China joined the World Trade Organization (WTO) in December 2001. The first ten years after China’s WTO accession suggest that the country has achieved greater progress in achieving compliance in some sectors than others.1 One of the most problematic sectors in the accession negotiations, both at the bilateral level (particularly with the European Union and the United States) and at the multilateral level (through the Working Party for China’s accession based at the WTO headquarters in Geneva) was telecommunications services. There was wide expectation that telecommunications services would pose many challenges to China’s WTO compliance. Surprisingly, no telecom-related case has been launched against China under the WTO dispute settlement mechanism (DSM) so far. However, after a decade in the WTO, China has not issued any license for basic telecommunications2 joint ventures and has approved very few value-added joint ventures.3 This indicates that WTO Members were either not interested in obtaining licenses for the Chinese market or were not successful in obtaining licenses. However, when one considers the pressure telecommunication companies have exerted on their governments to open up China’s telecom market in the accession negotiations, the former seems unlikely.4 The discussions in the Trade Review Mechanism (TRM) and Trade Policy Review (TPR) further suggest that although foreign companies generally view the Chinese telecommunications market as a lucrative one, they remain uncomfortable investing in the Chinese market and have also been unsuccessful in obtaining the required licenses post-accession. As such, assessments of China’s compliance behavior in this sector should take into consideration not only China’s performance under the DSM, but also the TRM and TPR reports which provide an indication of Members’ grievances with China’s compliance record to date.5 Article 18 of China’s Protocol of Accession sets up the TRM whereby

Those subsidiary bodies of the WTO which have a mandate covering China’s commitments under the WTO Agreement or this Protocol shall, within one year after accession and in accordance with paragraph 4 below, review, as appropriate to their mandate, the implementation by China of the WTO Agreement and of the related provisions of this Protocol.6