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JUNE 2018

ISSUE NO. 245

Quality Rules in India: Trade,


Technical Regulations and Consumer Protection
PHILIP GRINSTED, ALOK KESARI, KHUSHWANT SINGH

ABSTRACT India's competitiveness in manufacturing and the success of 'Make in India' depend
on its ability to produce high-quality products and services. Product quality is important for
human health and consumer safety, as well as for protecting the climate and the environment.
One way of ensuring that products and services meet certain standards is through technical
regulations with mandatory compliance. However, technical regulations also have the potential
to impede the cross-border flow of goods and services if they become barriers to trade. Until
recently, India had few technical regulations, but it is now set to change this. This brief analyses
sectoral patterns and trends in India's technical regulation by looking at mandatory certification
schemes and notifications to the Technical Barriers to Trade Committee of the World Trade
Organisation. Four measures are identified, which could support goals such as consumer
protection while also improving India's competitiveness and its integration into international
trade.

INTRODUCTION

Indian Prime Minister Narendra Modi was long-term regulator y trends have been
applauded at the 2018 World Economic Forum neglected. Currently, India is strengthening its
for speaking in favour of globalisation and regulatory framework for products by making
publicly positioning himself against protect- compliance mandatory for a growing number of
1
ionism. Yet, tari rates were increased on a technical standards. Until now, India has had
range of products in the 2018 19 public budget, relatively few technical regulations. However,
creating a concern that Indian policy did not recently enacted policies have extended the
2
echo Modi's words in Davos. While higher in uence of Indian ministries on technical
tari s attract immediate media attention, the regulations. Technical regulations such as

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

mandatory safety standards for gas appliances improving India's competitiveness and its
are important because they are one way of integration into international trade.
ensuring that products and services do not
harm people. Similar regulations can be TECHNICAL REGULATIONS IN INDIA
important for consumer safety and to protect
the environment. Standards guide consumers to make informed
However, mandatory technical regulations decisions and gauge key quality aspects of
tend to increase costs for companies. e products, such as safety, performance or
necessity of collecting information about environmental friendliness. Standards play an
regulations, conducting compliance, product important role in improving the e ciency of
testing and certi cation, and possibly even production and facilitating international trade,
changing production processes all add up. Both for example, by ensuring the compatibility of
domestic and foreign companies incur these products. Companies in many countries thus
costs, and the latter face them more often in the engage proactively in the development of
form of technical barriers to trade (TBT). TBTs standards. Compliance to standards is usually
are measures that can regulate markets and voluntary, but governments may take necessary
protect consumers, but they can also be used to measures in the public interest.
make imports and exports more di cult to According to the WTO, legitimate objectives
protect domestic markets. include national security, the prevention of
TBTs are not always intentional; often, they deceptive practices, protection of human health
are the result of regulatory di erences and or safety, animal or plant life or health, and the
contradictions. is makes it crucial for environment (Article 2.2, TBT Agreement). By
regulators to weigh the necessity of new or making compliance to standards mandatory,
modi ed regulations to ensure that unintended these standards become technical regulations.
TBTs do not arise. is will facilitate the ease of ese regulations may also include requirements
doing business in India and the competitiveness related to packaging, marking and labelling, and
of the domestic industry, as well as the success procedures for demonstrating compliance, e.g.
of the 'Make in India' initiative, which aims to conformity assessment procedures (testing,
transform India into a global design-and- inspection and certi cation).
manufacturing hub. In India, the government primarily leads
Sectoral patterns and trends in India's standardisation with the Bureau of Indian
technical regulation are outlined in this brief by Standards (BIS), recognised as the national
looking at the emergence of India's mandatory standards body. By 2017, more than 19,000
certi cation schemes and data from the TBT voluntary Indian standards had been developed,
Committee of the World Trade Organisation of which only 137 product standards are
(WTO). ese insights are used to identify the mandatory. e BIS operates several schemes
possible challenges Indi a may face in that de ne the compliance procedure. e BIS
international trade and competitiveness in Mandatory Product Certi cation Scheme
manufacturing. Four measures are then applies for 116 products, for which it grants
identi ed, which could support consumer safety licences after the successful completion of
and environmental protection while also production-site inspections and sample testing.

