LIMITE EN COUNCIL OF THE EUROPEAN UNION. Brussels, 9 December /1/10 REV 1 LIMITE ENFOCUSTOM 104 ENFOPOL 322 CRIMORG 198 DROIPEN 127

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1 COUNCIL OF THE EUROPEAN UNION Brussels, 9 December /1/10 REV 1 LIMITE ENFOCUSTOM 104 ENFOPOL 322 CRIMORG 198 DROIPEN 127 NOTE From: Hungarian delegation To: Customs Cooperation Working Party No. prev. doc.: 7805/3/10 REV 3 ENFOCUSTOM 26 Subject: Threat assessment on intellectual property rights (IPR) Following the approval of the mandate to produce a threat assessment on intellectual property rights including all of the Member States and which would serve as a basis for a future Joint Customs Operation (doc. 7805/3/10 REV 3 ENFOCUSTOM 26), the Hungarian delegation hereby presents such a threat assessment which has been revised based on the outcome of the CCWP meeting of 10 November /1/10 REV 1 RR/dk 1 DG H 3A LIMITE EN

2 I. Table of contents I. Table of contents... 2 II. Introduction... 3 III. Background... 4 IV. Justification... 5 V. Former documents taken into consideration... 8 VI. Analysis of previous operations VII. Methodology VIII. General analysis IX. Detailed analyses Seizure data Transportation methods Types of seizure locations Seized goods Routes; departure and destination countries X. Conclusion XI. Recommendations /1/10 REV 1 RR/dk 2 DG H 3A LIMITE EN

3 II. Introduction Trade in counterfeit and pirated goods is a large and growing problem requiring the international community, national governments, and all other stakeholders at all levels to assign higher priority to the fight against this gradually growing threat. Over the past years, widespread concern has been expressed regarding the negative social and economic impacts of counterfeiting and piracy. Links with transnational organised crime groups have also been demonstrated. For instance, Europol (in its Intellectual Property Crime analysis) has found sufficient evidence to prove that organised crime groups are actively involved in the trade in counterfeit commodities. Many counterfeit products endanger the health, safety and security of consumers, and there are strong indications for potential corruption emanating from the trade in counterfeit and pirated products. Counterfeiting damages the economy by depriving national economies of revenue, by creating unfair market conditions for the fair players of global trade, and by undermining public trust in branded commodities of excellent quality. For the aforementioned reasons, and taking into consideration, on the one hand, the development of financial crimes and, on the other hand, the protection of economic interests of the EU as well the safety and security of the EU citizens, the Hungarian CCWP delegation offered to produce - in cooperation with Europol - a new intellectual property rights (IPR) threat assessment (TA) including all of the Member States. Council Resolution of 23 October 2009 on a reinforced strategy for customs cooperation 1 invites the customs authorities and other law enforcement authorities of the Member States and the competent European Union agencies and bodies to continue to do their utmost to strengthen and further develop cooperation with each other and with third countries in the fields of prevention, detection, investigation, and prosecution of cross-border criminal activities. 1 OJ C 260, , p /1/10 REV 1 RR/dk 3 DG H 3A LIMITE EN

4 The final report (15609/1/09 REV 1 ENFOCUSTOM 124) of the project group on Action 3.4 "To produce guidelines for the establishment, use and updating of threat assessments" (third Action Plan ) states as follows: If a Member State sees the need for a threat assessment at the European level a proposal should be put forward to the CCWP experts. The proposal can be made by any member of the CCWP. Furthermore: CCWP experts should decide who will coordinate the drafting of the threat assessment. Within the framework of the CCWP, no threat assessment has been specifically carried out on IPR violations, although an initiative to carry out a threat analysis on piracy and counterfeiting was launched by Spanish and Belgian delegations in 2007 (5331/3/07 REV 3 ENFOCUSTOM 7). Regardless of the outcome of initiative of the Spanish and Belgian delegations, a well-grounded, detailed, and complex TA reflecting the current situation, trends, and phenomenon might be very useful for the whole Customs and law-enforcement community. The TA seeks to present a snapshot of the most vulnerable group of goods and the typical means of transport. Nevertheless, similarities and differences in other findings such as the 2009 Annual IPR report prepared by WCO have been taken into consideration in order to avoid duplication. III. Background Perceiving the spread of intellectual property rights crime and its effect on the European economy, Hungary decided to treat this issue as a priority during the Hungarian Presidency of the EU in the first half of Since joint customs operations have proved to be an effective tool in the past, Hungary has decided to organise a joint customs operation targeting intellectual property crime in the spring of In accordance with the recommendations of the Guide for Joint Customs Operations (JCO) 2, the Hungarian delegation requested a mandate to prepare a threat analysis on the subject at the March 2010 meeting of the CCWP Experts Group. The mandate was granted on 2 June /09 ENFOCUSTOM 38 + COR /3/10 REV 3 ENFOCUSTOM /1/10 REV 1 RR/dk 4 DG H 3A LIMITE EN

