30 September 2022

Phil Mellor

Economic Division, Ministry of Foreign Affairs and Trade, Wellington

(By email)

Dear Phil,

Thank you for your email of 1 September, seeking our comments on the three year review of the Comprehensive and Progressive Agreement for Trans Pacific Partnership (CPTPP).

As a long-term supporter and advocate of CPTPP (and its predecessor) we welcome this review.  While it comes fairly early in the life of this agreement (and, as the review notes, a time of constraint for the region’s economy), we are pleased (although not at all surprised) to see that trade flows with CPTPP partners have increased and utilisation of preferences is high, notably with Mexico, Canada and Japan.  Anecdotal evidence suggests that CPTPP has given New Zealand much to gain in terms of trade with Japan particularly as tariff elimination/reduction in key sectors accelerates.  Implementation efforts remain critical. We appreciate the New Zealand Government’s willingness to consider options to enforce existing obligations through utilising CPTPP’s dispute settlement provisions where necessary (eg. such as in the case of Canada’s approach to dairy tariff rate quota administration). We hope also that the work of CPTPP implementing committees can pick up pace now that the pandemic has eased – we see significant value to be gained, especially in trade facilitation, from the work of these committees.  

We understand that this review has been undertaken primarily to assess the impact of the agreement in terms of inclusion and sustainability.  We would however make the (obvious) point that unless the agreement gives rise to increased trade and investment, the outcomes in other areas are unlikely to be achieved fully.  In that context, since CPTPP entered into force, NZIBF has welcomed the interest in new members acceding to the agreement, and the formal launch of the UK’s accession process. We support CPTPP as an ‘open plurilateral’ to build on the existing agreement and allow new members to join on the basis that they can meet the existing standards of the agreement.  We note however that we would not want to see the dilution of existing trade access, through for example, the ability of new members to access existing tariff rate quotas. We appreciate the New Zealand Government’s efforts to protect and maintain this existing access as membership expands. With regard to new members, we appreciate also the Government’s efforts to advocate for the US to re-join in the future.  While we understand that the US may not be in a  position to join at this point, we welcome the Government’s ongoing advocacy of their future accesson.

In relation to inclusion, we welcome the progress and metrics in relation to women, Māori and small and medium sized enterprises (SMEs).  In New Zealand we believe more could be done to bring the agreement and its benefits to the attention of these groups.  While again the pandemic has had an effect on outreach, we consider this needs to be stepped up in the next period.  In relation to SMEs we suggest the development of further metrics around usage of digital tools, particularly in relation to paperless trade, would be useful.

We also welcome the review’s findings in relation to sustainability.  In this regard we note the range of metrics pertaining to environmental goods appears to be rather narrow:  some broader discussion of impacts on the environment and climate would be helpful, although we appreciate data is difficult to identify.

As a general comment, not related directly to the review document, we are unsure what use has been made of the Trade for All Advisory Board in seeking comments on the review. We note the Board is not one of the entities identified with in the targeted stakeholder consultation.  Having been consulted on the establishment of the TfAAB, we are disappointed that little public information is available on the Board’s continuing work or their role in guiding the development of trade policy.  Since Trade for All was established to make up for a deficit in information related to trade negotiations, this seems something of an anomaly !

In general we are pleased to endorse the recommendations in the review document.  We appreciate the opportunity to be consulted.

One final small point – we are the NZ International Business Forum and would be grateful if you could amend the document accordingly.

Yours sincerely

Stephen Jacobi – Executive Director, NZIBF