RESPONSE TO USTR REQUEST FOR COMMENTS

BY THE AIR COURIER CONFERENCE OF AMERICA

            These comments are submitted by the Air Courier Conference of America (ACCA) in

response to the Office of the U.S. Trade Representative's (USTR) request for written comments

to assist USTR in formulating objectives for negotiations with countries acceding to the WTO,

and bilateral and plurilateral FTA trade agreements.  ACCA commends USTR's important

efforts to advance global trade liberalization and urges that trade in express delivery services be

fully covered and liberalized in any trade agreement.

ACCA's strong interest in these negotiations stems from our members' central role in

helping facilitate trade throughout the world.  ACCA is the trade association representing the

express delivery services industry; its members include large firms with global delivery

networks, such as DHL Worldwide Express, Federal Express, Airborne Express, TNT U.S.A.

and United Parcel Service, as well as smaller businesses with strong regional delivery networks,

such as International Bonded Couriers, Midnite Express and World Distribution Services.

Together, our members employ approximately 510,000 American workers.  Worldwide, ACCA

members have operations in over 200 countries; move more than 25 million packages each day;

employ more than 800,000 people; operate 1,200 aircraft; and earn revenues in excess of $50

billion annually.

ACCA members have significant experience facilitating global trade, with the express

delivery services sector serving an important and growing role in the free flow of trade between

the United States and the rest of the world.  Express delivery services further serve as a key

contributor to employment, growth, competitiveness and efficiency in both the United States and

our global trading partners.  Given the importance of the express delivery services sector itself,

as well as its role in facilitating future trade between the United States and the rest of the world,

it is crucial that any trade agreement include provisions making clear each signatories' mutual

commitment to fully liberalized trade in express delivery services.  In particular, we believe the

following objectives are essential to progress in this sector.

First, the express delivery services sector must be specifically recognized as a distinct

service sector in any trade agreement.  Failure to include a definition of express delivery services

could lead to reliance on other sources for a definition of the service, such as the Central Product

Classification (CPC) or the GATS.  However, the CPC definition of  courier services  utilized in

some prior negotiations inappropriately focuses on the service provider rather than the service

itself.  Thus, the CPC definition of courier services expressly excludes courier services if they

are performed by a national postal administration, notwithstanding that they are the exact same

services.  Furthermore, as USTR noted in the express delivery services paper it recently proposed

at the WTO, the present courier services sector utilized in some GATS schedules is inadequate to

capture what is encompassed in the express delivery services sector.  As one of ACCA's key

goals is a level playing field in the provision of express delivery services, ACCA requests that all

trade agreements adopt the following clear definition to explain the sector's coverage:

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