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

Another 50 products fall under the Compulsory are related to food safety, cement, cylinders and
Registration Scheme, which requires valves, and household electrical goods (nine
manufactures to be registered with the BIS after percent each). Up until 2012, cement and
their products have been tested by a BIS- household electronics goods, such as electric
recognised laboratory. stoves, irons and room heaters, had been the
On 12 October 2017, the Bureau of Indian sectors with the most regulated products (see
Standards Act, 2016 came into force, replacing graph). Household electronic goods are
the previous 1986 law. Besides other changes, products for which people understandably
the new BIS Act makes it easier for the prefer a high degree of product safety and
government to notify or declare products, corresponding enforcement. e same holds
systems and services for which compliance to true for the regulation of cement and the role
speci ed standards are mandatory. is this regulation plays in safety for construction.
noti cation of technical regulations by Indian ere have not been any complaints from other
ministries is often called Quality Control countries at the WTO that the introduction of
Orders. According to Article 16(1) of the BIS such measures in India would violate a free
Act, 2016, the central government can do so in trading system. In this context, however, the
public interest or for the protection of human, volume of imported cement in India has
a n i m a l or pl a nt he a l t h , s a fe t y o f t he constantly been at a low level.
environment, or prevention of unfair trade Due to its use in the defence industry, steel is
practices, or national security. Several of strategic relevance for governments. e
ministries have already started examining the current trade dispute between the US and China
need for new technical regulations or have had its starting point with steel tari s. Looking
begun product noti cation. at quality, however, it would seem reasonable to
As the prevention of 'unfair trade practices' have stronger regulation to ensure safe
is mentioned in the Act, some recent Quality construction and industrial goods. e
Control Orders make use of this possibility. A numerous technical regulations for steel in India
noti cation by the Department of Heavy have been a matter of dispute at the WTO. In
Industry on 13 September 2017 listed ve heavy 2009, China, the European Union (EU), Japan
electrical industr y items for which the and a few other countries raised a Speci c Trade
Department of Commerce had suggested Concern at the TBT Committee, regarding
Quality Control Orders for trade purposes. India's Quality Control Order on mandatory
certi cation for steel products. e countries
PATTERNS AND TRENDS IN INDIA'S claimed a lack of har monisation with
TECHNICAL REGULATIONS SINCE THE international standards and that the regulation
EARLY 2000s was an unnecessary barrier to trade. Similarly,
e Stainless-Steel Products (Quality Control)
As of 1 March 2018, 146 products have been Order, 2015 was criticised by the EU for its
regulated in India through mandator y disproportionality and a lack of harmonisation
3
certi cation. Most of these products are either with international standards.
from the electronics and IT sector (27 percent) For some observers of India's quality
or steel (25 percent). Other regulated products landscape, the introduction of the 'Compulsory

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

Registration Scheme (CRS) for Electronic and IT was announced that further standards were to
Products' was seen as a turning point in the use become mandatory in the solar photovoltaic
of technical regulations. Launched in 2012, this sector, electrical components and electrical
scheme regulates products such as video games, motors.
wireless keyboards, mobile phones and laptops. Are these regulations for the bene t of
It was speculated that the introduction of this consumers, to protect indigenous industries, or
regulation was a response to India's growing both? Despite the depicted trends, it is di cult
trade de cit with China. In 2004, India had a to speculate on the reasoning behind each
small trade surplus of US$2 billion with China; regulation. Indian discourse on technical
by 2011, this had changed to a trade de cit of regulations provides some indications that
about US$40 billion, with Chinese electronics there is a focus on trade considerations. In 2016,
and IT products representing a substantial share the Government of India shortlisted 137
of the Indian imports. products for a technical regulation, rst phase.
e graph shows that, in India, there has e shortlist was based on four inputs: 1) 105
been an increase in not only the overall number product proposals from an Inter-Ministerial
of technical regulations but also the number of Committee on Non-Tari Measures; 2) a list of
sectors that are regulated. At the end of 2017, it 121 products, for which anti-dumping duties

Graph: Number of Products under Mandatory Certi cation in India (2003-18*)

180

160
Number of technical regulations (cumulative)

140
Solar photovoltaics
Steel
120
Electrical transformers
& Electrical motors
100

80 Automobile Electronics
Oil pressure stoves and IT
accessories

60
Medical equipment

Food safety
40
related products
Household electronics goods Cylinders,
20 valves
Cement
0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

New or amended mandatory certi cation for products since 2003.


