Foreign Trade Statistics
National Statistical Institute
|Contact organisation unit|
Foreign Trade Statistics Department
|Contact person function|
Head of Department
|Contact mail address|
2, P. Volov Str.; 1038 Sofia, Bulgaria
|Contact email address|
|Contact phone number|
+359 2 9857 653
|Contact fax number|
|Metadata last certified||26 November 2014|
|Metadata last posted||26 November 2014|
|Metadata last update||26 November 2014|
Foreign trade in goods covers the trade with third countries (Extrastat) and with the Member states of EU (Intrastat).
Imports/arrivals include all goods entering the statistical territory of the Republic of Bulgaria from other countries and are for consumption in the country, for processing in the country with the purpose to be exported/dispatched to another country after processing, and also imports/arrivals of goods after processing outside the country.
Exports/dispatches include all goods leaving the statistical territory of the Republic of Bulgaria and are for normal export to another country. It covers also goods returned to the trade partner after processing in Bulgaria or exported/dispatched goods sent for processing in another country in order to be returned back to the Republic of Bulgaria.
Statistical data on imports and exports do not include imported goods placed under the customs warehousing procedure without processing, and in exports - re-exports of these goods.
Foreign trade statistics does not cover the transit of goods through the territory of Bulgaria.
The main sources of information are:
· Single Administrative Document completed by all entities engaged in import or export of goods from/to third countries;
· Intrastat declarations for arrivals and dispatches of goods from/to countries of the European Union;
Customs Agency is the institution responsible for the collection of customs declarations (SAD) and the National Revenue Agency - for Intrastat declarations.
Adjustments are applied to compensate the impact of exemption thresholds, which release the information providers from statistical formalities, as well as, to take into account the late or not response of the providers.
The detailed statistical information is collected on commodity level of the Combined Nomenclature (CN8) and data are prepared and disseminated also on higher levels of aggregation sub-headings (6-digits), headings (4-digits), chapters (2-digits) and sections). On the basis of correspondence tables data are presented on aggregated levels of Standard International Trade Classification and Classification of Products by Activity.
Data by countries are classified according to the nomenclature of countries and territories for the external trade statistics. Since 2007 the aggregated data are published by partner country. Data on imports by country of origin are available in the Information System "Foreign Trade".
Price (unit value) indices of exports and imports are published quarterly by sections and divisions of the Standard International Trade Classification.
· Harmonized Commodity Description and Coding System (HS);
· Combined Nomenclature (CN);
· Classification of Products by Economic Activities (CPA.BG 2008);
· Classification of Economic Activities (NACE.BG-2008);
· Standard International Trade Classification (SITC);
· Broad Economic Categories (BEC);
· Nomenclature of countries and territories for the purposes of foreign trade statistics.
Subject of the statistical survey on foreign trade statistics are the goods leaving or entering the statistical territory of the Republic of Bulgaria which form the trade turnover of the country.
|Statistical concepts and definitions|
The detailed statistics on trade in goods are collected and disseminated on a monthly basis. The trade value and the quantity in net mass are the main indicators available for all products of the Combined Nomenclature. On the basis of these detailed data price (unit value) indices and various other indicators on foreign trade statistics are compiled.
Any natural and legal person lodging a customs declaration in a Member State is reporting to the extra-EU trade statistics on the condition that the customs procedure is of statistical relevance.
Within intra-EU trade statistics any taxable person carrying out an intra-EU trade transaction is responsible for providing the information.
However small and medium trade operators are exempted from obligation to provide Intrastat declarations. Each year thresholds are defined which allows intra-EU traders not to report on their transaction or provide less detailed information on condition that their total trade value does not exceed a certain amount during the previous or present calendar year. However, quality standards are assured when determining the thresholds.
Trade in goods includes all goods which add or subtract from the stock of material resources of the country by entering (imports) or leaving (exports) its statistical territory of the Republic of Bulgaria including goods for processing. Information on the goods is provided by legal or natural person.
The information covers foreign trade in goods with third countries and Member States of the EU.
Quarterly price (unit value) indices of exports and imports of goods are calculated based on average annual prices of the previous year.
|Unit of measure|
The value of trade is collected and published in the BGN. Information System "Foreign Trade" also gives possibility to select value in EUR and USD. Moreover the Information System contains data on the net weight in kilograms and quantity in supplementary unit (eg. liter, number, m2, m3, gram, pair, per cent, etc.), as defined in the Combined Nomenclature for the referent year.
