   
  
INF/TE/SSD/W/23  
 
23 March 2023  
(23-2112) Page: 1/31 
  
  Original: English  
 
  
TRADE AND ENVIRONMENTAL SUSTAINABILITY STRUCTURED DISCUSSIONS  
COMMUNICATION  FROM THE UNITED KINGDOM  
The following communication, dated 23 March  2023, is being circulated at the request of the 
delegation of the United Kingdom . 
 
_______________  
 
BUILDING OUR EVIDENCE BASE AROUND ENVIRONMENTAL GOODS  
Technical paper from the United Kingdom  
Introduction  
TESSD can be used to collaborate on, and develop, a s hared evidence base for environmental goods, 
helping us understand barriers to trade in key technologies that will help achieve environmental 
objectives – and what can be done about them. Value chain analysis is a good way to explore these 
questions.  
1. The 2022 TESSD work programme proved effective at convening a broad base of WTO members 
to discuss urgent environmental challenges posed by climate change, pollution and biodiversity 
loss, and the role that trade plays in combatting them. Environmental goo ds and services (EGS) 
remained one of the highest priority areas for members, and various presentations shared 
through our meetings have shone a light on issues holding back trade, particularly in 
environmental goods. There is broad support for the idea th at moving forward, shared 
environmental objectives should form the foundation of EGS discussions, with deep dive 
discussions into the various sectors supporting these objectives . 
2. Furthermore, as set out in the World Trade Report 2022, global coordination a round government 
measures will be required to ensure trade and climate policies are mutually supportive and play 
a full role in helping countries meet their environment objectives.  
3. In this context, EGS deep dive discussions in 2023 provide an important op portunity to build a 
shared understanding of:  
a. which goods will be most important to help us achieve environmental objectives and 
what services enable them ; 
b. what barriers are limiting trade in these goods ; and  
c. what steps can be taken to alleviate these bar riers. 
4. In our view, a powerful way to build up an evidence base is through value chain analyses, 
identifying and then analysing the full range of goods and services associated with various key 
technologies. Not only do value chain diagrams provide an acces sible way to visualise the link 
between goods and services, product lifecycles as well as the nature of production and trade, 
they provide an important launching point for further analysis into relevant barriers to trade.  
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  5. The remainder of this paper is d evoted to explaining the concept of value chain analysis and how 
it can contribute to building the proposed evidence base. The examples we have developed in 
this paper are focussed on renewable electricity generation1, aligned with the first proposed deep  
dive into renewable energy under the objective of climate mitigation. In developing these 
examples, we have reviewed the extensive literature relating to two types of solar photovoltaic 
(PV) modules: monocrystalline and multicrystalline.  
Climate mitigati on, renewable energy, and electricity generation – cases for solar  
Solar PV modules will be important in achieving climate mitigation objectives, reducing greenhouse 
gas emissions and operational costs compared with fossil -fuel based electricity generation . 
6. That solar PV modules make a significant positive impact towards meeting environmental 
objectives is well understood.  
7. The International Renewable Energy Agency (IRENA) in their report on the Future of Solar 
PV2 indicate that scaling up capacity of Solar PV over the next three decades could bring capacity 
up to 8,519 GW by 2050. Furthermore, they outline that enabling market conditions are essential 
to prepare the future energy system and that the cost competitiv eness of Solar PV drives 
reductions in system prices. If accompanied by sound policies, the transformation can bring 
socio-economic benefits associated with greater employment, education, and skills – in short, 
"unleashing the massive potential of solar PV  is crucial to achieve climate targets " (IRENA, 2019, 
p. 9). 
8. The International Energy Agency (IEA)  have estimated in their roadmap for the global 
energy sector3 that distributed solar PV generation, which represents around 40% of the solar 
PV market in 20 50, could be 7,500 TWh by 2050 in their sectoral pathway to Net Zero. They 
indicate that low -cost renewable energy technologies will make a significant difference in the 
race to Net Zero, outlining a pathway that calls for scaling up solar rapidly this dec ade, reading 
annual additions of 630GW of Solar PV by 2030.  
9. Project drawdown  also documents  the impact that solar photovoltaics have according to 
growth in energy output and avoidance of GHG emissions worldwide:  
"We assume that distributed solar photovoltaics can grow from 180 terawatt -hours of 
electricity generation to 6,010.21 –9,786.80 terawat t-hours by 2050. This large range is due 
to the many possibilities for future renewable technologies and the extent of electrification. 
That growth can avoid 26.65 –64.86 gigatons of greenhouse gas emissions. "4 
10. The UN Climate Technology Centre and Network  (CTCN)  clearly sets out that under the 
objective of climate mitigation, Solar PV5 responds to three key needs: diversification of energy 
sources, cleaner energy sources, and reduced GHG emissions. An indication is also provided of 
the applications  Solar PV is best suited for: areas with high solar irradiation, residential as well 
as co mmercial buildings, small off -grid systems, and grid connected systems. Extensive 
information is also provided regarding the feasibility of the technology and its operational 
necessities.  
 
1 Although the scope of technologies considered in this paper is limited, we are aware of and recognise a 
wide range of other solar solutions which have not been addressed here. There are similarly a wide variety of 
other renewable energy technologies that have not been addressed. We are interested in exploring a wider 
variety of solar solutions in future, but beyond solar we recognise and are interested in exploring several other 
types of renewable electricity generation that may be of interest to members s uch as: wind, hydroelectric 
solutions (of various scales), geothermal solutions, ocean or marine energy solutions, and other nascent 
technologies.  
2 https://www.irena. org/publications/2019/Nov/Future -of-Solar-Photovoltaic .  
3 https://www.iea.org/reports/net -zero-by-2050, p. 147. 
4 https://drawdown.org/solutions/distributed -solar-photovoltaics  n.b. figures from 2017/2018 . 
5 https://www.ctc -n.org/technologies/solar -pv.  INF/TE/SSD/W/23  
 