5 IV. Justification As a 2008 OECD report Economic Impact of Counterfeiting and Piracy points out, The growing importance of IP in knowledge-based economies has generated concerns about the potential adverse effects of counterfeiting and piracy on governments, right holders, and consumers. Most of these so-called knowledge-based economies are encompassed by the European Union, which suffers the highest rate of losses due to IPR infringements. This high level of involvement is further illustrated by the fact that (according to the Global Review of Counterfeiting and Piracy in 2009, published by the WCO) in 2009 RILO Western Europe reported 6,958 seizures (52.4% of the total 13,280), while RILO Eastern and Central Europe came third with 1,122 seizures and an 8.4% share of total IPR seizures, according to the CEN database. These figures suggest that the countries of Europe are affected by more than 60% of the discovered illicit trade in IPR infringing goods, mainly as destination countries. This report also states that there has been a significant increase of items in textile articles, and among the top-10 counterfeit trademarks accounting for 56% of the estimated value of all seized items 4 major producers of clothing, sportswear and footwear, such as Nike, Adidas, Puma, and Crocs, can be found. Also, the involvement of organised crime in the area of IPR violations is a proven fact, assessed through Europol s Organised Crime Threat Assessment (OCTA) project and confirmed by Analysis Work File AWF COPY contributions received from the Member States and Europol s partners since the operational project commenced in Operation GOMORRAH, a 2 year investigation coordinated by Europol and Eurojust, involved 20 Member States and 3 third countries. This resulted in the arrest of 67 criminals linked to Camorra clans, the seizure of more than 800 tons of counterfeit products valued at 12 million euro and the recovery of assets exceeding 16 million euro /1/10 REV 1 RR/dk 5 DG H 3A LIMITE EN

6 Operation KUSSEN, led by Italy s Guardia Di Finanza (GdF), resulted in the discovery and dismantling of 16 illicit factories in Italy where the majority of the counterfeit clothing products were manufactured, the arrest of 12 suspects and the seizure of 3 million counterfeit items, affecting more than 10 different brands representing a value of more than 150 million euro, across the EU. Besides generating huge profits for the criminals, the illicit actions also fuelled the establishment of black markets, illegal immigrants operating the production centers and knock on crimes such as customs and VAT frauds. In Europol s experience, the main OC entities detected were Chinese groups, the Camorra, expanding from prostitution and drug trafficking to counterfeit consumer goods, Russian criminal organisations and Turkish groups. Connections between Chinese syndicates and Italian Camorra are also apparent in the EU. The new Council Decision establishing Europol 4 has provided the opportunity to strengthen the cooperation between the partners of the Europol network as recently demonstrated by Operation FLASHPOINT, an investigation which has resulted in the seizure of 28 tons of counterfeit pesticides. Despite the fact that customs administrations have made progress in their fight against counterfeiting and piracy, the global volume of seizures relating to counterfeiting in 2009 showed an increase of 127% compared to the figures for These indications clearly show the need for an EU-wide approach to fighting counterfeiting and piracy. Owing to the fact that there have been many operations and initiatives aiming at the physical inspection of overseas container traffic entering the EU, Hungary wishes to highlight the need for enhanced roadside checks by proposing a JCO focusing on clothing, accessories and footwear. 4 OJ L 121, , p /1/10 REV 1 RR/dk 6 DG H 3A LIMITE EN