The reference period for the exported and imported goods is the calendar month during which the customs declaration is accepted by the customs authorities on extra-EU trade and for intra-EU trade the calendar month during which goods are physically delivered or left the territory of the Republic of Bulgaria.
|Legal acts and other agreements|
Trade with third countries:
- Regulation (EC) No 471/2009 of the European Parliament and of the Council;
- Regulation (EC) No 92/2010 of the Commission;
- Regulation (EC) No 113/2010 of the Commission;
- Customs Law;
- Ordinance No 17/2006 for the written declaration by the Single Administrative Document (SAD);
- Agreement for co-operation and exchange of data between the NSI and the Customs Agency.
- Regulation (EC) No 638/2004 of the European Parliament and of the Council;
- Regulation (EC) No 222/2009 of the European Parliament and of the Council;
- Regulation (EC) No 1982/2004 of the Commission;
- Regulation (EC) No 1915/2005 of the Commission;
- Regulation (EC) No 91/2010 of the Commission;
- Regulation (EC) No 96/2010 of the Commission;
- Regulation (EC) No 1093/2013 of the Commission;
- Law on Statistics of intra-Community trade in goods;
- Ordinance No H-4/2007 for the implementation of the Intrastat system;
- Ordinance on the different or specific rules applied to specific goods and movements of goods, reference periods, method of reporting and declaring, as well as goods to be excluded from the statistics on intra-Community trade in goods;
- Ordinance of the President of the NSI defining the thresholds for declaring under the Intrastat system and the types of data subject to declaring (for each year);
- Instruction for provision of data on intra-Community trade in goods from the NRA to the NSI and for the interaction between the two institutions related to the operation of the Intrastat system.
The data are provided to Eurostat, the UN, FAO and other international organizations.
|Confidentiality - policy|
- Law on Statistics;
- Regulation (EC) No 223/2009 on European statistics (recital 24 and Article 20(4)) of 11 March 2009 (OJ L 87, p. 164), stipulates the need to establish common principles and guidelines ensuring the confidentiality of data used for the production of European statistics and the access to those confidential data with due account for technical developments and the requirements of users in a democratic society.
|In foreign trade statistics the principle of "passive confidentiality" is applied, by which data should be suppressed only at the request of traders who feel that their interests would be harmed by the dissemination of their data. Passive confidentiality is therefore different from "active confidentiality", where the NSI takes directly the initiative to suppress data automatically when the suppression criteria are met, without informing the trade operator concerned. |
|Confidentiality - data treatment|
Individual data are not published in accordance with article 25 of the Law on Statistics. The publishing of individual data can be performed only in accordance with article 26 of the same law.
|The only exception in which the external trade statistics do not apply the principle of "passive confidentiality" are certain specific goods and movements of goods. The value of the transactions for these products is included in the total value of trade, but the partner country and commodity code are suppressed.|
| Confidentiality - INTRASTAT|| || || || ||2008||2009||2010||2011||2012||2013||2014||2015|
| ||Confidentiality in detailed data - Impact in figures||Number of CN8 codes affected|| ||Arrival||0||0||0||0||0||0||0||0|
|Share of confidential records in total trade value|| ||Arrival||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%|
|Share of confidential records in total net mass|| ||Arrival||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%|
| || || || || || || || || || || || || || || |
| || || || || || || || || || || || || || || |
| Confidentiality - EXTRASTAT|| || || || ||2008||2009||2010||2011||2012||2013||2014||2015|
| ||Confidentiality in detailed data - Impact in figures||Number of 8-digit codes affected|| ||Import||0||0||0||0||0||0||0||0|
|Share of confidential records in total trade value|| ||Import||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%|
|Share of confidential records in total net mass|| ||Import||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%||0.0%|
The date of publication of statistical information is indicated in the Release Calendar presenting the results of the statistical surveys carried out by the National Statistical Institute.
|Release calendar access|
The calendar is available on the NSI website: http://www.nsi.bg/en/node/480
Data are published on NSI website under the section Foreign Trade and Information System "Foreign Trade" in accordance with the Law on Statistics and the European Statistics Code of Practice respecting professional independence and aimed at objectivity, transparency and equal treatment of all users.
|Frequency of dissemination|
Monthly, quarterly and annual.
|Accessibility and clarity|
Press releases are published monthly in the announcement of the data.