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  11. The UNIDO ITPO Tokyo STePP platform6 describes  the major features and advantages of a 
variety of solar solutions7,8, which are attributed to the stability of power supply, the 
effectiveness of solar in many applications, the adaptability in a wider array of climates, and the 
durability and reliabili ty of solar systems. The platform also includes engineering schematics for 
these technologies , which can be useful for HS classifiers when evaluating the essential 
characteristics of solar PV technologies.  
12. The World Intellectual Property Organi zation 's (WI PO) Marketplace for Sustainable 
technologies9 is a large and ambitious resource that can be used to identify opportunities for 
voluntary technology transfer on mutually agreed terms. In this database, companies holding 
intellectual property rights for sustainable technology can provide an indication t o firms 
elsewhere in the world regarding the type of commercial relationship under which they would be 
willing to facilitate voluntary technology transfer. Each entry in the database has also been rated 
according to its technology readiness level (TRL)10,11,12,13, a measurement system used to assess 
the maturity level of a technology, which is widely applicable across all sectors.   
13. Reviewing the WIPO resource, a variety of database entries exist for different types and 
applications of solar PV technologies along with details of the intellectual property owners and 
benefit descriptions for each solution. A selection of examples from this resource for solar PV 
technologies can be found in the table in ANNEX II.  
14. Reflecting on these frameworks, examples of aspe cts which could demonstrate the positive 
environmental impact of a good might include: their effectiveness at achieving environmental 
outcomes; the nascence of technologies; how easy it is to deploy the solution; the state of 
commercialisation of the solut ion; and wider instructive frameworks for qualifying the 
environmental credentials of goods and services. These impact considerations have been 
elaborated on in ANNEX III.  
15. Having reviewed the case for solar technologies found in these resources, we have developed 
example value chain diagrams for the production of Solar PV modules. We are conscious that 
the examples we have used may be incomplete or require correction. They s hould be seen as 
illustrative . Our intention is to refine the underlying examples and to submit these in due 
course as substantive contributions to an evidence base. However, we welcome views on the 
nature of this analysis, how it may be refined and whethe r others are interested in partnering 
or conducting similar work.  
Value Chain Mapping  
Value chain diagrams provide a powerful tool for organising key information relating to goods.  
16. Trade has evolved into 'Global value chains ' through which the  production a nd distribution of 
environmental goods and services have spread around the world. Value chain analysis is the 
means of describing and evaluating  the activities and products involved in any given value chain 
for an environmental good.  
17. Value chain  diagrams visualise and describe a range of manufacturing activities or production 
processes that are applied to raw material inputs and intermediate products as these are 
transformed into final goods, that combine to form technological solutions to environmental 
challenges.  
  
 
6 http://www.unido.or.jp/en/activities/technology_transfer/technology_db/ .   
7 http://www.unido.or .jp/en/technology_db/2883/ .  
8 http://www.unido.or.jp/en/technology_db/2978/ .  
9 https://wipogreen.wipo.int/wipogreen -database/ .  
10 Mankins, J.C. (2009). Technology readiness assessments: A retrospective. Acta Astronautica, 
65(9-10), 1216 -1223.  
11 https://innovolo -group.com/innovation -en/innovation -terminology -en/what -is-a-technology -
readiness -level-trl/.  
12 https://www.gov.uk/government/news/guidance -on-technology -readiness -levels .  
13 https://www.nasa.gov/directorates/heo/scan/engineering/technology/technology_readiness_level .  INF/TE/SSD/W/23  
 
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  18. We draw a distinction here between supply chain and value chain analyses; the former focusing 
on which firms are trading goods and where they are trading them; the latter focusing on 
precisely what is being traded and how traded input and intermediate goods are transformed 
into final goods. We have not calculated the value -added at stages of each value chain in this 
paper, though this type of analysis could be informed by the value chain diagrams in future.  
19. These diagrams describe both goods and services, production and trade. They can therefore 
serve as a unifying conceptual framework on which we can 'hang' information relevant to 
environm ental goods and services using annotations which speak to various policy challenges. 
Such diagrams can be used to organise information to improve our collective understanding of 
trade and production in the relationship between goods and services, and the e nvironment. In 
this way, they also tie together policy information needed to develop better and more 
coordinated trade, industrial, and environmental policies.  
20. The diagrams shown below are for illustrative purposes only and are not yet finalised. The 
classifications have not been quality assured and should not be assumed accurate. The codes 
appearing in these diagrams should not be read as a complete 'list of products ' as have 
previously been developed for environmental goods policy.   
 
Figure 1 : Value chain diagram showing the final assembly stages for a solar PV cell. See ANNEX  I.VIII 
for an enlarged version.  
21. We have worked through various publications in the public domain to produce value chain 
diagrams for the manufacture of solar PV cells, including a report from the US Energy department 
into the supply chain for photovoltaics .14 Reports such as these often contain relatively simple 
explanations or diagrams showcasing the value chain activities that sit behind a certain portion 
of the  supply chain. We have  built from these diagrams by reformatting the existing information 
into the value chain diagram shown in Figure 1 and consulting with academic publications, 
industry publications, and (where possible) sector experts to incorporate fu rther details.  
  
 
14 https://www.energy.gov/eere/solar/solar -photovoltaics -supply -chain -review -report .  
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  Benefits of using value chain diagrams  
22. Value chain diagrams organise complex information (often contained in lengthy academic and 
industry publications) in an accessible way and can be used to visualise a wider set of issues 
than simple li sts of goods historically have contained. Such information can support better 
decision making around policy intervention and implementation.  
23. The elements of a value chain diagram describe the productive capabilities that a country needs 
to participate in t he global value chain for the final good; illustrating these capabilities provides 
a roadmap for economies on all development pathways. It shows exactly where governments 
need to support industrial development to participate in the emergent global environm ental 
economy. As a result, trade and industrial policymakers across the world can use these diagrams 
to assess their national or firm -level productive capability in these technologies and improve 
their understanding of the relationship between production and the environment. Doing so could 
then lead to greater participation in the global value chains for the associated environmental 
goods, or their inputs and intermediate products.  Value  chain diagrams are not only useful in 
understanding where countries currently possess relevant productive capabilities in the 
environmental economy, but also where countries can work towards building capabilities 
oriented towards improving the environmental compatibility of  industrialised production.   
24. Value chain diagrams themselves could be used to identify where voluntary and mutually agreed 
tech transfer is possible and where it will be most valuable. A more developed annotative layer 
of analysis could seek to explicitly link technologies found in these value chain diagrams with 
entries in the World Intellectual Property Organisation 's (WIPO 's) Marketplace for Sustainable 
Technologies15, a potential area of future refinement discussed further in ANNEX I.II.  
25. Value chain dia grams can also be used as 'skeletons ' upon which further relevant information 
can be added. This could include further information to aid classification. It could also include 
information on broader environmental impacts across the lifecycle or more specif ic issues around 
barriers to trade.  
Constraints around value chain diagrams  
26. The depth of information about production processes can vary significantly across source 
publications. For example, we may only have a basic 'assembly' step, rather than a full 
description for the processes involved in assembly. As further evidence is gathered through 
expert engagement, we hope to elaborate on these parts of the diagrams to fill in the gaps.  
27. Often, the processes represented in these diagrams may not be the only way  to do things. 
Further research may reveal alternative processes which can be captured in future diagrams. 
Similarly, we are aware that some processes are currently missing entirely from these diagrams. 
There may be multiple routes to get to the same final  product, but there may also be differing 
final products that utilise the same technology. For example, the predominant type of solar 
module is the conventional, mature crystalline silicon module, but there are other, more 
innovative types of solar panels,  which are yet to be scaled up but which may share cross -cutting 
inputs, manufacturing processes, embedded learning and so on.  
28. Moreover, we have made no assessment of respective national productive capabilities or 
participation in different elements or po rtions of these value chains. We have also not completed 
analysis of where specialist expertise or equipment may be required or made any assessment 
of the degree of specialisation required at any stage of each value chain.  
  
