[Public Comments] Public comment on Japan Fair Trade Commission’s“discretionary surcharge system”

On August 31st, JANE submitted its comment in response to a draft on discretionary surcharge system compiled by the Japan Fair Trade Commission.

<Reference> Request for Public Comments on “Summary of Issues Concerning the Modality of the Administrative Surcharge System”

Download the document (in Japanese) from here

<Comment Summary>

  1. Particular care is required in considering the introduction of the so-called “discretionary surcharge system”
  2. Regarding the standards of surcharge amount, the current level of fees should be maintained. Raising of fee levels should not be left to discretion in the least.
  3. The introduction of the discretionary surcharge system should be premised on the following two points: 
       3-1 Securing of due process as well as rights of defense
       3-2 Establishment of a clear guideline regarding procedures and standards for
         discretionary reduction of rates