- "Statistical Reference Book";
- "Statistical Yearbook";
- "Bulgaria 2011 - statistical panorama".
Monthly publication on the website.
Aggregated data are available to all users of the NSI website under the section Foreign Trade: http://www.nsi.bg/en/node/7977
Detailed monthly data are available through the Information System "Foreign Trade": http://ftrade.nsi.bg/portal/page?_pageid=34,1&_dad=portal&_schema=PORTAL
Information service on request in accordance with the Rules for the dissemination of statistical products and services by NSI.
|Documentation on methodology|
Methodology on statistical recording of exports and imports of goods; Methodology on defining the threshold on intra-EU trade in goods; Methodology on estimation of non-response and below threshlod trade of intra-EU trade in goods; Methodology for calculating price (unit value) indices of exports and imports of goods.
Quality reports are available at: http://www.nsi.bg/en/node/7979
Quality assurance is according to Eurostat requirements.
Quality report on the statistics transmitted is provided annually to Eurostat according to standardized quality indicators.
Main users are Bulgarian National Bank, Ministry of Economy and Energy, Ministry of Agriculture and Food, Council of Ministers, regional and municipal administrations, Eurostat, UN, private citizens, media and other international and national organizations.
Specific survey on user?s satisfaction has not been carried out. However, user?s satisfaction is constantly monitored through formal and informal contacts.
Completeness of the information is provided in accordance with the above-mentioned legislative framework.
|Accuracy and reliability|
As intra-EU trade statistics stem from Intrastat declarations by the traders, a main source of error that affects accuracy of intra-EU data is late or non-response. Intra-EU as well as extra-EU trade data accuracy is also affected by specific characteristics of this statistical field, such as the practice of concealing confidential information and the exemption thresholds applied by countries in order to reduce the burden on enterprises.
Foreign trade statistics are based on the Intrastat system for the intra-EU trade and on the customs clearance system for the extra-EU trade. Thus, foreign trade statistics in goods are not affected by errors specifically applicable to sample surveys.
Accuracy of the foreign trade data is affected in different ways by thresholds, non-response, confidentiality practices, as well as by statistical value calculations.
a) Thresholds and non-response
In order to reduce the burden on enterprises, each year thresholds are defined for intra-EU arrivals and dispatches that exempt enterprises to provide statistical information or to limit the information collected. By defining the exemption thresholds is ensured that at least 97 % of the trade value is covered. From the reference year 2009 onwards the minimum coverage rates are 95 % for arrivals and 97 % for dispatches. From the reference year 2014 onwards the minimum coverage rates are 93 % for arrivals
The loss caused by the exemption threshold as well as the loss of coverage due to late-response or non-response must be offset by means of estimations. The estimations are calculated by Member State and chapters of CN. The share of the estimations and the methodology for their calculation, is documented for in the Quality Report on Foreign Trade Statistics.
In foreign trade statistics the principle of "passive confidentiality" is applied, by which data should be suppressed only at the request of traders who feel that their interests would be harmed by the dissemination of their data. Passive confidentiality is therefore different from "active confidentiality", where the NSI takes directly the initiative to suppress data automatically when the suppression criteria are met, without informing the trade operator concerned.
The only exception in which the external trade statistics do not apply the principle of "passive confidentiality" are certain specific goods and movements of goods. The value of the transactions for these products is included in the total value of trade, but the partner country and commodity code are suppressed.
c) Statistical value calculation
Trade figures are published as "statistical value". This is the value of goods at the border of the country: FOB (free on board) value for export/dispatch or CIF (cost, insurance and freight) value for import/arrival. In intra-EU trade, the statistical value usually differs from the amount agreed on the sales agreement (the invoice value) as a result of the delivery terms used in the transaction; therefore the statistical value must be collected in connection with the invoice value or must be estimated by using other variables such as delivery terms and mode of transport.