7 In order to estimate the gravity of the impact of IPR infringements on national economies and the EU as a whole, this TA has been compiled with the help of other relevant sources of information, such as: OECD report Magnitude of Counterfeiting and Piracy of Tangible Products (2009). It highlighted, and confirmed, the findings of this TA (detailed analyses and annexes) that the probability of counterfeiting of textile products is much higher compared to other types of goods, and this is why customs administrations encounter more instances of such counterfeit commodities. WCO Customs and IPR Report (2009) (see above). Commission Staff Working Document IPR Enforcement Report This document emphasised the relevance of IP cooperation between the EU and China, the obvious reason for which is that analysis of seizure data showed that China was the most frequent country of departure and/or origin. The survey carried out for this TA came to the same result taking EUrelated seizures into consideration. Council Resolution on the EU Customs Action Plan to Combat IPR Infringements for the Years 2009 to 2012 (OJ C 71, , p. 1). Recommendations of La Villette of the Customs seminar on the fight against counterfeiting - IPR and the Internet (Paris, 5 October 2010). Europol study Knowledge Product: Intellectual Property Crime IPC (Oct 2010). This study - compiled at the specific request of Hungary for this TA - identified linkages between IP related crimes and organised criminality, and emphasised the importance of Europol AWF COPY in making analyses and providing support for the requesting Member States. Europol has gathered enough intelligence and evidence to prove that organised crime groups are effectively involved in the illicit trade of counterfeit commodities and, to a lesser extent, in piracy. The huge amount of money generated by this illegal activity, added to the low level of penalties or effective prosecutions in this area, has provided criminal organisations with the opportunity to make substantial profits, which in turn support other criminal activities. These include links with illegal immigration, money laundering, smuggling, drug trafficking, corruption and the funding of terrorism. Like the aforementioned studies, the analysis clearly indicates the relevance of Far-Eastern countries in the field of IPR violations, and at the same time warns that probably only the tip of the iceberg is seen, so that law enforcement agencies need to commit to this kind of activity more and more in the future /1/10 REV 1 RR/dk 7 DG H 3A LIMITE EN

8 European Observatory on Counterfeiting and Piracy study Damages in Intellectual Property Rights (2009). In drawing up this study the authors put special emphasis on illustrating the damage done to right holders, and negative impacts on the fair market. The legal consequences of infringements and judicial remedies were also analysed. All members would welcome the harmonisation of legal measures and judicial decisions and the introduction of a unified methodology in the fight against IPR violations. CEN Database (see below in the analyses). V. Former documents taken into consideration - The Stockholm Programme - an Open and Secure Europe Serving and Protecting Citizens (OJ C 115, , p. 1) states that: Counterfeiting poses a serious danger for consumers and economies. The Union must make further studies of this phenomenon and ensure that greater account is taken of law enforcement aspects in the work of the future European Observatory on Counterfeiting and Piracy. 5 - Council Resolution on the EU customs Action Plan to combat IPR infringements for the Years 2009 to 2012 (OJ C 71, , p. 1). - Council Regulation (EC) No 1383/2003 of 22 July 2003 (OJ L 196, , p. 7) concerning customs action against goods suspected of infringing certain intellectual property rights and the measures to be taken against goods found to have infringed such rights. 5 Point 4.4.5, p /1/10 REV 1 RR/dk 8 DG H 3A LIMITE EN

