinations for human beings and medication for animals ; indeed, it already provides for an expansion to other product groups and even sets a precise timetable. Expediting the process and expanding to include still other products would be a welcome development. Another area already being discussed by the EU and United States is medical devices. We welcome the idea of mutual recognition of reports on inspections of medical device manufacturers that conform with the regulatory requirements of both systems.

State-owned Enterprises (SOEs) The U.S. intention to establish a stricter subsidy regime vis-à-vis SOEs than is foreseen at the WTO level and to prevent SOEs being granted excessive subsidies is positive. What is unclear, however, is the remark that no harm should be thereby caused to the United States. Moreover, the following statement of intent is vague: “Seek to develop disciplines that address the creation or maintenance of capacity inconsistent with market principles.” This general comment is no substitute for a strict government aid regime such as that of the EU. While in the past year, the EU and the United States have agreed to eliminate subsidies, the text of the agreement fails to explain how Washington wants to achieve that goal. Since subsidy and funding programs are not fully controlled centrally in the United States but rather at the federal state level in many cases, it is currently almost impossible to determine how high subsidies are overall.

Competition Policy The United States is seeking to ensure that principles of procedural fairness – for which basic rules are also to be included in the agreement with the EU – underpin a ‘Multilateral Framework on Procedure’. This document would oblige the participating competition authorities to follow fundamental due process. It is currently doubtful that the EU will participate in that framework. Germany and the EU are skeptical about some of the contents of the accord and, in particular, are opposed to a new authority that would promote the dominant position of the United States. However, the competition authorities should agree to shared basic principles such as transparent and fair decision-making process, to principles such as non-discrimination, transparency, rapidity of procedure, confidentiality, conflict of interests’ resolution, proper notification, opportunity of defense, access to legal advice, and judicial review.

At the same time, it must be ensured that in the exchange of information, confidential data and trade secrets do not end up in the possession of the other authority – or do so only under extremely strict conditions.

Furthermore, the United States has long practiced the extraterritorial application of U.S. antitrust law.

This practice is based on the so-called effects doctrine, which has now been implemented almost everywhere in the world, but which is subject to certain restrictions under international law. It is unclear to what extent it is planned to further limit remedial measures (with regard to the violation of antitrust or competition law or in the case of mergers) beyond the already existing limits on the effects doctrine under international law. In the upcoming negotiations, care should be taken to ensure that the extraterritorial application of U.S. antitrust law is further restricted in the way described above and under no circumstances further expanded.

As regards access to information, it should be ensured that no requirements that go beyond the provisions of the EU – for example, pre-trial discovery under U.S. law – are introduced in Europe. As cases in the United States have shown, this would lead to a huge cost burden for European companies in 9

The U.S. Negotiating Objectives for a Trade Agreement with the EU

antitrust proceedings and increase the pressure to settle irrespective of the substance and outcome of the suit.

Labor and Environmental Standards The EU shares the approach of the United States to include binding provisions on sustainability in comprehensive FTAs in order to implement and enforce labor and environmental standards. BDI supports ensuring that comprehensive agreements contain such provisions, including binding and enforceable obligations and the involvement of civil society in monitoring and implementation. Corresponding rules were included in the EU negotiating mandate for TTIP. But there is no chapter on sustainability in the European Commission draft mandates of 18 January 2019 for negotiations between the EU and the United States on the elimination of tariffs on industrial goods and conformity assessments. These drafts are based on the agreements reached by U.S. President Trump and European Commission President Juncker in summer 2018, which aimed at politically feasible negotiation areas. Although both sides are known internationally for maintaining very high sustainability standards, the fundamental differences between the United States and the EU in this area are likely to prove difficult to overcome in the foreseeable future. For example, France is insisting that all parties to an EU FTA must implement the Paris climate accord, from which U.S. President Trump has withdrawn. Moreover, the United States has not ratified all core labor standards of the ILO .

Ratification would require comprehensive amendments to U.S. law at the federal and sub -federal level, and the U.S. negotiating objectives do not provide for such steps to be taken.

Anti-corruption To promote cross-border standards in the fight against corruption, anti-corruption provisions of international agreements concluded by the OECD and the UN should be taken into account beyond those of the U.S. negotiating objectives. This would encourage the global harmonization of the fight against corruption, whereby internationally active companies and other players would have more legal clarity on how to comply with anti-corruption rules. Moreover, it would also facilitate the implementation of voluntary preventive measures in companies.

In addition, the jurisdiction of the state responsible for the prosecution of a corruption offense should be regulated. In cases in which the jurisdiction of several states is concerned, the matter of jurisdiction should be decided in a procedure between the respective authorities of those states prior to prosecution in order to avoid parallel proceedings and avert the danger of different rulings applying to the same case.

Trade Remedies It goes without saying that both the United States and the EU should be entitled to deploy trade remedies in line with WTO rules.

In its negotiating objectives, the United States asserts that it must remain able to enforce rigorously its trade laws. But it is unclear if this means the continuation of the 232 measures against the EU .

U.S. imports of steel, aluminum, and automotives and auto parts from the EU do not endanger the national security of the United States. Therefore, the United States should rapidly and unconditionally remove the tariffs imposed on steel and aluminum in summer 2018. As long as it does not do so, the EU rebalancing measures should remain in force and the EU should push ahead with the dispute settlement procedure at the WTO. Moreover, the United States should refrain from imposing tariffs on automotives and auto parts.

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

Government Procurement The U.S. objectives are not very far-reaching and seem to a large extent unbalanced. A cause of extreme dissatisfaction for German industry is that the U.S. negotiating objectives: ▪

demand, on the one hand, improved access for U.S. companies to EU procurement markets, which are already wide open at all levels; and

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appear to seek, on the other hand, that the commitments to be negotiated fully exclude crucial issues such as access to the sub-federal markets of the United States while continuing to cement the highly problematic “Buy America” rules (including the Berry Amendment), which are hugely discriminatory against foreigners.

The United States appears to be once again insisting on the unbalanced and thus unacceptable positions that it adopted during the failed TTIP negotiations – namely, the exclusion of the subcentral markets and the continuation of the broad-based “Buy America” rules. From the point of view of Germany industry, this is unacceptable.

SMEs The approach and working structure adopted in the negotiating objectives are to be supported. To achieve robust results, it will be necessary to name relevant players for w orkshops and make suitable provision for the involvement of NGOs. In all their activities and in the selection of representatives, the EU and the United States should refer not to the current EU definition of SMEs but rather should also include export-oriented companies with up to 1,000 employees.

Currency It is incomprehensible why the United States wants to discuss exchange rate manipulation with the EU. For some time now, the IMF has been publishing, on behalf of the G20, its so-called External Sector Reports, in which to date neither the Eurozone nor other EU members have been berated .

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The U.S. Negotiating Objectives for a Trade Agreement with the EU

Impressum Bundesverband der Deutschen Industrie e.V. (BDI) Breite StraĂ&#x;e 29, 10178 Berlin www.bdi.eu Tel.: +49 30 2028-0 Editors Dr. Stormy-Annika Mildner Tel.: +49 30 2028-1562 s.mildner@bdi.eu Julia Howald Tel.: +49 30 2028-1483 j.howald@bdi.eu Valerie Ross Tel.: +49 30 2028-1623 v.ross@bdi.eu As of: Mai 2019 BDI document number: D 1034

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