This communication constitutes the response of the Joint Industry Group ("JIG") to the invitation for public comments issued by the Trade Policy Staff Committee (66 Fed. Reg. 22,627 May 4, 2001) in relation to the Committee's efforts to develop product-specific rules of origin for the Free Trade Area of the Americas (FTAA), the U.S.-Chile Free Trade Agreement (Chile FTA), and the U.S.-Singapore Free Trade Agreement (Singapore FTA). The JIG reserves the right to supplement its comments as appropriate.

JIG is a coalition of more than 160 companies, trade associations, professionals and businesses actively involved in international trade. We both examine and reflect the concerns of the business community relative to current and proposed international trade-related policies, actions, legislation, and regulations. We undertake to improve policies and procedures through dialogue with government agencies and the Congress. The Joint Industry Group represents over $350 billion in trade.

The JIG wishes to register a cautionary note as the United States pursues negotiations on preferential rules of origin with Singapore, Chile and in the FTAA context, in addition to the preferential rules of origin already in place under other regional trade agreements, such as the NAFTA and U.S-Israel Free Trade Area Agreement, and under statutory arrangements such as the Caribbean Basin Initiative and the Africa Growth and Opportunity Act. Although the efforts of the United States Government to expand trade opportunities are welcome, the potential increase in the number and variety of preferential rules of origin is not. The diversity of such rules is neither in the best interests of traders, who must look at the specific rules under each agreement or program for each transaction, nor of the Customs Service, which will have increasing difficulty administering and enforcing these rules.

Accordingly, the JIG urges the Committee, in providing interagency input to the United States Trade Representative in these negotiations, to take into account (a) the impact on the U.S. trading community of multiple and divergent sets of preferential rules of origin and (b) the advice of the operational units within the U.S. Customs Service to ensure that whatever rules of origin are negotiated can be implemented effectively.

Material Copyright © 2001 Joint Industry Group