Unit 2
WTO Accession and System Building of Shanghai
The accession of China to the World Trade Organization (WTO) ushered in an institutional revolution in its government administrative regimes. The institutional revolution displays itself mainly in sweeping structural reforms based on the rule of law in the governance regimes, at the national as well as at the sub-national level, so as to bring government conduct in every aspect in line with the framework of WTO rules. The strategic adjustments in administrative regimes and governmental functions are not only an essential part of fully implementing China’s WTO accession commitments, but also a significant step in seizing the opportunities and meeting the challenges of international competition following China’s entry into the WTO.
A highly-centralized economy in the past, China’s government once played a decisively pivotal role in running the economy, and Shanghai used to be held as the country’s model in the planned economy. Reforms in restructuring the national economy have gradually been deepened over the past two decades or so, and Shanghai has come to the fore in China’s process of reform and opening up to the outside world since the 1990s, unremittingly exploring and trying out ways in aligning its economic mechanisms with international practices. Nevertheless, Shanghai as well as China are still a transitional economy tinged with traces of its former planned economy, and the country’s economic regimes, mechanisms and governance are still, in many respects, incompatible with WTO rules.
For the past three years since China joined the WTO, historic changes have taken place in Shanghai’s institutions. Transparency in the legislative, executive and judicial branches has been markedly improved, market supervision and administration increasingly normalized, protection of intellectual property rights further strengthened, and the pace of bringing domestic technical standards in line with international standards noticeably accelerated. While advancing trade liberalization, Shanghai is, at the same time, endeavoring to establish an effective working mechanism to protect fair trade and safeguard the legitimate rights and interests of Chinese firms. It should be particularly noted that in regard to institutional reforms, Shanghai is working unrelentingly to develop various trade associations and promote trade facilitation, both of which do not directly come under China’s WTO commitments. It is, therefore, quite safe to say that rather than passively fulfill its WTO obligations, Shanghai has constantly taken the initiatives to align itself with the norms of international market economy, to improve its business environment through institutional innovations, and to build a more modernized metropolis.
Chapter 3
Transparency in the Government and Reforms in the Administrative Regime
The transparency principle of the WTO is designed to enhance and ensure the stability and predictability of the economic regimes and economic governance on the part of its member countries, to check and eliminate policies of discriminatory treatment as well as substantial barriers to international free trade produced by non-transparency in the administrative conduct of its members, and to monitor and guarantee the full compliance of WTO rules by its member governments.
WTO’s principle of transparency in the government has become a strong external catalyst in enabling the enhancement of transparency in China’s administrative behaviors, an excellent point of breaking through the deeply-entrenched systematic barriers constraining government functions, and a solid foundation for the overall improvement of the effective functioning of the government.
In 2004, municipal government departments and agencies at all levels in Shanghai have made remarkable progress in implementing the Law of the People’s Republic of China on Administrative Licensing and the State Council’s Enforcement Guidelines in Promoting Rule-based Government through making public various government-related information and reviewing and filing on record normative government documents. This has not only greatly improved the transparency in the administrative behaviors in compliance with China’s WTO commitments, but also provided necessary conditions for deepening the reforms in government functions in the years to come.
I. WTO’s Transparency Principle and the Strive for an Open Government
The transparency principle, a cornerstone of WTO rules, requires that its member countries publish and implement in a uniform, fair and reasonable manner all the laws, regulations and other measures pertaining to and affecting trade. Therefore, in accordance with WTO rules, China should further promote transparency in all the spheres of the government functioning, thereby shifting from a secretive government to an open one.
1. The publication of laws and policies. In compliance with the WTO principle of transparency and China’s WTO accession commitments, transparency should be taken into account in the process of enacting new laws, regulations and other measures. (1) In order to prevent discrimination as a result of non-disclosure of trade policies, all the laws, regulations and other measures pertaining to or affecting trade should be published in a timely manner in a designated official journal, and an enquiry point should be established or designated to provide policy consulting services to any individual, enterprise or WTO member. (2) After the publication of any law, regulation and other measure pertaining to or affecting trade, a reasonable period of time should be provided to all those concerned for comment to the appropriate authorities before they are implemented, except for those involving national security and those the publication of which would impede law enforcement.