9 Council Decision establishing Europol (OJ L 121, , p. 37), Art. 4(2) states that on a recommendation by the Management Board, the Council shall lay down its priorities for Europol, taking particular account of strategic analyses and threat assessments prepared by Europol. To fulfil these tasks and in response to the Hague Programme, as concluded by the European Council in November 2004, in particular its emphasis on the need for a future-oriented assessment of organised crime to support law enforcement efforts in EU, it was decided that Europol would replace its Organised Crime Report (OCR) with the Organised Crime Threat Assessment (OCTA). Council Conclusions on the basis of the first OCTA were endorsed on 1-2 June The OCTA remains the flagship product of Europol dealing with threat assessment. The CCWP decides on the organisation of joint customs operations targeting areas identified in the OCTA. OCTA 2009 prepared by Europol states that: The manufacturing and distribution of counterfeit commodities constitute a serious problem beyond the financial loss of owners of intellectual property rights and legal enterprises in general. The industrial sectors mostly affected by counterfeiting are music, software, tobacco products, automotive parts, pharmaceutical and chemical products, and clothing. Due to the fact that IP crimes are identified as a serious problem outside the EU as well, various responses have been developed by numerous international organisations. An INTERPOL Intellectual Property Action Group has been formed, and is operating under the umbrella of publicprivate partnership. The core membership of the Action Group consists of representatives from national law-enforcement and customs authorities, international intergovernmental organisations, cross-industry private sector bodies (including market operators such as Microsoft or Procter & Gamble) and patent protection entities. In 2008 the WCO issued its Customs and IPR report, in which it said that: The negative effects of IPR infringements range from threats to public health and safety to loss of government revenues, as well as the huge damage done to legitimate trade and business /1/10 REV 1 RR/dk 9 DG H 3A LIMITE EN

10 VI. Analysis of previous operations As indicated in the TA mandate, it was intended to take into account the experiences and results of previous IPR operations, such as Operation FAKE in 2005, where OLAF provided secure information exchange throughout the V-OCU system. The aim of Operation FAKE was to check containers on air and maritime routes. While this operation took place five years ago, it is considered important to include the experience gained with it in the analysis of the present situation. According to the available data of Operation FAKE, 266 controls were carried out during the operation with support from the V-OCU system, and as a result 59 seizures were made by the Member States /1/10 REV 1 RR/dk 10 DG H 3A LIMITE EN

11 Counterfeit textile industry products and clothing accessories formed a significant part of the seized goods. The infringement was committed against, inter alia, the following brand owners: Adidas, Burberry, Louis Vuitton, Nike, Chanel, Gucci, D&G, Dior. The large numbers of detections proved that JCOs are of real importance, enabling participating Member States to enhance their activity throughout prompt data exchange via the available information system. The aforementioned results called attention to the existing and proved threat to EU finances and economies and to the need to address this threat and curb it to the possible greatest extent. VII. Methodology Since questionnaires are rather time-consuming and have a greater uncertainty factor, it was decided to use the following method for the analysis: The relevant IPR seizure and operational data filed by the Member States and other European countries - were selected from the CEN data system which is provided by the WCO and available for every Member State. These data were analysed to obtain an overall picture of the IPR threat throughout Europe (not only in the European Union: data of all seizures have been taken into consideration, where the involvement of any Member State as country of dispatch, destination, or transit could have been shown). Source of the data: MS Access data file downloaded on 3 September /1/10 REV 1 RR/dk 11 DG H 3A LIMITE EN

12 Selection criteria: date of the case (seizure) between and and the destination country, the origin country or the country which carried out the seizure. Data tables used for the query: t_case, t_ipr, t_conveyance, t_rel_country_continent. It should also be noted that cases falling after the aforementioned date are not included in the present analysis. VIII. General analysis For the sake of manageability of data, the survey period covers a year and a half. Practically, it meant a data row of lines, which were analysed in the widest sense. According to the aforementioned facts it can be generally stated that Europe and the economic and financial stability of the Member States are exposed to increasing damage. This analysis indicates the detection results (frequency, location of the seizure), the main transport routes and transportation methods, the quantity of goods seized and the type of goods broken down by country /1/10 REV 1 RR/dk 12 DG H 3A LIMITE EN