 
15 https://wipogreen.wipo.int/wipogreen -database/database .  INF/TE/SSD/W/23  
 
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  29. These  diagrams contain no analysis of the market structures or power dynamics in global value 
chains16,17 among participants. Power dynamics can shape the emergence and development of 
barriers to trade but can also be an influential force in overcoming these. By exploring this in 
greater depth as we develop our understanding of value chains for environmental goods further, 
we can proactively identify those dynamics least conducive to environmentally preferable 
outcomes in trade.  
Using value chain diagrams to organise key informatio n 
Having illustrated the activities and products involved in the development of environmental 
technologies, we can add layers of annotations describing various issues relating to trade.  
30. As described above, value chain diagrams can be annotated with further information in support 
of policy decisions relating to goods. Below, we explore a number of areas where hanging 
additional information can support prioritisation and planning for policy  intervention, these 
cover: classification, links between goods and services, lifecycle considerations and barriers to 
trade.  
Classification annotations  
31. Constraints around commodity codes are well understood. The most specific level of goods 
classificatio n on which all WCO Members are harmonised is at the 6 -digit level, at which codes 
represent broad categories of goods.  Only rarely can HS6 codes be used to pin down specific 
goods which policy makers may wish to target, and they often contain a wide range of goods 
that are not connected with environmental outcomes. Historically, goods have been identified 
using HS6 codes and ex outs (more detailed specifications / exclusions) which have then been 
interpreted at national level to achieve specificity. T his often leads to divergences of 
implementation among members who do or do not maintain national classification systems 
beneath the HS6 level.  
32. Important efforts at HS reform at the WCO have introduced greater harmonisation around 
specific goods which migh t be labelled 'environmental ' over recent years; efforts which continue 
as part of the HS27 reform and revision process. But a pre -requisite to the development of HS 
reform proposals is a detailed understanding of the essential characteristics of environme ntal 
goods and how these differ from other products classifiable under a shared subheading. The 
'Ex-Out' descriptions found in past lists of environmental goods do not offer sufficient specificity 
to assess these characteristics.  
33. Our starting point for und erstanding these goods should be the proper identification of relevant 
commodity codes. In the diagram below, we have sought to capture the most specific commodity 
codes available within the Combined Nomenclature (CN) system used in the UK and EU, together  
with CAS numbers18 where appropriate .19 The first 6 digits of a CN code is common to all WCO 
members as an HS6 commodity code.  
 
16 Dallas, M.P., Ponte, S. and Sturgeon, T.J., 2019. Power in global value chains.  Review of International 
Political Economy , 26(4), pp.  666-694. 
17 Dallas, M. P., Ponte, S. and Sturgeon, T.J., 2017.  A typol ogy of power in global value 
chains  (pp. 1-35). Frederiksberg, Denmark: Copenhagen Business School, Department of Business and Politics.  
18 https://www.cas.org/support/docume ntation/chemical -substances/faqs .  
19 Where chemical elements are clearly named, labelled, or otherwise identifiable, they have typically 
been assigned a CAS Number. The ECICS consultation database can be used to look up the CN codes 
associated with CAS num bers: 
https://ec.europa.eu/taxation_customs/dds2/ecics/chemicalsubstance_consultation.jsp?Lang=en .  INF/TE/SSD/W/23  
 