2. The transparency of administrative procedures. Efforts should be made in enhancing the transparency of day-to-day government functioning. On the one hand, the process of decision-making on the part of the government should be open and transparent, democratic and scientific. On the other hand, all the government conduct should be based on the rule of law, and no under-the-table deals should be tolerated. In the meantime, the pace of formulating a law regarding administrative procedures should be quickened, and those systems concerning the disclosure of government affairs, public hearing, accountability, time limit, information enquiry and consultation should be established.
3. The normalization of administrative examination and approval. The system of government examination and ratification should be reformed to ensure its openness and fairness. (1) Unnecessary and excessive administrative examination and approval should be abolished so that the number of matters subject to examination and approval could be trimmed. (2) Those matters that still come under government examination and approval should be reviewed on a case-by-case basis and placed under administrative examination and approval, when necessary and appropriate. (3) An effective administrative examination and approval system, including the procedures system and the monitoring system of examining and approving, should be introduced and improved in the due course. The legal basis of administrative rights in examination and approval should be clearly defined, and sound procedures of examination and approval should be established and strengthened. Matters subject to examination and approval should be explicitly designated, procedures of examination and approval simplified, time limit to complete examination stipulated, conditions for granting approval specified, and transparency in examination and approval increased. In a word, administrative examination and approval should be normalized, systematized and rule-based. In addition, accountability and monitoring systems of examination and approval should be established correspondingly so that those who have, in any way, violated the pertinent laws in the process of examination and approval could be brought to justice. Everything concerning administrative examination and approval such as applicants, items, conditions and procedures should be made readily available to the public, and mechanisms of market competition, checking and monitoring should, whenever possible, be introduced into the process of examination and approval, thus creating an administrative examination and approval system based on strict procedures and adequate monitoring, openness and fairness.
II. The Implementation of the Administrative Licensing Law in Normalizing Government Conduct
After the Law on Administrative Licensing was passed and promulgated by the Standing Committee of the Tenth National People’s Congress on August 27, 2003, the implementation of the new code has topped the 2004 agenda in Shanghai’s municipal departments and agencies. A work group headed by Shanghai’s mayor has been set up for the implementation of the law in the city, and to the same end, a coordinating group between the municipal congress and the municipal government has also been established. Because of all the full preparatory work, the law has been enforced in an orderly and smooth way in Shanghai since it took effect on July 1, 2004.
The review and clean-up of administrative licensing items is a key task in the preparation for implementing the law. With a view to speeding up the changes in government functions through the implementation of the law, administrative licenses have been either adjusted or cancelled, licensing procedures have been simplified, and governmental bodies granting licenses have been streamlined. Altogether, 1,242 administrative licenses have come under review, among which 1,039 licenses (83.7%) were set by national legislations and regulations and 203 licenses(16.3%) by local laws and regulations.
Of the total 203 administrative licenses set by local legislations and regulations, 102 licenses have been nullified, accounting for 50.2% of all the locally established licenses, among which 36 licenses were set by local laws and 66 by government regulations. Among the 101 administrative licenses that have been retained, the overwhelming majority were established by local laws and only 12 licenses were set by government regulations. The 36 items that were required licensing in accordance with the local laws but have been rescinded were deemed either against the principle of legality or against the principle of rationality.
Those administrative licenses that were considered against the principle of legality and hence revoked refer to any of the following four cases where local licensing has now been restricted in the new Administrative Licensing Law.
1. Qualification certificates or permits for individuals or enterprises that should be issued by the State. Ten items fall into this category, such as the certificate for engaging in psychological health counseling services, the certificate for engaging in recreation and entertainment services, the certificate for conducting energy-saving inspection and examination services, and the permit for organizations to accept the donation of corpse for medical research.
2. Registration of the set-up of enterprises or other entities and their prior licensing. Two items come under this category, such as the examination and approval prior to the opening of companies or businesses under individual ownership that manufacture or sell funeral articles.
3. Licenses aimed at restricting companies or individuals from other areas to provide services in Shanghai or restricting the market access of products made elsewhere to Shanghai. Nine items belong to this category, such as the license granted to construction companies from other parts of the country to conduct business in Shanghai, the license to employ staff from areas other than Shanghai, and the license to use construction materials for municipal construction projects.
4. Licenses established in addition to those stipulated in the upper-order laws. Three items are in this category, such as the permit to the postponement of cremation.