* 2018 includes announced mandatory certi cation, which have not yet entered into force.
Source: Authors' calculations based on public data from the Bureau of Indian Standards 2018, www.bis.org.in/cert/ProdUnManCert.asp.

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

had been levied in the past ve years; 3) 100 operating in India, it became apparent that the
products with an Indian export interest; 4) 25 challenges of technical regulations include
sectors under the Make in India initiative.4 operational di culties. Among the issues
brought up were a lack of understanding on the
CHALLENGES implementation of technical regulations,
burdensome compliance procedures, and short
India has recently celebrated remarkable transition periods for new regulations.
improvements in the ease of doing business, Companies pointed to one recent case: the
indicating its willingness to remove bureaucratic introduction of new Indian energy-e ciency
hurdles. However, there is a tipping point when regulations for electric motors, which are used in
too many sometimes unnecessary technical a wide range of production facilities. e motor
regulations create red tape and in ate costs for regulations entered into force in January 2017
companies. Even though technical regulations and went into e ect in October 2017. Many
are neglected in the heavily cited World Bank companies argued that a 10-month period was
Index, they represent a real potential burden for insu cient because of the substantial technical
companies. changes and compliance procedures that were
In several industry roundtables held in 2017 required. Even after the government extended
and 2018 with German companies who operate the implementation by two months, companies
in India, the relevance of technical regulations claimed that a transition period of up to 24
was discussed in detail. ese roundtables took months would have been more appropriate.
place in the framework of the Indo-German ese examples show that companies have a
Working Group on Quality Infrastructure high interest in regulatory certainty and need an
between the German Federal Ministry for adequate planning horizon to make sound
Economic A airs and Energy and the Indian business decisions.
Ministry for Consumer A airs, Food and Public When regulations are introduced or changed,
Distribution. Within this bilateral Working companies face higher costs. e Indian
Group, Germany and India cooperate on government, too, incurs additional expenditures
standardisation, conformity assessment and when overseeing and enforcing a larger number
accreditation, and market surveillance to reduce of mandatory certi cations. Every rupee spent
TBTs and strengthen consumer protection. on unnecessary certi cation requirements is a
Repeated testing requirements due to non- rupee that cannot be spent on much-needed
acceptance of test reports in India are a regulations in other areas. For instance,
common concern for foreign companies. In one currently, there are almost no technical
of the roundtables, a German manufacturer of regulations for the safety of machinery or gas
agricultural machinery pointed out that the appliances, while there are regulations for
requirement to carry out additional test wireless keyboards. is raises the question of
procedures in India made it unviable to launch in whether such a product should take regulatory
the Indian market. e costs of the required priority over a product that is connected to
testing procedures would have exceeded the ammable gases.
potential pro ts for this manufacturer. Technical regulations on trade may have a
In further discussions with companies potentially negative e ect on India's own

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

economy. e goal to increase manufacturing's fostering the innovative capabilities of