13 Inasmuch as the data were filed in different foreign currencies with varying exchange rates, it was not intended to deal with the value of the quantities seized. Since the filing methods are different in each country, some adjustments were made during the analysis in order to obtain valid results from the available information. The transport methods varied widely, so to facilitate the procedure they were classified in the following categories: Mail (Post, Express Carrier, TNT, EMS, UPS, DHL, FEDEX); Air (Commercial, Other); Vehicle (Vehicle, Truck/Lorry, Car/Passenger van, Trailer truck, Container Lorry, Delivery van, Articulated lorry, Coach/bus, Caravan/Mobile home); Vessel (Commercial, Container Ship, General Cargo, Other, Ferry, Bulk Carrier); Rail; Pedestrian; Other; Unknown. According to the seizure data, searches could be carried out on the basis of various criteria (e.g. information from the police in the Member State, certain Member States on the itinerary, or a certain Member State as destination or departure country, etc.), so the analysis was wide-ranging. Problems of "unknown" and "other" categories of transport methods During the analysis it was noticed that the field "transport modality" of a seizure was not filled in or remained "unknown" or "other". This happened only if the seizure was made by an inland office (possibly during a raid of a market or a store) and no information was available on the actual origin and/or route of the consignment /1/10 REV 1 RR/dk 13 DG H 3A LIMITE EN

14 During the data classification such problems arose, as in France, Poland and Hungary the following number of cases was recorded in those two categories: HU: 2418 FR: 403 PL: 543 The quantities concerned amounted to 16,4% of the total quantity seized, i.e. a significant figure. With regard to Hungary it can be stated that these seizures were performed in inner (city) areas, such as markets or housing estates. Given the specific features of the areas concerned, the goods seized in the 2418 instances in Hungary could only have got to their destination via the public road network, so these seizures could safely be counted as road transport. They were recorded in the "unknown" and "other" categories only because of the special features of the database. Although it was impossible to establish the background to the French and Polish data, similar conditions to those in Hungary were assumed. IX. Detailed analyses 1. Seizure data The seizure data of the countries are presented in Annex 1. According to the figures, almost every Member State reported data on seizures of IPR infringing goods to CEN, so the threat clearly exists and is real. Besides the Member States, more than a dozen non-eu European countries made seizures of goods whose departure, transit and/or destination country was a Member State. These facts underline that not only Member States but all of the European countries are under threat from counterfeit or pirated goods. The seizure data revealed that 8 countries recorded more than 1000 cases, thus carrying out 75% of the total seizures during the survey period. These 8 are countries both with and without seaports, and are both older and newer members of the EU. Taking into consideration the 550 calendar days of the survey period, the arithmetic mean (average) of seizures per day is 37. (The total number of seizures meeting the criteria for CEN reports is ) 15841/1/10 REV 1 RR/dk 14 DG H 3A LIMITE EN

15 2. Transportation methods Annex 2 contains the detailed presentation of the breakdown of transportation methods in the survey period. The transportation methods listed in Point VIII: General Analysis were used and applied in accordance with the clarifications and alterations given under the Point VIII in the assessment work. As regards figures, it was established that the highest number of seizures (6194 cases, 30% of the total) concerned mail (postal service), while road vehicles (4600 cases) and aircraft (4475 cases) came second and third in this imaginary competition. These three transportation methods account for approximately 75% of the total seizures. Due to the variety of different units and measures applied (e.g. piece, pairs, tab, roll, kilogram, etc.), correlations or relations between the number of cases and the quantities detected and seized could not be established. However, if the aforementioned comparison were made, mail as transportation method would be beaten by maritime shipping, which comes out at 15% of the total seizure quantity if seizure numbers are taken into consideration. The typical categories of the seized goods in every transport method were examined. The analyses reveal that it is difficult to precisely assign typical counterfeit goods to typical transport methods, but the most common categories, irrespective of transport method are: textiles and textile articles, accessories, tobacco, phonographic products, footwear, mobile phones and accessories, etc. The breakdown of transportation methods in relation to countries was also examined, and the results are shown in Annex 3. Regarding the categories, the following results were established (concerning exclusively the Member States): Mail: UK 19%, Vehicle: Hungary 61% (including inland seizures), Air: UK 41%, Vessel: Italy 29%, Rail: France 4,5 % /1/10 REV 1 RR/dk 15 DG H 3A LIMITE EN