Those administrative licenses that were considered to run counter to the principle of rationality and, therefore, terminated refer to any of the four cases stated below: those matters that could be effectively regulated by market competition, such as the permit to engage in container yard operation; those matters that could be subsequently supervised, such as the license to hang items from trees along public roads; those licenses that have already been abolished by the State Council or that have ceased to be enforced in Shanghai, such as the permit to public order in renting and leasing houses.
Out of the 1,039 administrative licenses set by the State, 109 licenses have been retained in Shanghai. Administrative licenses instituted by the regulatory documents of municipal government bodies at all levels have also been reviewed and cleaned up. According to recent incomplete figures, 13 district or county governments have decided to cancel 118 licenses, and 41 municipal government departments and agencies have decided to abolish 103 licenses.
While abolishing a large number of administrative licenses in accordance with the law, due attention has been accorded to the role of market in resources allocation and the shifts of government functions from management to service and guidance. Specifically, four adjustment measures have been adopted.
1. After the abolition of licenses, the management system of filing on record relevant information has been introduced so as to facilitate ex-post supervision and process monitoring. For example, after the license to sell gas kitchen utensils and the license to use construction materials for municipal construction projects have been stopped, the enterprises should file relevant information in advance to the competent authorities. After the permit for first-aid medical institutions to collect blood on a temporary basis was abolished, they are required to file relevant information afterwards to the public health authorities.
2. Activities formerly subject to licensing have now become forbidden. For example, schools and teachers are prohibited from arranging students for any activities not related to education, and the competent authorities should not grant approval for such activities.
3. New and existing laws and regulations should be applied, whenever appropriate. The permit to auction firms to sell confiscated items by auction has been abolished, and confiscated items are to be sold at auction in accordance with relevant stipulations in the Auction Law. After the licenses to shoot movies and television dramas in Nanjing Road were revoked, such matters now come under the relevant regulations governing the use of urban roads.
4. Opinions should be solicited between and among government bodies concerned so as to streamline licensing procedures. For example, after the permit for construction work for the upkeep of the People’s Square was rescinded, relevant government bodies should consult the People’s Square Management Office prior to conduct any construction in the area.
Government bodies vested with the right to grant licenses have also be reviewed. At present, 205 government bodies at the municipal level and 837 government bodies at the district and county levels have been confirmed to have the authority to grant various licenses, the names of which have been made known to the public in Government Bulletins and the portal website www.shanghai.gov.cn.
It should, however, be pointed out that the implementation of the Administrative Licensing Law is a long-term task. In the process of the enforcement of the law, Shanghai should strive to build a service government, an accountable government and a rule-based government.
1. Through the disclosure of government-related information, the transparency of administrative conduct should be increased, and the right of the public to be informed and to oversee public affairs should be protected, thereby ensuring in a systematic way the openness, fairness and equity in the exercise of administrative discretion in establishing and awarding licenses. All matters concerning administrative licensing should be made readily available to the general public, such as items requiring licenses, legal basis of licensing, application materials, conditions, procedures and time limit for granting licenses.
2. Through the implementation of the State Council’s Enforcement Guidelines in Promoting Rule-based Government, all government conduct should be strictly based on the relevant laws, and substantial breakthroughs should be made in adjusting government functions. On the basis of the principle of legality and rationality and the principle of supervision and accountability, structural reforms should be pushed forward, clearly defining the power of the government and the way to rightfully exercise the power, and ensuring the link of power and responsibility and the de-link of interest from power.
3. Through the deepening of reforms in the municipal administrative licensing, the number of items subject to licensing should be further trimmed, the procedures of licensing simplified, and the awarding of licenses normalized, thereby increasing the efficiency of the government functioning and providing convenience to the general public.
