Dear Secretary General Mikuriya
The WCO Data Model – The Need for a Change in Policy
I write this open letter on behalf of my company, Illumonus LLC, and also on behalf of many others software companies (global and niche), traders, standards experts and, informally, members of customs authorities who have expressed serious concerns to me or to my colleagues concerning the WCO’s current highly restrictive policy regarding the dissemination and potential use of the WCO Data Model.
I also write with considerable experience of trade facilitation and international standards, and of the WCO’s past very positive role in contributing to them, having been one of the leaders of the UN/EDIFACT and ebXML standards developments, as well as for many years a senior Vice<Chairman of UN/CEFACT.
Previously, WCO has made an unquestionable commitment to the development of open, interoperable standards. This commitment, as you will recall, was a core element in the championing by WCO of open standards as being the raison d’etre for the whole of its data model development.
The results from this position have been superbly successful worldwide. However, the adoption of the current sales and publication policy of the Data Model has, in our view, detrimentally changed the view of many regarding the WCO’s commitment to these open standards.
Leaving aside what many consider the associated, but separate, issue of the exorbitant price being charged for the Data Model, the intellectual property rights restrictions in place within the current publication and use policy of the Data Model are having a very negative effect on its wider global uptake.
This is more than disappointing given that the Model is an important standards development tool incorporating much work contributed by other organisations and experts that could, if made widely and freely available, make a real breakthrough in interoperability. Further, the current restrictive policy also brings into issue the question of the proper ownership of the intellectual property in this data incorporated in the Data Model.
Given these concerns, it is the view of Illumonus that the Data Model will never achieve its true potential until the WCO rescinds its current policy.
Therefore, I urge you and your colleagues to reconsider the current usage and pricing policies and adopt a truly open and non–restrictive policy to facilitate the widest possible use of the Data Model.
In our view that will be in the best interests of WCO, its members, all members of the international trade community, and the world’s standards developers and implementers generally.
A copy of this letter goes to the Directors General of Customs (or their equivalents) in the USA, UK, Belgium, The Netherlands, Luxembourg, and Japan, these all being countries or trade areas where Illumonus has a presence.
Ray Walker OBE
Vice President eBusiness Development
Brussels, 7 September 2011.