- [Public Comments] Public comment on Japan Fair Trade Commission’s“discretionary surcharge system”
[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
- Particular care is required in considering the introduction of the so-called “discretionary surcharge system”
- 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.
- 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