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Figure 2 : Value chain diagram with commodity code annotations. See ANNEX I.IX for enlarged 
version.  
34. It is important to stress that this is not a 'list of environmental goods ' to which we envision 
future provisions might apply. This illustration simply shows how a product which appears on 
many past lists of environmental goods, i.e. Assembled Solar PV Mod ules (that have recently 
been allocated a dedicated HS6 commodity code in the HS2022 nomenclature), can be placed 
within its full value chain context in a way which links it to input and intermediate products.  
35. As described above, these classifications are  illustrative. They are based on short descriptions 
of products and would need further research into product specifics together with more extensive 
discussions with classification experts to confirm their essential characteristics and place within 
the nome nclature. For this reason, we welcome active collaboration with the WCO as we develop 
the evidence base around environmental goods.  
36. A collaborative process to identify commodity codes is likely to highlight specific areas where 
divergences are most marked or problematic, and thus where HS reform may be most suitable. 
However, it is unlikely that HS reform will isolate all relevant goods, and collaboration between 
members to harmonise approaches to national classification may become the best approach to 
simplify trade across key global value chains.  
Links  between goods and services  
37. The separate challenges around goods and services have led to a separation of effort in these 
areas. However, as reflected in these 'goods and services ' working groups, there is a growing 
recognition of their close relationship to one another. While the question remains open on 
combining goods and services, value chain diagrams highlight their close relationship. 
Fundamentally, services are used in the production of goods, goods are  used in the delivery of 
services and services can be used to ensure that environmental benefits are realised in the use 
of goods (particularly important when dual -use concerns persist).  
38. Value chain diagrams already show the combination of processes and go ods that form 
technologies. Some of the processes described in the diagrams can be provided by a value chain 
participant or by a third -party firm as a service. In addition to annotating value chains with 
commodity codes, annotating them with CPC codes show s which services might be involved in 
different stages of the value chain.  
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Figure 3 : Value chain diagram showing some CPC code annotations .20 See ANNEX I.X for enlarged 
version.  
39. Services experts note that in general, it is more challenging to list services that specifically 
contribute to environmental outcomes compared to environmental goods. Much like how HS 
codes represent categories  of goods, CPC codes represent a wide array of  services. Traditionally, 
the definition of 'environmental services ' has been constrained to the very narrow 'core list ' 
under CPC section 94, covering areas such as sewage, sanitation and refuse disposal services.  
40. The classification difficulties for servi ces stem from the breadth of the CPC system compared to 
the Harmonised System, as well as general difficulties in categorising and tracking services 
trade. There are therefore more technical challenges associated with dual -use, as noted in the 
recent WEF p aper on accelerating decarbonisation through trade .21 The available trade data for 
environmental services is also more limited, making it more difficult to prioritise those of interest 
according to trade volumes and environmental impacts. Value chain analy sis therefore offers an 
opportunity to explore the processes which sit behind the delivery of an environmental service 
in greater depth, whilst directly linking them to goods.  
Lifecycle considerations  
41. Reviewing previous work on potential environmental good s, a disproportionate emphasis is often 
placed on the end use of goods, with relatively little consideration given to relevant 
environmental issues around other lifecycle stages. However, it is important that a balanced 
view should be taken regarding a pro duct's relationship to the environment, covering both 
benefits and risks  to the environment.  
42. We recognise it is entirely possible, for example, that the processes associated with the 
extraction of raw materials and production of a good may outweigh the environmental benefits 
associated with its end -use. It is therefore imperative that we find a meaningful way of 
accounting for the balance of positive and negative impacts that might arise at different lifecycle 
stages when describing the relationship betw een products and the environment. This does not 
 
20 These are very rough and purely illustrative examples. The classifications used here have not been 
quality assured.  
21 WEF's (2022) paper  noted the issues with liberalisation of dual use services, and offers suggestions 
for possible solutions, including potentially speci fying services in more detail than the CPC code.  
https://www.weforum.org/reports/accelerating -decarbonization -through -trade -in-climate -goods -and-services/ . 
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  prevent us from describing how goods can support environmental outcomes. This allows us to 
scope out opportunities for collaboration to improve the environmental compatibility of different 
lifecycle stages ac ross the value chain.  
 
 
Figure 4 :22 Value chain showing lifecycle considerations. References in footnotes and enlarged 
diagram in Annex I.XI.  
43. Figure 4 shows how a value chain diagram might be annotated to account for both risks and 
opportunities to envir onmental outcomes. Here we have reviewed the literature on the 
relationship between the production of solar PV cells and environmental outcomes. Conclusions 
on the environmental benefits of solar electricity can be reasonably balanced against the risks 
of its lifecycle stages. A holistic understanding of the risks can support coordinated efforts to 
improve the environmental compatibility of production over time using new techniques, such as 
the new process for using laser irradiation in debonding EVA sheets .  
44. By representing a sequence of activities, value chain diagrams often align with the lifecycle of 
technology. It is therefore possible to annotate lifecycle issues directly onto the value chain  
diagram, reflecting specifically on:  
a. Raw material extraction . 
b. Production or manufacturing . 
c. Transportation . 
d. End-use or consumption . 
e. Re-use, recycling, other recovery,  disposal, waste prevention & reduction etc.  
 
22 References from Figure 4:  Farrell, C., Osman, A.I., Zhang, X.  et al. Assessment of the energy 
recovery potential of waste Photovoltaic (PV) modules.  Sci Rep  9, 5267, 2019. 
https://doi.org/10.1038/s41598 -019-41762 -5; Gifford, J. Recycling the whole module, PV -magazine, 2015.  
https://www.pv -magazine.com/magazine -archive/recycling -the-whole -module_100018150/ ; US Department of 
Energy. Solar Energy Technologies Office Photovoltaics End -of-Life Action Plan. Office of Energy Efficiency & 
Renewable Energy, U S Department of Energy, 2022 ; Weckend, S., Wade, A., Heath, G. End -of-Life 
Manage ment Solar Photovoltaic Panels. Irena.org, 2016 ; https://www.irena.org/publications/2016/Jun/End -of-
life-management -Solar-Photovoltaic -Panels ; Xiaotong Li, Huan Liu, Jiachuan You, Hongwei Diao, Lei Zhao, 
Wenjing Wang, Back EVA recycling from c -Si photovoltaic module without damaging solar cell via laser 
irradiation followed by mechanical peeling, Waste Management, Volume 137, 2022, pp. 312-318, I SSN 0956 -
053X, https://doi.org/10.1016/j.wasman.2021.11.024 .  
INF/TE/SSD/W/23  
 