Box 3.1 Government-Enterprise E-mail Service Launched in Shanghai
To strengthen the ties and interaction between the government and the enterprises in Shanghai, to provide a convenient and easily accessible channel between them, and to improve government services to enterprises, the municipal government of Shanghai has launched its enterprise services e-mail on the portal site www.shanghai.gov.cn. The services currently available to the enterprises include:
|
Serial No. |
Government Bodies |
Services |
|
1 |
Municipal Economic Commission |
Notice of the Application of New Patented Products |
|
2 |
Municipal Economic Commission |
Notice of Key Industry-related Scientific and Technological Projects |
|
3 |
Municipal Economic Commission |
Enterprise Survey |
|
4 |
Municipal Economic Commission |
Notice of Temporary Measures on Electricity Consumption |
|
5 |
Municipal Economic Commission |
Information on Economic and Trade Cooperation between Shanghai and Hong Kong |
|
6 |
Municipal Economic Commission |
Notice of Certification of New Products |
|
7 |
Municipal Economic Commission |
Notice of Certification of Enterprise Centers |
|
8 |
Municipal Economic Commission |
Notice of Strengthening Food Safety in Holiday Seasons |
|
9 |
Municipal Economic Commission |
Annual Report on Industrial Development |
|
10 |
Municipal Economic Commission |
Annual Report on Commerce Development |
|
11 |
Municipal Finance Bureau |
Notice of Annual Examination of Tax Registration |
|
12 |
Municipal Finance Bureau |
Notice of Annual Examination of Foreign Invested Enterprises |
|
13 |
Municipal Finance Bureau |
Notice of Delivery of Financial Statements |
|
14 |
Municipal Finance Bureau |
Notice of Annual Examination of General Tax Payers |
|
15 |
Municipal Finance Bureau |
Notice of the Period for Tax Declaration |
|
16 |
Municipal Finance Bureau |
Reminder Notice of Tax Declaration and Payment |
|
17 |
Municipal Finance Bureau |
Receipt of Electronically Transmitted Tax Declaration |
|
18 |
Municipal Finance Bureau |
Electronic Version of Tax Law |
|
19 |
Municipal Finance Bureau |
Publication of New Policies |
|
20 |
Municipal Commission for Foreign Economic Relations and Trade |
Publication of Laws, Regulations and Policies |
|
21 |
Municipal Commission for Foreign Economic Relations and Trade |
Notices and Announcements |
|
22 |
Municipal Commission for Foreign Economic Relations and Trade |
Notice of the Results of Requested Matters |
|
23 |
Municipal Commission for Foreign Economic Relations and Trade |
Electronic Magazines |
|
24 |
Municipal State-owned Assets Supervision and Administration Commission |
Notice of Annual Declaration Software Download |
|
25 |
Municipal State-owned Assets Supervision and Administration Commission |
Notice of Annual Examination of State-owned Assets |
|
26 |
Municipal Administration of Industry and Commerce |
Notice of Annual Examination of Enterprises |
|
27 |
Municipal Bureau of Quality and Technical Supervision |
Notice of Annual Examination of Organizational Code |
|
28 |
Municipal Bureau of Quality and Technical Supervision |
Notice of Application of Famous Brand Products |
|
29 |
Municipal Bureau of Quality and Technical Supervision |
Notice of Delivery of Quality Data |
|
30 |
Municipal Bureau of Quality and Technical Supervision |
Service on Standardization |
|
31 |
Municipal Bureau of Quality and Technical Supervision |
Notice of Review of Measurement Certification |
III. The Implementation of the State Council’s Enforcement Guidelines in Promoting Rule-based Government
In accordance with the Enforcement Guidelines in Promoting Rule-based Government issued by the State Council on March 22, 2004, the Shanghai municipal government put forward Suggestions on Implementing in Shanghai the State Council’s Enforcement Guidelines in Promoting Rule-Based Government in order to experiment specific ways to build a rule-based government.
The State Council’s Enforcement Guidelines stated the guiding thought, specific principles and demands, as well as major tasks and measures in the next ten years on how to base all government conduct on law, whereas the municipal government’s Suggestions on Implementing the Enforcement Guidelines, within the framework of the Enforcement Guidelines and on the basis of historical backgrounds and specific situations of Shanghai, enumerated ten tasks and measures to be completed before the expiry of the tenure of the present municipal administration in 2007 for the purpose of building an accountable government, a service government and a rule-based government. To proceed step by step and to ensure efficiency, each of the ten tasks and measures focuses on one aspect of institutional reforms. For example, the implementation of the Administrative Licensing Law is aimed at promoting and speeding up the transformation of government functions, governance regimes and management means; the disclosure of government-related information is designed to strengthen the construction of rule-based government.
IV. The Disclosure of Government-Related Information
The Municipal Regulation on the Disclosure of Government-related Information was promulgated by the municipal government of Shanghai on January 20, 2004 and ran into effect on May 1, 2004. So far, preliminary results have been achieved as the disclosure of government-related information proceeds smoothly.