16 3. Types of seizure locations During the assessment work, the locations of detections and seizures were listed in order of importance. The list is presented and summarised in Annex 4. The facts and figures reveal that 29% of the seizures were carried out in Mail Centres, 24% on inland territories and 23% at airports. These figures accordingly concur with the results of seizure data analysis. 4. Seized goods The types of the seized goods are set out in Annex 5, which requires some further explanation. While the figures were designed applying the breakdown of CEN records, similarly to the presentation of transportation methods collective categories had to be used to facilitate and support data handling and transparency. As an aid to interpreting the figures, an alphabetical table is set out in Annex 5. The assessment based on the collective categories is demonstrated by Annex 6. After studying the annex in detail and examining the breakdown of types of seized goods, it is clear that textiles and textile articles rank highly considering the number of seizures (5301), directly followed by accessories in second place and footwear in fourth, revealing that these three categories total up to 47% of the number of cases. Based on these data and comparison of the number of cases, it can be determined that the main threat is posed by textile industry products and accessories. The country breakdown for detections of textile articles, which may take pride in the highest number of cases in terms of type of goods seized, is given in Annex 7. This assessment resulted in the following conclusion: if seized quantity is taken into consideration, Italy, Romania and the Czech Republic are exposed to the gravest threat and, in line with this conclusion, these Member States proved to be the most successful and efficient countries as regards detection /1/10 REV 1 RR/dk 16 DG H 3A LIMITE EN

17 5. Routes; departure and destination countries Further assessment regarding the most significant groups of textile products among the seized goods is demonstrated by Annex 8. This annex contains two diagrams which, based on the frequency of the recorded routes, reveal the breakdown of seizures by quantity and by number of cases. With special regard to the units of pieces and pairs which were used in the reporting process, these data are shown separately. Both figures prove that those routes where departure country is unknown top the lists. In terms of quantity seized, Italy is awarded first place; conversely, in terms of number of cases, Hungary wins the gold medal, although, it has to be said that the quantity seized is not as high in this comparison as in the case of Italy. In terms of number of cases, the most important routes are "unknown"-hungary, "unknown"-poland, China-Spain, "unknown"-uk and China-France; conversely, the most significant routes in terms of quantity seized are "unknown"-italy, China-Romania-Ukraine, China-Spain, China-Italy and China- Germany-Czech Republic. Besides the above assessments on textile products, a general analysis was made of departure, destination and transit countries as well. The conclusion of this general analysis, which took into consideration only countries having reported more than 100 cases, is presented in Annexes 9, 10 and 11. Among the departure countries, China took first place, in front of unknown, with India, Hong Kong and Turkey coming in third, fourth and fifth. In terms of destination countries, UK is top, followed by Hungary, France, Spain and Italy. The order for transit countries is as follows: "unknown", the Netherlands, Germany, France, Hungary /1/10 REV 1 RR/dk 17 DG H 3A LIMITE EN

18 X. Conclusion Based on the assessment detailed and explained above, the project does not seem to have been absolutely successful in terms of further defining the degree of threat to which the different transportation methods are exposed, but it can firmly be declared that, irrespective of quantity, the most significant proportion of seizures are made in the case of mail, vehicle, vessel and air transportation. Taking into consideration the fact that in recent years a number of successful JCOs have been carried out targeting maritime container smuggling (JCO SIROCCO, JCO DIABOLO I and II), the topic of IPR could usefully, advantageously and beneficially be mapped and broadened by enhanced control on vehicle (road) transportation, with particular regard to and targeting of those types of textile industry products and accessories which emerge most significantly from the assessed seizure data. XI. Recommendations A JCO aiming at the subject detailed above (IPR) and organised within the framework of CCWP is proposed, to be carried out with the participation of every Member State, invited third countries and international organisations in spring Taking into account the fact that a number of successful JCOs have been carried out targeting maritime container smuggling, the proposal focuses on vehicle (road) transportation. With regard to the assessed and presented seizure data, enhanced control on vehicle (road) transportation should include not only BCPs but inland territories as well, where mobile control units (if such units are available) should carry out intensified control activities. More frequent and increasing application, use and utilisation of the analysis and coordination capacities of Europol are highly recommended. It is suggested that Europol (AWF COPY) become the focal point for national threat assessments and risk analyses being prepared on IPR subjects. It is recommended to enhance cooperation with the European Observatory on Counterfeiting and Piracy, the agency responsible for the effective utilisation of synergies from cooperation between the public and the private sector (such as right holders and consumers) /1/10 REV 1 RR/dk 18 DG H 3A LIMITE EN