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  45. Mapping environmental issues across the lifecycle onto the value chain is a good way to enable 
alignment between environmental and trade policies. While trade policy can remove barriers to 
trade, wider environmental policies may be needed to mitigate the r isk of an associated potential 
increase in environmental harm. This can allow more holistic thinking about goods and policy 
actions we take.  
46. There is no agreed  methodology for conducting lifecycle analysis, though several frameworks 
exist.23,24 However, si mply working to annotate issues identified by businesses and other experts 
across the lifecycle onto value cains can greatly enhance our understanding and enable us to 
take more holistic decisions, more confidently. Our aim here is not to prescribe an appr oach to 
firms regarding how such analysis should be conducted, simply to highlight those risks and 
opportunities for environmental outcomes across a lifecycle that we can see from a policymakers ' 
perspective. The intention is that these resources can act as a signpost to manufacturers and 
traders in these goods for how they can align the valuable work they are already doing to 
improve the environmental compatibility of production with the wider en vironmental objectives 
we are pursuing.  
47. Ultimately, with appropriate citation and referencing, a list of opportunities and risks at each 
lifecycle phase need not be any longer than the environmental benefit descriptions found in past 
environmental goods l ists. Indeed, many of the benefit descriptions in past lists already make 
reference to more than one lifecycle phase, despite their scope often being limited to end -use, 
so there is a base of evidence for goods in this format which can be built on – taking  the value 
chain approach to describing environmental goods does not mean starting from scratch.   
Barriers to trade: Tariffs and Non -Tariff Measures (NTMs)  
Technical Barriers to Trade (TBTs): standards and regulation  
48. While much previous discussion has been  devoted to MFN tariff rates on potential environmental 
goods, businesses and stakeholders tend to flag non -tariff measures as posing barriers to trade 
in environmental goods. Indeed, the WTO Secretariat described a wide range of possible NTMs 
affecting go ods trade in their presentation in October 2022. This paper delves briefly into TBTs 
because of their importance and relevance to the products in question and to build on the UK 's 
presentation on TBTs from July 2022 .25 The research behind the presentation found that TBTs 
account for 34% of the 89,421 non -tariff measures recorded in UNCTAD 's database .26  
49. When exploring NTMs  for environmental goods, it is important to note that regulations and 
standards are often employed to achieve legitimate domestic policy purposes, including 
improvements in sustainability and environmental protection. UNCTAD (2021) reports that about 
10% of all measures notified under the WTO SPS Agreement and the TBT Agreement cite 
environmental protection  as one of their objectives .27 Very often international, regional or 
domestic standards are used as a basis for mandatory technical regulations and conf ormity 
assessment procedures which businesses have to meet. Where these don 't exist or are not 
appropriate, countries can use domestic and regional standards.   
50. TBTs, as per the WTO TBT Agreement, cover technical regulations, standards and conformity 
assess ment procedures, As a starting point, we can analyse TBTs associated with certain 
commodity codes for final 'environmental ' products/goods. However, this faces challenges 
associated  with classification and risks excluding TBTs which affect production proce sses, inputs 
and intermediate products. Identifying how different TBT aspects are relevant to elements of the 
value chain helps improve our understanding of their impacts at different production stages. This 
analysis can be performed at the value chain lev el for each of the areas covered under TBT 's. 
 
23 In 2011 , Defra, the Carbon Trust, and the British Standards Institute published the Guide to 
PAS2050, which explains how to perform  lifecycle analysis on goods using five overarching lifecycle phases. 
This framework built on ISO 14040:2006, which describes the principles for lifecycle assessment and impact 
assessment, focusing on similar overarching phases.  
24 https://www.iso.org/standard/37456.html .  
25 https://www.wto.org/english/tratop_e/tessd_e/uk_presentation_190722.pdf .  
26 https://trainsonline.unctad.org/home . 
27 UNCTAD (2021), Better Trade for Sustainable Development: The role of voluntary sustainability 
standards . INF/TE/SSD/W/23  
 
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  We have begun this exercise by exploring which standards might apply across the final assembly 
stages for a solar PV module in Figure 5.  
 
Figure 5 : Value chain diagram with standards annotations. See ANNEX I.XII for enlarged version.  
Table I : Classification of different types of standards  
Classification 
of Standards  Standard included 
in Figure 5 
annotation  Examples  Nature of 
Document  
International 
Standards  ISO, IEC  Developed by global standards 
development organisations (SDOs) such 
as International Organization for 
Standardization (ISO) and International 
Electrotechnical Commission (IEC) for 
countries to adopt for national use  Volunta ry 
Regional 
Standards  BS EN  Prepared by a specific region  
e.g., BS ENs are British standard 
implementations of English language 
versions of European standards (ENs)  Voluntary  
National 
Standards   Developed either by a national 
SDO/body or other accreditation bodies  
e.g., Bureau of Indian Standards (BIS) 
for India, Standards Australia for 
Australia  Voluntary  
Industry 
Standards  PV, ASTM  Criteria developed within an industry 
relating to the standard functioning and 
carrying out of operations in the ir 
respective fields of production28 e.g. 
Photovoltaic Standards (PV) and 
American Society for Testing and 
Materials Standards (ASTM)  Voluntary  
 
28 https://www.directives.doe.gov/terms_definitions/industry -
standard#:~:text=A%20set%20of%20crit eria%20within,the%20members%20of%20an%20industry . 
INF/TE/SSD/W/23  
 
- 12 - 
 
  51. Table I provides detail on the types of standards we have included in the annotation of the value 
chain diagram (Figure 5), and whilst standards are voluntary, they can become mandatory when 
used or incorporated in domestic regulation.  
52. Figure 5 illustrates several important points simultaneously. Firstly, it  documents how standards 
might apply to or affect a final product by showing where they apply across various production 
stages. Secondly, it shows that standards which affect the supply of env ironmental goods, and 
therefore potentially affect trade, may not always apply directly to the finished product .29 Thirdly, 
it reveals where multiple standards could apply to a product or input, giving rise to potential 
divergence among standards that migh t apply in different markets.  
53. Producers conforming to regulations and standards across the value chain can incur significant 
compliance costs and technical difficulties understanding which standards to adhere with and 
where, especially SMEs and producers in developing countries.  
54. Working in  a value chain format is the first step in understanding and addressing these issues, 
through a) identifying the relevant international standards so it is more clear what kinds of best 
practice exist, which is useful for  technology transfer, b) encouraging the practice of basing 
technical  regulations on international standards and c) identifying where there is significant 
divergence in standards and encouraging the development of new standards. The increased 
alignment and  in some cases harmonisation of standards and other regulatory practices will 
facilitate better quality trade and therefore facilitate better deployment of environmental 
technologies that have the capacity to reduce carbon emissions.  
MFN Tariffs  
55. As well documented, efforts over the last 30 years to promote trade in environmental goods 
have primarily been focused on the reduction of import tariffs .30 However, the debate regarding 
tariff reductions on environmental goods requires more nuance. Identifyi ng tariff rates across 
global value  chains helps to identify not only where tariffs may be high on finished goods, but 
also where tariffs may be high on inputs to production, forming potential bottlenecks.  This 
framework allows us to explore where tariffs exist, why they are in place, whether they ultimately 
pose a barrier to the uptake of these technologies, and explore more creative solutions to resolve 
these challenges.  
56. The simple average applied MFN tariff rates across G20 and TESSD members for the com modity 
codes  highlighted in Figure 6 have been analysed in Graphs 1 -4, compared with an illustrative 
5% tariff cap (the tariff cap agreed as part of the APEC environmental goods initiative in 2012). 
Average tariff rates on final environmental goods are oft en low, demonstrated by Graph 1 for 
Assembled PV Modules. Whilst TESSD members maintain low average applied tariffs on some 
key inputs to the production of these technologies compared to the G20, as shown by Graph 2, 
higher average tariffs remain on some i nputs to the production of these technologies, as shown 
by Graph 3. Tariffs on inputs to the production of renewable electricity technologies and on 
components of utility scale renewable electricity generation facilities can directly increase the 
cost of e nergy provision .31,32 Further analysis could replicate the kind of bottleneck analysis 
conducted by the WTO Secretariat looking at COVID -19 goods during the pandemic .33 
  