share of GDP to 25 percent by 2025 and become companies, requires allowing companies to
a global or regional manufacturing hub depends develop their own ways to achieve goals such as
on the availability of imports. If companies face product safety, at least for low-risk products.
barriers in importing intermediate and capital In the highly regulated EU, it proved
goods, they are less likely to select India as an successful to refer to performance standards
5
export-processing location. is especially that outline functional requirements instead of
holds true for high value-added manufacturing prescribing speci c technological solutions.
with complex and long value chains.6 However, if European standards are there to facilitate
India embraces imports, it is likely to attract compliance with requirements de ned in
more foreign direct investments under the Make legislation (EU Directives), but their use
in India campaign. remains voluntar y. is so-called new
While India is populous, the comparatively approach of the EU even though more than
low domestic purchasing power still makes it 30 years old by now can help spur innovation
attractive for companies to tap foreign markets. because companies have the possibility to
India is aiming to reach a 3.5-percent share of develop their own technological solutions to
global trade by 2020, which will require a deeper ensure that the objectives of regulations are
integration into global value chains. e met.8
electronics and IT hardware industry is one Finally, technical regulations are inadequate
where the country has the potential to move tools to counter unfair trade practices of other
into higher value manufacturing.7 However, this countries, such as illegitimate export subsidies
sector relies heavily on products from multiple or import restrictions. ey are in exible and
countries. High import duties and technical create technological path dependencies for
re g u l a t i o n s , s u c h a s t h e C o m p u l s o r y companies, for example when making capital
Registration Scheme for Electronic and IT investments to set up a production process for a
Products, could become a potential hurdle for product based on an India-speci c standard. If
India in its attempts to diversify. the other country revokes unfair trade practices,
Despite their name, TBTs are not only about technical regulations cannot be taken back
trade. ey can a ect domestic rms as well as easily. Given that the WTO o ers mechanisms
foreign ones. Creating India-speci c technical to respond to unfair trade practices such as
regulations sets Indian companies on a separate countervailing duties, it may usually not be
technological path. is reduces the economies required to apply technical regulations for those
of scale for export-oriented Indian companies, means in the long run.
as both international and Indian speci cations
must be met. THE ROAD AHEAD
Regulating products by prescribing speci c
technical requirements may limit the innovative In closing the gap between products that are
capabilities of companies. Given today's fast- regulated and those that are not, it is important
paced technological changes, a technical to avoid the issues discussed above. e
standard made mandatory today might already following steps could help reach the goals of
be outdated tomorrow. Avoiding this, while also protecting the environment, the climate and the

6 ORF ISSUE BRIEF No. 245 • JUNE 2018


consumers, without compromising on the With the implementation experience,
achievements in the ease of doing business. policymakers can assess the extent to which
ey can also bene t the Indian economy and a regulation is able to meet its speci ed
contribute to initiatives such as Make in India. objective and recalibrate if needed. While
regulatory impact assessments sound like a
1. Develop an Indian Roadmap for good idea in theory, they might be quite
Implementing Good Regulatory cumbersome in practice, given the high
Practices9 complexity of most subject matters,
especially considering the e ects on foreign
ere is no single de nition of good trade. erefore, the contributions of sector
regulatory practices, but some common experts through systematically organised
principles have been developed to ensure stakeholder consultations is key. For the
that policy serves the public interest while stakeholder consultations to function
minimising the associated costs. Two properly, regulators must ensure high
practices are crucial as India works towards transparency of the process, availability of
stronger regulation of certain sectors: early and adequate information, and
regulator y impact assessments and inclusivity.
stakeholder consultations.10
2. Embrace International Standards and
Systematic regulatory impact assessments Certi cations
can be done before (ex-ante) and after (ex-
post) the introduction of a regulation. e economic bene ts of standards are well
Before introducing a new technical documented.11 ey increase compatibility,
regulation, the regulator must clearly de ne strengthen consumer trust and lead to
the policy objective, critically assess dissemination of knowledge. International
available options, conduct a needs standards take this one step further as they
assessment, and follow a risk-based represent a global consensus among leading
approach. Public-policy problems are often experts on a speci c issue. ey are, thus,
highly complex with multiple regulators codi ed 'best practices'. International
being concerned at the same time. It might standards allow companies to apply best
therefore be helpful to de ne a practical practices to their products, and they
roadmap to g uide polic y makers in enhance the e ciency of global value chains
conducting a cost-bene t analysis for new and facilitate market access.
regulations. is systematic approach
especially avoids unintended negative For instance, the adaption of international
e ects on the ease of doing business by standards to national speci cs may be
making potential impacts visible to necessar y in dealing with climatic
decision-makers. di erences in India . However, any
adaptations should be carefully considered
is kind of analysis should be repeated as small alterations in standards can
after a regulation has been introduced. require signi cant technical or procedural