To promote the disclosure of government-related information, a joint committee headed by a vice mayor has been established and involves ten relevant municipal government departments and agencies. The Municipal Information Commission is designated as responsible for the organization, guidance and advancement of the disclosure of government-related information. The tasks of every district and county government as well as every municipal body have been specified. Fifteen government departments responsible for education, real estate, civil affairs administration, industrial and commerce administration, personnel, public security, public health, labor welfare and so on are the key government bodies whose information should be made readily available to the general public, as these government departments receive the most attention of the public, relate directly to the well-being of the public and exercise immense power. As for the categories of government-related information, all government departments should disclose information in a timely manner to the public and disclose information in full upon request. In particular, information concerning management norms, development planning, the use and management of public funds, personnel, draft decisions or any other information which affects greatly the livelihood of the public should be made readily available to the public. Due attention has been paid to the media used for the disclosure of government-related information so as to ensure equal access to the information. All kinds of media, such as government bulletins, press conferences, government websites, public reference rooms and posters, have been utilized for the disclosure of government-related information so as to better serve different types of target audience. In addition, one-stop information service has been established in the Government Information Search-and-Read Center in the new municipal archives office.
By the end of October, 2004, up to 7,921 items of government-related information have been made public by the 15 key government bodies, among which 7,669 items have been made available by the government agencies and 252 items have been disclosed upon request. A total of 3,210 requests of information have been received, 90% of which have been fully or partially met. Since May 1, 2004, enquiries on the disclosure of government-related information made by telephone or in person have reached 180,000 person-time, and visits to the government web page of information disclosure have stood at 53 million person-time. The public has generally expressed great satisfaction in and placed high expectation on the disclosure of government-related information. In addition to the 15 departments, other government departments and agencies have, as from May 1, 2004, also undertaken the task of information disclosure, cataloging information to be disclosed and receiving requests for information. It could be said that a working mechanism for information cataloging, verification, disclosure, requests, monitoring and review has already taken shape, which provides a favorable condition for further disclosure of government-related information.
Box 3.2 Full Disclosure of Government-related Information in Shanghai, the Text of Which is Also Available on the Internet
By November 1, 2004, government departments and agencies at all levels in Shanghai have completed the cataloging of government-related information. The public has access to the government-related information through various channels on and off the Internet.
Government-related information is easily available on the portal website www.shanghai.gov.cn, the websites of various municipal government departments and the websites of all the districts and counties in Shanghai. In addition, government-related information is also available in the Government Information Search-and-Read Center in the new municipal archives office (No. 9, Zhongshan East No. 2 Road) near the Bund.
Shanghai residents can subscribe electronically to the kind of government-related information according to their specific choices through applying for and registering a special e-mail account known as the Shanghai Residents E-mail (or Shimin Xinxiang) at www.smmail.cn.
The Shanghai Residents E-mail is a real-name electronic mail system formally launched by the Shanghai municipal government on August 18, 2004. Different from other e-mail services, the Shanghai Residents E-mail can, apart from receiving and sending e-mail, provide all kinds of information closely related to the lives of Shanghai residents, for example, the record of the payment of “four funds” (old-age pension fund, medical insurance fund, unemployment insurance fund, and housing common reserve fund), public utilities bills, statement of account of credit cards, reminder of personal credit, notice of fines for violating traffic rules of automobiles, and government bulletins. The Shanghai Residents E-mail, which provides an easy and safe access to personal and government information and an important way of identification in electronic businesses, has become a key crossing bridge between the public and the government.
V. The Filing on Record and Reviewing of Normative Documents
To strengthen the filing on record and reviewing of normative administrative documents facilitates the normalization of abstract administrative behavior on the part of the government. Over the past several years, Shanghai has established and improved the mechanism of making, putting on files and reviewing normative administrative documents so as to rectify in a timely manner inappropriate and illegitimate normative documents.
The Municipal Regulation on Drawing up and Filing on Record Normative Documents was issued on December 28, 2003 and went into effect on May 1, 2004. The Municipal Regulation provides specific stipulations on normalizing the processes of formulating and putting on record normative documents.