 
29 The codes we have matched to goods should not be seen as definitive, and more investigation will be 
needed to identify the specifics.  
30 https://www.wto.org/english/tratop_e/tessd_e/  
secretariat_presentation_experiences_with_egs_promotion.pdf .  
31 Feedback from industry gathered in 2021 highlighted that tariffs can directly affect the calc ulation of 
the levelized cost of electricity (LCOE) by adding to capital costs. LCOE can act as a proxy indicator for the total 
cost of electricity provision.   
32 https://www.marathoncapital.com/news/impact -of-section -201-import -tariffs -on-utility -scale-solar-
lcoe.  
33 https://www.wto.org/english/tratop_ e/covid19_e/vaccine_inputs_report_e.pdf .   INF/TE/SSD/W/23  
 
- 13 - 
 
  57. In the European Commission 's 2014 impact assessment on the Environmental Goods 
Agreement34, elimination of  tariffs on environmental goods considered as part of the EGA was 
estimated to, relative to the baseline, reduce global carbon emissions by almost 10 million 
tonnes by 2030 and prices in these goods by 0.8% on average .35 There are different examples 
of how  tariff reductions can be achieved. Under the APEC initiative, members agreed to steadily 
reduce their tariffs to below 5%. Such examples can give inspiration for how we can tackle tariff 
barriers in the future. Beyond this, there are a variety of flexible  options for addressing tariff 
barriers, particularly where they are creating bottlenecks to the supply of environmental goods.  
 
 
Figure 6 : Value chain diagram highlighting simple average tariff rates for G20 and TESSD members 
studied below.  
  
 
34 https://op.europa.eu/en/publication -detail/ -/publication/f256d8d8 -067c-4f3c-9a21-c3601816c2cf .  
35 The results of the study should be interpreted as relative to the baseline scenario (without EGA) 
rather than as absolute reductions.  
INF/TE/SSD/W/23  
 
- 14 - 
 
   
Graph 1: Assembled Solar PV Module  Graph 2: Component of Back Sheet - PET  
  
Graph 3: EVA Sheet  Graph 4: I -V Curve Tester  
s
  
 
Source: Tariff data sourced from ITC MacMap (Market Access Map, International Trade Centre , 
https://www.macmap.org/ ) for all countries except UK where tariff data is from national sources.36 
  
 
36 The latest year available in MacMap for each country was used in the tariff analysis (2021 for the 
majority of countries but in some cases data has been sourced from earl ier years and in rare cases tariff data 
was missing altogether). Analysis was carried out using HS2017 nomenclature. Where data for individual 
countries was reported in a different HS nomenclature it was concorded into HS2017. For HS codes that are 
new in HS2022 we have assumed that the tariff data for the corresponding HS2017 code(s) also applies to the 
new HS2022 code(s). For example, we have assumed that the average tariff for HS2017 code 854140 applies 
equally to HS2022 codes 854142 and 854143. For the purposes of the analysis, EU members have been 
included as one EU group rather than as individual countries due to the EU 's Common External Tariff.  
INF/TE/SSD/W/23  
 
- 15 - 
 
  Countermeasure tariffs and disputes  
58. In addition to MFN tariffs, in some instances goods can be affected by retaliatory tariffs, which 
are selected both for their trade value and ability to incentivise a country which has breached 
international agreements or obligations to redress issues which have been subject to trade 
disputes.  The Swedish National Board of Trade37 has suggested that significant proportions of 
renewable energy products under discussion as part of the EGA have been subject to retaliatory 
tariffs arising from trade disputes over the last 20 years.  
59. We can annotate the value chains noting those goods wh ich are subject to these additional tariffs 
and highlighting the specific impact they may have on global value chain participation, and thus 
on trade.  
60. Identifying products subject to such tariffs could lead to greater consideration of environmental 
issues when selecting products to target and in reviewing them. We note that often, 
environmental considerations do not feature within criteria used for applying retaliatory tariffs.  
Next steps  
Working together to build and collate an evidence base around enviro nmental goods  
61. The development of an evidence base built upon value chain analysis is an effective way to 
organise information  related to environmental technologies, to support an assessment about the 
best way to implement policies that promote sustainable trade and increased deployment.  
62. As described, the UK will be refining the examples in this paper to be shared in due course. 
Examples in this paper remain illustrative.  
63. We also intend to undertake similar work into other technologies, including those supporting the 
development and installation of offshore wind turbines. Exploration of other forms of renewable 
electricity generat ion, low -carbon electricity generation, transmission and distribution of 
electricity, and electricity storage could form the basis of future research. We also recognise the 
importance of expanding the scope of solutions under consideration in future to cov er renewable 
energy more holistically, such as by exploring clean heat technologies, hybrid electricity and 
heat generation, heat management, and broader energy storage solutions. Future research in 
the energy sector could also explore sector -specific appl ications of Carbon Capture, Use and 
Storage (CCUS ), as well as hydrogen production, distribution, and storage.  
64. We strongly encourage members to undertake similar work, to help understand the scope of 
goods and services, barriers to trade, as well as to ide ntify potential policies that support 
sustainable trade. Alternatively, we encourage members to review the evidence base being 
brought forward by others.  
65. We welcome reflections on the ideas shared in this paper, and welcome engagement from 
interested membe rs with questions, views or interest in collaboration.  
66. Ultimately, the planned  TESSD deep dive discussions can be used to present and share research. 
Such contributions, if well organised through a living report or similar document, can ultimately 
support discussions between members about actions we can take.   
 