The trade operators above the statistical value threshold only are required to provide this value in the Intrastat declarations. In transactions of trade operators under the threshold, the statistical value is calculated on the basis of the invoice value, terms of delivery, mode of transport and the partner country.
|Timeliness and punctuality|
The data are published as follows:
· Aggregated data - 40 calendar days after the reference month.
· Detailed data on trade with third countries - 40 calendar days after the reference month.
· Detailed data on trade with EU Member States - 70 calendar days after the reference month.
· Exports and imports price indices - 95 calendar days after the reference quarter.
Release dates of the data from the previous position are respected.
|Coherence and comparability|
|Comparability - geographical|
a) Comparability between intra-EU trade statistics and statistics on trade with third countries
There are two main approaches used for the measurement of international trade in goods, the general trade system and the special trade system. For extra-EU trade statistics, the special trade system is applied which means that goods from a non-EU country which are received into customs warehouses are not recorded in international trade in goods statistics unless they subsequently go into free circulation in the Member State of receipt (or are placed under the customs procedures for inward processing). Similarly, outgoing goods from customs warehouses are not recorded as exports. The general trade system, which is applied by most of the EU main partner countries, is a wider concept since it includes all goods entering or leaving the country. It should be noted that intra-EU trade statistics do not have a direct link to customs procedures, thus they are not compiled on a general or special trade basis.
b) Comparability between Community concept and National concept
EU legislation serves as a basis for compiling the intra- and extra-EU trade statistics sent by the Member States and published by Eurostat. However, EU statistics, which cover the EU as a whole, and the statistics compiled and published by the Member States, are not always directly comparable. Member States may use a national concept at national level but they have to provide Eurostat with harmonised data according to the Community concept. The principal differences between the Community concept and national concepts are as follows:
- Breakdown by partner country: For arrivals, certain Member States record the country of origin as the partner country, whereas the Member State of consignment appears in the Community statistics relating to the same movements.
- Treatment of goods in transit: Some Member States do not record in their national figures goods, which they consider to be 'in transit'. This involves, firstly, imports from non-member countries which are cleared in these Member States before being dispatched to other Member States and, secondly, goods from other Member States which are immediately re-exported to non-member countries. These flows are included in the Community statistics under intra- or extra-EU trade, as appropriate. This phenomenon is sometimes referred to the 'Rotterdam effect'.
- Other differences: Other methodological differences can cause discrepancies between national and Community statistics, for example applying the general trade system at national level rather than the special trade system.
c) Comparability between intra-EU trade statistics based on Community concept
In theory, intra-EU trade statistics based upon Community concept should be fully comparable; therefore data should generally be less affected by asymmetries than extra-EU trade statistics. Dispatches from Member State A to Member State B, as reported by A, should be almost equal to arrivals into B from A, as reported by B. Due to a different valuation principle (CIF > FOB), arrivals should be slightly higher than dispatches. However, since the Intrastat system came into operation, 19 bilateral comparisons have revealed major and persistent discrepancies in the intra-EU trade statistics. Therefore, comparisons dealing with intra-EU trade statistics have to be made cautiously and should take into account the existence of these discrepancies. The main reasons for the discrepancies are known and are represented by the thresholds, the non-response and their related adjustments; statistical confidentiality; triangular trade; time lags in the registration of the transactions; misclassification of goods; or by other methodological differences. The Member States regularly carry out bilateral studies to find out at detailed product level where the problems are and to resolve them. However, remedies are not easily found despite all the analyses done.
Some Member States do not collect but estimate net mass when the supplementary unit is collected for intra-trade statistics. Estimates of the net mass could also cause discrepancies in mirror data between the Member States.
|Comparability - over time|
Changes due to definitions, coverage or methods and other changes will have an impact on the continuity of foreign trade series. The impact of the different methodological and practical changes that have occurred in recent years (enlargement of the EU, changes in the Intrastat and Extrastat legislation, changes in product nomenclatures, etc.) is difficult to assess precisely. In particular the accession of new Member States to the EU may cause problems to the comparability over time since it implies for the acceding country a change from an administrative data source (Extrastat) to a purely statistical data collection system (Intrastat). This may have an impact on the accuracy of statistics at detailed level.