1. Severely restricting the drawing up of normative documents. The Municipal Regulation places more rigid conditions on drawing up normative documents. (1) To reduce the number of government bodies that have the authority to issue normative documents. The General Office of the Shanghai Municipal Government, the district and country general offices, subdistrict offices, as well as district and county government departments directly under the municipal government have all been barred from making any normative documents. Those government departments and agencies that have been entitled to issue normative documents should exercise their power within the limits of relevant laws and regulations and shall not in any case exceed the boundaries of their authority. (2) To review all drafted normative documents. All the normative documents should clear the process of review by relevant authorities. Normative documents drawn up by district and county governments should be sent to their respective executive meeting for review and decision; normative documents drafted by municipal, district and county departments and agencies as well as township governments should be reviewed and decided by their respective general meeting. (3) To delimit the contents of normative documents. No normative documents shall establish administrative licensing, administrative punishment and penalty, mandatory administrative measures, administrative fees, or any other items that should be established by laws and regulations or authorities at the higher level. Specific enforcement regulations in the implementation of laws and regulations should not create additional obligations on the part of citizens, legal entities or any other organizations and should not restrict in any way the lawful rights of citizens, legal entities or any other organizations.
2. Establishing the mechanism of putting normative documents on files. The Municipal Regulation has put in place a stringent system of filing on record normative documents for the review by higher authorities, namely, “three levels of government and two ranks of filing on record.” The filing on record of normative documents is designed to strengthen their full and overall review on the basis of their legality and rationality. For this purpose, every normative document should be filed on record, reviewed, commented and rectified, if and when any mistakes are found. Normative documents which run counter to the prevailing laws or are, in any other way, found to be inappropriate should be withdrawn or adjusted; only those that satisfy all the criteria will be approved to be filed on record.
3. Fully protecting the right of the public to be informed and to be heard. The Municipal Regulation makes it clear that no normative documents should be enforced before they have been made readily available to the public. Drafted normative documents should be published on government bulletins and government websites for comment from the public. In addition, the public also have access to drafted normative documents in archives office and government offices. Anyone can make written comments or suggestions on normative documents to the drafting government bodies or to other authorities which should handle the matter accordingly.
To implement the Municipal Regulation to the full, the Working Norms on the Filing on Record and Reviewing of Normative Administrative Documents was drawn up and issued by the municipal government, in which the reviewing mechanism is clarified, the responsibility of government departments defined, and the process of filing on record normative documents specified.
From May 1 to October 15, 2004, the Shanghai Municipal Legal Affairs Office has received a total of 54 normative documents, among which 14 documents are from district and county governments, accounting for 26%, and 40 from municipal government bureaus and agencies, making up the rest 74%. In addition, one written suggestion on normative documents has also been received from a Shanghai resident. In the end, 20 normative documents have been approved to be filed on record (among which 5 documents were accompanied by the Legal Affairs Office’s suggestions for improvement, and 2 documents were modified by the drafting government organs in the process of review), accounting for 83% of the processed normative documents; 3 normative documents have been sent back for rectification, making up for 13% of the processed normative documents; 1 normative document has been rejected, accounting for 4% of the processed normative documents. As for those normative documents that go against existing laws or are in other ways inappropriate, -- for example, in the drafted Regulation on the Protection of Running Water Sources at the Water Intake submitted by a district government, water sources protection area is arbitrarily decided, which goes against the Law of the People’s Republic of China on the Prevention of Water Pollution, -- the drafting government body is instructed to have them rectified and report their rectifications. As for those normative documents in which minor defects have been found, pertinent suggestions are made while approval is granted for them to be filed on record.
A number of encouraging results have been achieved since the mechanism of putting on files and reviewing normative documents was initiated.
1. Constant improvement in the mechanism of filing on record and reviewing normative documents. Since the Municipal Regulation was issued, district governments such as Jing’an and Jingshan, as well as municipal government departments and agencies such as the Municipal Civil Affairs Administration and the Municipal Information Commission have, in light of their own specific situations, formulated corresponding measures to improve the process of drawing up and filing on record normative documents.
2. Noticeable decline in the number of normative documents. According to incomplete figures over the past few years, 1,610 normative documents were issued in 2001 by district and county governments as well as by municipal government departments and agencies, 1,380 normative documents in 2002, and 1,103 in 2003. In stark contrast, for the past half year between May 1 to October 15, 2004, only 54 normative documents have been submitted for review by district and county governments and municipal government bodies. Taking into account those normative documents that are being drawn up and have not been submitted for review, the normative documents in 2004 probably will total around 100, a very significant decrease in number.
3. Marked improvement in the quality of normative documents. The role of review by the legal affairs office has been increasingly strengthened in the process of drawing up normative documents. Many normative documents that fail to meet the standards have been rescinded in the process of review by the legal affairs office, and now many government departments and agencies actively seek the opinions of the legal affairs office at the higher level during the whole process of drawing up normative documents.