  
 
37 https://www.kommerskollegium.se/globalassets/publikationer/rapporter/2020/trade -barriers -to-
goods -and-services -important -for-climate -action_webb.pdf .   
  INF/TE/SSD/W/23  
 
- 16 - ANNEX I – EXAMPLE SOLAR PV MODULE VALUE CHAIN DIAGRAMS  
I.I  Methodological notes  
When contemplating how to approach the development of value chain diagrams, we were inspired by the work of the Advanced Propulsion Centre (APC) to 
document the value chain associated with hydrogen fuel cells .1 The contents of our diagrams are based on publicly available sources of information. Our starting 
point for documenting the different stages of the Solar PV value chain was one report in a series of supply chain deep dive a ssessments from the US Energy 
Department into different renewable energy technologies .2 This report contained process diagrams explaining the intermediate production steps that take place 
at different points in the supply chain. We converted the contents of this publication into the val ue chain format found in the APC report and added to this using 
further desk -based research.  
The value chain diagrams we have produced relate to conventional, silicon crystalline solar cells as opposed to other, more i nnovative cells being developed such 
as thin -film, BIPV, etc. In future, with further input from experts, traders, and TESSD participants, we would like to expand this an alysis to cover other solar 
solutions as well.  
Astute observers may note that the set of value chain diagrams developed her e does not yet cover the products or processes entailed in and arising from the 
safe disposal or recycling of materials at the end of a Solar PV Module 's lifecycle. We are aware of some of the work that has been done to explore this lifecycle 
stage3,4,5 and wish to incorporate these stages into future value chain diagrams.  
I.II  Classification notes  
The commodity codes in these diagrams have not been verified by classification experts and therefore should be treated as ill ustrative. Traders should not c ite 
this material as reference for how products should be classified.  
Whilst the diagrams themselves assist in answering some classification questions needed to ascertain the essential characteri stics of the final product (What 
components does the product  have? What are the raw material inputs?), they do not contain answers to other important classification questions (What does it 
look like when presented at the border? How is it packaged? Is there any accompanying paperwork which might assist in the ide ntification of the product? etc.). 
In future, we would like to work directly with traders, experts, and classifiers to seek more accurate classifications for th e products appearing in these diagrams.  
CAS numbers have been used to support the classification o f chemicals and metallurgical materials because we can cross -reference these with the Combined 
Nomenclature classifications found in the ECICS consultation database .6 We then use the first six digits of the CN code as the HS code in the diagram – noting 
that classification divergence is possible among members beneath the HS6 level.  
 
1 See page 3 of the report: https://www.apcuk.co.uk/automotive -fuel-cell-system -and-hydrogen -tank-value -chains/ .  
2 https://www.energy.gov/eere/solar/solar -photovoltaics -supply -chain -review -report .  
3 https://www.irena.org/publications/2016/Jun/End -of-life-management -Solar-Photovoltaic -Panels .  
4 Komoto, K.  (2014), "Developments on PV Recycling in Japan ", Proceedings 24th European Photovoltaic Solar Energy Conference , Hamburg.  
5 Komoto, K., Oyama, S., Sato, T. and Uchida, H., 2018, June. Recycling of PV modules and its environmental impacts. In  2018 IEEE 7th World Conference on Photovoltaic 
Energy Conversion (WCPEC)  (A Joint Conference of 45th IEEE PVSC, 28th PVSEC & 34th EU PVSE C) (pp. 2590-2593). IEEE.  
6 https://ec.europa.eu/taxation_customs/dds2/ecics/chemicalsubstance_consultation.jsp .   
  INF/TE/SSD/W/23  
 
- 17 - Future improvements  under consideration  
Diversifying the colours to represent more.  Other prototype diagrams we have developed apply a wider selection of colours to these diagrams to indicate the 
differences between raw materials, worked materials, processed goods, and final goods; processing versus assembly stages; spe cific technologies;  and machinery 
or tools required in each step.  
WIPO Green database entries layer . This layer of annotations could show which of the products or technologies appearing on the diagram are available through 
the marketplace for sustainable technologies. Each product or technology could be annotate with the database ID for the relevant entry. We could also experiment 
with different colour coding systems for different layers of analysis, such as a shaded risk and opportunities assessment on the lifecycles layer.   
Adding economic metrics . This could potentially span multiple new layers. As suggested in the paper, these resources could be used to perform value -added 
analysis, which could be conducted at the level of entire diagrams, portions of a diagram, or indivi dual products. We might also be able to explore the addition 
of product complexity indicators7, Revealed Comparative Advantage (RCA) values for specific economies or groups of economies, and other product -specific 
economic assessments.  
Assessments of Nati onal Productive Capabilities.  Products and processes appearing in the value chain diagrams could be coloured differently according to where 
any given country does or does not host firms capable of making or using these. This could be modelled on the value chain analysis contained within the APC 's 
Automotive Batteries Chemical Supply Chain Report8 (see page 6). 
  
 
7 https://atlas.cid.harvard.edu/rankings/product#:~:text=The%20Product%20Complexity%20Index%20(PCI,produce)%20include%20electro nics%20and%20chemicals .  
8 https://www.apcuk.co.uk/automotive -battery -chemical -supply -chain -report -summary/ .   
  INF/TE/SSD/W/23  
 
- 18 - I.III  PV Module Frame  
 
 
 
  
 
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- 19 - I.IV  Raw Silicon Refining  
 
 
  
 
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- 20 - I.V  Monocrystalline Silicon Wafers  
 
  
 
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- 21 - I.VI  Multicrystalline silicon wafers  
 
  
 
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- 22 - I.VII   Full-area PERC cells  
 
 
  
 
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- 23 - I.VIII   Final assembly stages for a solar photovoltaic module  
 
 
  
 
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- 24 - I.IX  Final assembly stages for a solar photovoltaic module annotated with commodity codes  
 
 
  
 
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- 25 - I.X  Final assembly stages for a solar photovoltaic module annotated with CPC codes  
 
 
  
 
  INF/TE/SSD/W/23  
 
- 26 - I.XI  Final assembly stages for a solar photovoltaic module annotated with exemplary lifecycle considerations  
  
 
  INF/TE/SSD/W/23  
 
- 27 - References for lifecycle considerations:  
- Farrell, C., Osman, A.I., Zhang, X.  et al. Assessment of the energy recovery potential of waste Photovoltaic (PV) modules.  Sci Rep  9, 5267, 2019. 
https://doi.org/10.1038/s41598 -019-41762 -5 
 
- Gifford, J. Recycling the whole module, PV -magazine, 2015. https://www.pv -magazine.com/magazine -archive/recycling -the-whole -
module_100018150/  
 
- U.S. Departmen t of Energy. Solar Energy Technologies Office Photovoltaics End -of-Life Action Plan. Office of Energy Efficiency & Renewable Energy, 
U.S. Department of Energy, 2022.  
 