|Coherence - cross domain|
Apart from the foreign trade statistics, information on trade flows can be found in National Accounts, Business Statistics and Balance of Payments. The compilation of the data and the production of the above mentioned statistics follow the recommendations (sources and methods) of different international organisations, i.e. Eurostat, International Monetary Fund (IMF), United Nations (UN), etc. The main differences between these sources are in terms of concepts and definitions, statistical unit or object, classification (nomenclature) used, geographical breakdown, reference period and correction methods.
|Coherence - internal|
A key feature of the data set is its coherence. Aggregated data are constructed from detailed data and over different product classifications with the help of official correspondence tables. This ensures internal coherence. In addition, derived indicators such as unit value indices are calculated from the detailed data.
|Cost and burden|
Reducing the administrative burden on businesses related to submission of primary data on trade in goods with Members States while maintaining the quality of the produced information continues to be a priority in the work of the NSI. Besides the application of threshold for simplified declaration of transactions with low values which reduce the response burden, the number of indicators which must be declared by the Intrastat operators since 2011 was also reduced, as requirement for the completion of the field "statistical procedure" in the Intrastat declaration. PSIs which had previously to provide a separate report to NSI for special movement of goods from 2011 on submit data directly to the NRA by Intrastat declarations together with the other data has carried trade in goods within the EU. Valid from 2011, after receiving permission from the NRA, part of Intrastat operators benefit by simplified declaration of spare parts for motor vehicles and aircraft, which facilitates businesses in the performance of their monthly obligations. Last but not least are the measures taken by NSI for optimizing the statistical tools and the use of reliable statistical methods for estimation of flows not covered by Intrastat declarations, which made it possible to reduce the scope of data for intra-Community trade and contributed to reducing the number of companies that have the obligation to provide Intrastat declarations.
|Data revision - policy|
At the end of each quarter (70 days after the reference quarter) all the monthly data from the beginning of the current year are revised. Final data for a given year are published nine months after the reference year. Revisions to previous years are made if in conducting mirror comparisons between Member States a necessity to revise the data are identified.
|Data revision - practice|
See the previous position.
· Single Administrative Document filled in by all persons engaged in import or export of goods from/to third countries;
· Intrastat declarations for arrivals and dispatches of goods from/to Member States, provided by trade operators that have exceeded the threshold for declaring Intrastat in a calendar year;
· Estimates of non-response and trade below the threshold;
· Statistical data for specific goods and movements;
· VAT returns.
|Frequency of data collection|
Single Administrative Documents (customs declarations) from all customs offices are entered in the Bulgarian Integrated Customs Information System. Monthly, based on a bilateral agreement with Customs Agency, NSI receives primary data which include 40 fields from SAD necessary for the compilation of foreign trade statistics.
Intrastat declarations are entered in the information system "Intrastat" of NRA. Monthly, according to the Instruction for information exchange between NSI and the NRA developed in implementation of the Law on Statistics of Intra-Community Trade in goods, NSI receives primary file with records of all Intrastat declarations. Monthly, according to the approved instructions, NSI receives from the NRA information from VAT declarations made by economic operators which had carried out intra-Community supplies and intra-Community acquisitions.
Monthly NSI receives additional information on specific goods and movements of goods.
Validation and logical control of data are made during their processing by Information System "Foreign Trade" on the basis of defined rules.
All the activities on input, processing, validation and logical control of data, estimations on below threshold trade and non-response, data analysis, and formation of output files and reports for different users in the NSI, other users from the country or abroad are automated and integrated into the Information System "Foreign Trade".
Foreign trade statistics in goods applies the special trade system which means that goods from a non-EU country which are received into customs warehouses are not recorded unless they subsequently go into free circulation in the Member State of receipt (or are placed under the customs procedures for inward processing). Similarly, outgoing goods from customs warehouses are not recorded as exports.
The statistical value
Foreign trade statistics in goods apply harmonised principles when compiling the statistical value of trade flows. In general all goods should be valued with the total amount which would be invoiced in case of sale or purchase at the national border of the country. In practice the statistical value of the good is based in most of the cases for intra-EU trade on the taxable amount determined for VAT purposes and for extra-EU trade on the value determined for customs purposes.
However, for some trade transactions the amount determined for fiscal or customs purposes is not applicable. This concerns mainly processing transactions, transaction not involving transfer of ownership and return of goods. In these cases the total sale or purchase amount of the good has to be estimated.