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

changes, defeating the very purpose of the regulatory dialogue with strategic
standards. Indian experts should be more economic partners. is goes beyond high-
active in introducing points to consider in level political meetings, as regulatory gains
the development of international can be achieved only by engaging in a
standards, thereby making the standards dialogue on regulatory speci cs. One
better through universal applicability. example for this is the Indo-German
Working Group on Quality Infrastructure,
In the Indian Strategy for Standards in which the countries cooperate on
(INSS), the Indian government expresses standardisation, conformity assessment
its intention to promote and contribute to and accreditation, and market
developing international standards. is surveillance in close collaboration with
can strengthen the competitiveness of the industry to reduce TBTs. Such working
Indian industr y and support the groups provide a framework to identify
integration of India in global and regional challenges and opportunities to trade,
value chains. As outlined, duplicate testing coordinate the commenting of draft
and certi cation can signi cantly add to re g u l a t i o n s , a n d s h a re p o l i c y a n d
companies' costs. erefore, India should implementation experiences. By publishing
consider increasing the acceptance of sector-speci c studies and over view
international certi cations and test documents, for example on the quality
reports. International accreditation infrastructure landscape, such groups
arrangements already provide the basis for enhance the understanding of regulatory
the evaluation of whether the testing and processes.
certi cation bodies have the required
capabilities. 4. Use Online Platforms for Easy and Early
Access of Information on Technical
3. Engage in International Regulatory Regulations
Dialogue
e costs for collecting required
e growing interdependencies between information are a major factor for
countries lead to larger potential bene ts of companies when it comes to technical
international cooperation. e OECD regulations, which are complex and
counts increased trade and investment, frequently changing. So far, India does not
e ciency gains and cost savings for have a common portal where companies
governments, companies and citizens, as can access all relevant information on
well as improved safety and strengthened technical regulations. e Indian Standards
environmental sustainability as possible Portal is a rst step to enhancing awareness
gains from international regulator y of the Indian quality infrastructure system.
cooperation.12 is cooperation can occur in It provides information on regulations and
various forms, whether internationally or compliance procedures for companies. It
bilaterally, formally or informally. For will be bene cial if all information on new
India, there is potential in strengthening technical regulations including drafts

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Quality Rules in India: Trade, Technical Regulations and Consumer Protection

under public consultation were accessible with regard to the ease of doing business, trade,
in an easy and timely manner. and the competitiveness of the Indian industry.
B y developing an Indi an roadmap for
CONCLUSION implementing good regulatory practices,
embracing international standards and
Because of regulatory gaps in critical areas, it is certi cations, engaging in multilateral and
likely that India will see more regulation in the bilateral regulatory dialogue with key countries,
future. is makes it crucial to discuss the best and developing online platforms for easy and
way to regulate, as India starts to strengthen early access to information on technical
technical regulations with the goal of protecting regulations, both Make in India's goals and
consumers, the environment and climate. is global trade integration could come within
brief addressed some of the potential challenges closer reach.

ABOUT THE AUTHORS


Philip Grinsted specialises in public policy matters of trade and economic development in an
emerging markets context (especially China and India).
Alok Kesari specialises in market access conditions, regulatory landscape including standards,
technical regulations and compliance procedures.
Khushwant Singh has been working in international development for over 10 years, currently
focusing on Indo-German cooperation on quality infrastructure.
The authors work at the Deutsche Gesellschaft für Internationale Zusammenarbeit GmbH
(GIZ) the German Agency for International Cooperation supporting the Indo-German Working
Group on Quality Infrastructure, on behalf of the German Federal Ministry for Economic Affairs and
Energy in the Global Project Quality Infrastructure.

REFERENCES
1. Department of Commerce, Confederation of Indian Industry. Indian Standards Conclave 2016:
Challenge of Standards & Technical Regulations. 21 June 2016.

2. European Commission. Report from the Commission to the Council and the European Parliament
on Trade and Investment Barriers and Protectionist Trends. 20 June 2016. Accessed 15 May 2018.
http://trade.ec.europa.eu/doclib/docs/2016/june/tradoc_154665.pdf.

3. International Organisation for Standardisation (ISO). Economic bene ts of standards Volume 1.


2011. Accessed 15 May 2018. https://www.iso.org/publication/PUB100288.html.

4. Kathuria, Rajat et al. Mapping the future of high value manufacturing in India. Indian Council for
Research on International Economic Relations, Working Paper 285, July 2014. Accessed 15 May
2018. http://icrier.org/pdf/Working_Paper_285.pdf.

5. Kau mann, Céline and Nikolai Malyshev. International Regulatory Co-operation: e Menu of
Approaches. October 2015. Accessed 15 May 2018. http://e15initiative.org/wp-
content/uploads/2015/09/E15-Regulatory-Kau mann-and-Malyshev- nal.pdf.