- Weckend, S., Wade, A., Heath, G. End -of-Life Management Solar Photovoltaic Panels. Irena. org, 2016. 
https://www.irena.org/publications/2016/Jun/End -of-life-management -Solar-Photovoltaic -Panels . 
 
- Xiaotong Li, Huan Liu, Jiachuan You, Hong wei Diao, Lei Zhao, Wenjing Wang, Back EVA recycling from c -Si photovoltaic module without damaging solar 
cell via laser irradiation followed by mechanical peeling, Waste Management, Volume 137, 2022, Pages 312 -318, ISSN 0956 -053X, 
https://doi.org/10.1016/j.wasman.2021.11.024 . 
   
  INF/TE/SSD/W/23  
 
- 28 - I.XII   Final assembly stages for a solar photovoltaic module annotated with standards codes  
 
  INF/TE/SSD/W/23  
 
- 29 - ANNEX II – SELECTION OF WIPO GREEN DATABASE ENTRIES FOR SOLAR PV TECHNOLOGIES  
Database ID  TRL Conditions for use – collaboration type  
7894 9 – Scaling up  Other -> bSolar seeks today for complementary funding, as well as for 
new customers who will join a list of strategic customers from Germany, 
China and Japan.  
147587  9 – Scaling up  For sale  
145206  9 – Scaling up  For sale, For service  
138915  9 – Scaling up  For sale, For service  
(Available technical assistance: personnel or training, materials)  
138866  9 – Scaling up  For sale, For service  
20048  7 – Technology optimization/prototype 
validated in operational environment  License  
9558 3-4 – Proof of concept  License  
8198 7 – Technology optimization/prototype 
validated in operational environment  R & D contract or research collaboration, For service, Joint venture  
(Available technical assistance: Materials, Documentation, Other -> 
Personnel/Training)  
7963 9 – Scaling up  Other -> The company is looking for partners in the field of PV/PVT 
installation/EPC to install millennium 's modules in Germany/worldwide, 
Solar thermal manufacturing to sign a joint venture licensing tec hnology 
transfer agreement and investments.  
 
 
   
  INF/TE/SSD/W/23  
 
- 30 - ANNEX III – WIDER ENVIRONMENTAL IMPACT CONSIDERATIONS  
The effectiveness of EGS for achieving environmental outcomes  and how this is measured can vary between sectors. In renewable energy for example, IRENA 
has investigated the criteria and indicators used to evaluate renewable energy deployment, which examines four collections of  criteria relating to: 1) effectiveness,  
2) efficiency, 3) equity, and 4) institutional feasibility .9 
Nascent  and innovative technologies continue to emerge as the environmental goods policy space progresses. Different interventions wi ll be suitable for 
technologies at different levels of devel opment. When considering the nascence of a technology there are a variety of factors we can account for, but these can 
be organised into two overarching scales of technological maturity and market maturity. Regarding technological maturity, the re are alrea dy well -established 
metrics in the literature for assessing the Technology Readiness Level (TRL) and the Manufacturing Readiness Level (MRL) .10  
State of commercialisation  - Are they already in the market? Are they widely produced?  The MRL helps us to addr ess a part of this question, but we may also 
account for the diversity of products available in the market for any given group of environmental technologies and the ubiqu ity of their production around the 
world .11 One way of narrowing our focus could be to  look at those products with a high TRL, high MRL, low diversity, low ubiquity, and highly positive environmental 
impact to ensure that the solutions we design will be both effective and scalable.  
How easy are they to deploy?  Some solutions are simple and  cheap to deploy, for example solar water pumps, for which decentralised decision making regarding 
uptake or installation can be taken by an individual farmer. Alternatively, the solution may be part of a much more complex p rocess such as a tidal barrage, for 
which much more complex centralised decision making will be required to achieve effective installation.  
Can they effectively be targeted in trade policy?  Using the example above, solar powered water pumps appear in past lists of environmental goods but possess 
no dedicated subheading in the harmonised system nomenclature, as first highlighted by the IISD in their paper on the issue .12 In line with the reco mmendations 
of this report, the UK has substantively engaged in the HS reform process at the WCO and proposed that a dedicated subheading  be granted to this product. This 
example shows that even where a product cannot be targeted effectively, this can form  the basis for collective action among members through the collaborative 
development of HS reform proposals to achieve better distinguishability for environmental goods.  
State of commercialisation - are they already in the market?  Are they widely produced?  The MRL helps us to address a part of this question, but we may also 
account for the diversity of products available in the market for any given group of environmental technologies and the ubiqu ity of their production around the 
world. One way of narrowin g our focus could be to explore those products with a high TRL, high MRL, low diversity, low ubiquity, and highly positive en vironmental 
impact to ensure that the solutions we design will be both effective and scalable.  
 
9 https://www.irena.org/pub lications/2014/Feb/Evaluating -Renewable -Energy -Policy -A-Review -of-Criteria -and-Indicators -for-Assessment .  
10 US Government  Accountability  Office  (GAO).  (2010).  Best practices:  DOD can achieve  better  outcomes  by standardizing  the way manufacturing  risks are managed  
(Report  No. GAO-10-439).  Washington,  DC: GAO.   
11 https://atlas.cid.harvard.edu/glossary  (see terminology for: diversity and ubiquity) . 
12 https://www.iisd.org/publications/report/code -shift-environmental -significance -2022-amendments -harmonized -system .   
  INF/TE/SSD/W/23  
 
- 31 - Wider frameworks  can also be instru ctive. In the UK, when making claims about environmental goods and services, under domestic consumer protection law 
businesses must not mislead consumers. The Competition and Markets Authority provides a checklist of ways of effectively capt uring the envir onmental impact 
of products .13 
Within the deep dive discussions, we welcome reflections from Members of which goods are likely to achieve the biggest impact  and why.  
 
 
__________  
 
13 https://www.gov.uk/government/publications/green -claims -code-making -environmental -claims/environmental -claims -on-goods -and-services . 