19 Training, seminars, courses and programmes, also aiming at exchange of experience, should be organised with the involvement and participation of right owners in order to ensure that the employees of the authorities taking a significant part and playing key roles in the fight against counterfeit and pirated goods acquire adequate and appropriate qualifications and experience in international cooperation. The Customs Administrations of all the Member States should be encouraged to make increased use of the WCO's CEN database, the European Statistical Information, the Customs Information System and the RIF-system, and recommend regular monitoring of the quality of the input data and the discipline of the input process /1/10 REV 1 RR/dk 19 DG H 3A LIMITE EN

20 ANNEX /1/10 REV 1 RR/dk 20 ANNEX 1 DG H 3A LIMITE EN

21 ANNEX /1/10 REV 1 RR/dk 21 ANNEX 2 DG H 3A LIMITE EN

22 ANNEX /1/10 REV 1 RR/dk 22 ANNEX 3 DG H 3A LIMITE EN

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28 ANNEX 5 Pieces / type type Total Textiles and textile article-other - Specify 1601 Other - Specify 1522 Textiles and textile article-shirts 1513 Pharmaceutical Products - Medicine-Viagra 1322 Watches-Watches 1192 Accessories-Other - Specify 1170 Pharmaceutical Products - Medicine-Other - Specify 996 Footwear-Sportsshoes 827 Electronical appliances-other - Specify 758 Footwear-Shoes 588 Accessories-Handbags 501 Mobile phones and accessories-mobile phones 495 Electronical appliances-nintendo 462 Toilettries/cosmetics-Perfume 448 Textiles and textile article-underwear 447 Textiles and textile article-trousers 429 Textiles and textile article-track suit 411 Phonographic products-dvd films 394 Games and toys-toys 388 Accessories-Jewellery 362 Accessories-Belts 322 Toilettries/cosmetics-Other - Specify 313 Accessories-Sunglasses 234 Textiles and textile article-socks 232 Games and toys-other - Specify 212 Computer accessories-other - Specify 206 Textiles and textile article-caps 203 Mobile phones and accessories-other - Specify 201 Mobile phones and accessories-batteries 177 Games and toys-games 177 Mobile phones and accessories-covers 172 Mobile phones and accessories-accessories 169 Spare parts-vehicles 146 Footwear-Boots 143 Toilettries/cosmetics-Make-up 138 Textiles and textile article-shorts 129 Computer accessories-software 117 Textiles and textile article-household articles (towels, bedsheets etc) 110 Textiles and textile article-dress 106 Computer accessories-hardware 106 Phonographic products-dvd RW /1/10 REV 1 RR/dk 28 ANNEX 5 DG H 3A LIMITE EN

29 Beverage-Alcohol 97 Textiles and textile article-suit (jacket and trousers) 95 Phonographic products-music CD 78 Mobile phones and accessories-telephone bags 77 Footwear-Other - Specify 77 Tobacco-Other - Specify 64 Phonographic products-cd-r 64 Foodstuff 57 Accessories-Rucksacs 49 Phonographic products-other - Specify 49 Electronical appliances-playstation 27 Textiles and textile article-skirts 25 Electronical appliances-x-box 20 Computer accessories-cartrigdes 19 Watches-Other - Specify 15 International Sport Events-European Championsship - Football 12 Spare parts-other - Specify 12 Tobacco-Cigarettes 11 Toilettries/cosmetics-Hair care 9 Watches-Part of watches 8 Furniture 8 Electronical appliances-photo camera 7 Toilettries/cosmetics-Lotions 7 International Sport Events-World Championsship - Football 6 Beverage-Soft drink 6 Phonographic products-divx 4 International Sport Events-Other - Specify 2 Phonographic products-video tape (empty) 2 Electronical appliances-gameboy 2 Phonographic products-vcd 2 Phonographic products-audio cassettes 1 Electronical appliances-video camera 1 Spare parts-vessels 1 Spare parts-motorcycles 1 Pharmaceutical Products - Medicine-HIV/AIDS 1 Total /1/10 REV 1 RR/dk 29 ANNEX 5 DG H 3A LIMITE EN

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