ORF ISSUE BRIEF No. 245 • JUNE 2018 9


Quality Rules in India: Trade, Technical Regulations and Consumer Protection

6. Lovely, Mary E. Narendra Modi's Rise in Import Tari s Will Hurt India's Economy. Website of the
Peterson Institute for International Economics, 19 February 2018. Accessed 15 May 2018.
https://piie.com/commentary/op-eds/narendra-modis-rise-import-tari s-will-hurt-indias-
economy.

7. Organisation for Economic Co-operation and Development (OECD). International Regulatory Co-
operation and Trade: Understanding the Trade Costs of Regulatory Divergence and the Remedies.
2017.

8. OECD. How Imports Improve Productivity and Competitiveness. May 2010. Accessed 15 May
2018. http://www.oecd.org/trade/45293596.pdf.

9. Pelkmans, Jacques and Andrea Renda. Does EU regulation hinder or stimulate innovation? CEPS
Special Report, November 2014. Accessed 15 May 2018. https://www.ceps.eu/system/ les/
No%2096%20EU%20Legislation%20and%20Innovation.pdf.

10. Soni, Sunil and Rahul Kumar. Standards, Technical Regulations, Regulatory Framework, TBT-
Enquiry Point. In Role of Standards in International Trade: Challenges, Opportunities & Issues, 2016.

10 ORF ISSUE BRIEF No. 245 • JUNE 2018


Quality Rules in India: Trade, Technical Regulations and Consumer Protection

ENDNOTES
1. e authors would like to thank Dr. Kari Hiepko-Odermann for her valuable editorial comments.

2. For example, former vice-chairman of NITI Aayog: Arvind Panagariya, Return of protectionism:
Panagariya sounds alarm over Modi's new trade template for India, e Economic Times, 12 February
2018; Archana Chaudhary and Anirban Nag, Modi the protectionist: 30-year high import duty to
spur 'Make in India', Business Standard, 15 February 2018.

3. European Commission, Report from the Commission to the Council and the European Parliament
on Trade and Investment Barriers and Protectionist Trends, 20 June 2016, 13,
http://trade.ec.europa.eu/doclib/docs/2016/june/tradoc_154665.pdf.

4. Department of Commerce, Confederation of Indian Industry, Indian Standards Conclave 2016:


Challenge of Standards & Technical Regulations, 21 June 2016, 16.

5. See also Mary E. Lovely, Narendra Modi's Rise in Import Tari s Will Hurt India's Economy,
Peterson Institute for International Economics, 19 February 2018, https://piie.com/commentary/
op-eds/narendra-modis-rise-import-tari s-will-hurt-indias-economy.

6. OECD, How Imports Improve Productivity and Competitiveness, May 2010, http://www.oecd.org/
trade/45293596.pdf.

7. Rajat Kathuria et al., Mapping the future of high value manufacturing in India, Indian Council for
Research on International Economic Relations, Working Paper 285, July 2014, http://icrier.org/pdf/
Working_Paper_285.pdf.

8. Jacques Pelkmans and Andrea Renda, Does EU regulation hinder or stimulate innovation? CEPS
Special Report, November 2014, 12, https://www.ceps.eu/system/ les/No%2096%20EU%20
Legislation%20and%20Innovation.pdf.

9. Sunil Soni, Rahul Kumar, Standards, Technical Regulations, Regulatory Framework, TBT-Enquiry
Point, in Role of Standards in International Trade: Challenges, Opportunities & Issues, 2016, 86.

10. OECD, International Regulatory Co-operation and Trade: Understanding the Trade Costs of
Regulatory Divergence and the Remedies, 2017.

11. ISO, Economic bene ts of standards Volume 1, 2011, https://www.iso.org/publication/


PUB100288.html.

12. Céline Kau mann and Nikolai Malyshev, International Regulatory Co-operation: e Menu of
Approaches, October 2015, http://e15initiative.org/wp-content/uploads/2015/09/E15-
Regulatory-Kau mann-and-Malyshev- nal.pdf.

ORF ISSUE BRIEF No. 245 • JUNE 2018 11


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