RESTRICTEDWORLD TRADE
ORGANIZATIONG/TBT/W/91
24 September 1998
(98-3688)
Committee on Technical Barriers to Trade Original:  English
EUROPEAN UNION:  COUNCIL DIRECTIVE 92/23/EEC RELATING TO TYRES FOR
MOTOR VEHICLES AND THEIR TRAILERS AND TO THEIR FITTING
Communication from Indonesia
1. The Mission of Indonesia wishes to refer to the notification of the European Community to
the Committee on Technical Barriers to Trade (G/TBT/Notif.98.343) submitted on 8 July 1998
concerning tyres for motor vehicles and their trailers.
2. Having reviewed the EU proposal COM(97)6 80 final - 97/0348 (COD) of December 1997 to
amend Council Directive 92/23/EEC, the Government of Indonesia wishes to draw attention to the
following:
− After carefully studying Annex 1 and Appendix 1 of the draft proposal, particularly
concerning:  "Measurement Procedures for Tyres/Road Noise Level Emitted by Tyres at High
Speed", the Government of Indonesia is of the opinion that the very specific requirement,
among others, regarding Conditions of Measurements concerning Test Site, are extremely
costly;  tremendous investment will be imperative which will effectively close any smallmarket opportunity that Indonesian tyre manufacturers have been able to open in the last
decade.  The draft excluded the term authorized representatives from inter alia  administrative
procedures for E.C. type approved of tyres.
− Under Council Directive 92/23/EEC, E.C. ty pe approval maybe sought by both the
manufacturers or by his authorized representative.  In the absence of any production facilitiesin the EU, the role of the authorized representative (to include the importer or the person
responsible for placing the product on the market) has ensure the Council Directive92/23/EEC has not presented a barriers to trade to Indonesian  tyre imports.
3. In view of the above, the Government of Indonesia requests the EU to review the draft
proposal as contained in Doc. COM(97)680 final - 97/0348(COD) of 10 December 1997 eliminating
the elements of technical barriers to trade which substantially may injure trade interest of Indonesia tothe EU.
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