The statistical value does not include taxes on export or import, such as customs duties, value added tax, excise duty, levies, export refunds or other taxes with similar effect. It includes only incidental expenses (freight, insurance) incurred, in the case of exports/dispatches, in the part of the journey located on the territory of the country and, in the case of imports/arrivals, in the part of the journey located outside the territory of the country. It is said to be a FOB value (free on board), for exports/dispatches, and a CIF value (cost, insurance, freight) for imports/arrivals.
The statistical value of the trade flow is collected in BGN and converted into Euro and USD in order to be provided to the users.
The quantity measurements
The quantity of a commodity is documented essentially in kilograms. This is the net weight of the commodity, which is defined as the weight of the commodity without any packing.
For selected types of commodities the quantity is also recorded and documented in a supplementary unit as this furnishes further useful information (e.g. Carats, Kilowatt Hours, Litre, Square Metre, Cubic Metre, Number of Items, Terajoule). Further information whether a supplementary unit is collected for a given good is available in the Combined Nomenclature valid for the reference year.
The following transactions are generally included in international trade in goods statistics: Barter trade, goods on consignment, goods on financial lease, goods traded between enterprises under common ownership, goods traded on government account and goods with a view or following processing.
The following transactions are excluded from international trade in goods statistics for conceptual or methodological reasons:
- Goods in simple transit: The reporting on operations in transit countries are excluded when the good travels directly through the transit country or stops for reasons only related to its transport.
- Temporary trade: Goods moving abroad or entering the country for a period not longer than 24 month without change of ownership, undergoing no transformation except normal depreciation (e.g. hire, operational leasing).
- Particular trade not subject of a commercial transaction (e.g. advertisement material, commercial samples)
- Supply for national arm forces stationed abroad, embassies and emergency aid for disaster areas.
- Means of payment and monetary gold
- Goods for and after repair
A comprehensive list of goods excluded for methodological reasons is given in the Annex I of the Commission Regulations (EC) No 113/2010 (Extrastat) and Commission Regulation (EC) No 1982/2004 (Intrastat).
Specific movements of goods
There are some movements of goods of such a nature that their inclusion in international trade in goods statistics merits separate mention. These goods are defined as specific movements, whose features are significant for the interpretation of the information. More specifically, the features may relate to the movement as such, the nature of the goods, the transaction which gives rise to the movement of the goods or the exporter or importer of the goods, in particular industrial plant; vessels and aircraft; sea products; goods delivered to vessels and aircraft; staggered consignments; military goods; goods to or from offshore installations; spacecraft; motor vehicle and aircraft parts; electricity and gas and waste products. These goods need specific provisions regarding the scope of trade or the data sources. For most of these goods harmonised rules are determined by the Commission Regulations (EC) No 113/2010 (Extrastat) and (EC) No 1982/2004 (Intrastat). On national level these specific goods are regulated in the "Ordinance for the different or specific rules that will apply to specific goods and movements of goods, the reference periods, the method of reporting and disclosure, as well as goods to be excluded from statistics of intra-Community trade in goods since 2006".
From the traded during a given year goods that are exported/imported under customs procedures corresponding to "normal export and import" a selection of representative commodities is made. The transactions with commodities under customs procedure inward/outward processing are excluded. The information used for the index calculation is a 8 digit CN commodity code, values, net mass (in kg) or supplementary unit quantity, where it is applicable (i.e. meters, liters, items, etc.), country of origin for imported goods and country of last known destination for exported goods, monthly number of shipments, number of months in the year during which the selected goods were traded.
Data are collected quarterly on the base of item data files for the reference period used for the production of foreign trade data both for base and reference year. The sample for index calculation covers all goods exported or imported under customs or statistical procedure for normal export/import. Temporary exports/imports before and after processing and some special trade flows (i.e. ships, aircrafts, military goods, estimations of below threshold trade and non-response) are excluded from the sample. Based on that information after variation analysis a catalogue of selected representative commodities for the base period is elaborated. Chain indices for production year are calculated using this catalogue and substituting method.
The subject of the statistical survey are the changes in the relative average prices of the traded commodities in the reference period and the relative average prices in the base year.
Data on foreign trade of goods are not seasonally adjusted.
Estimations for trade below the thresholds and for non-response are made.