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Subject Responses to comments on ISO Committee Draft 2108

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					               ISO/TC 46/SC 9 Secretariat            ISO/TC 46/SC 9 Secrétariat

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                                Web site: <http://www.nlc-bnc.ca/iso/tc46sc9/index.htm>


                                                                                           ISO TC 46/SC 9     N 360
                                                                                          [supercedes document N 352]
                                                                                                           2003-07-25
         To:     Voting members (P-members) of ISO TC 46/SC 9
                 ISO TC 46/SC 9/Working Group 4
                 Selected organizations in liaison

         cc.     ISO TC 46 Secretariat
                 ISO Central Secretariat

         Subject:         Responses to comments on ISO Committee Draft 2108,
                          International Standard Book Number (ISBN)

         The attached document shows the disposition of comments on ISO Committee Draft 2108 for the
         the revision of the International Standard Book Number (ISBN).
         The results of voting and comments on CD 2108 were distributed in May 2003 as TC46/SC9
         document N 353. ISO/TC 46/SC 9 Working Group 4 discussed the comments on CD 2108 at its
         meeting in Rome on May 19-20, 2003. The attached document shows WG 4's agreed responses
         to those comments. The accompanying revisions to CD 2108 are shown separately in SC 9
         document N 361.
         WG4 presented its responses to the SC9 meeting on May 21, 2003 where SC9 resolved that
         Committee Draft 2108, as modified by the decisions of the WG 4 meeting, would advance to the
         Approval stage for voting as ISO Draft International Standard 2108 (see N 359, resolution 1).


         ACTION REQUESTED:                 Retain this document for future reference when DIS 2108 is
                                           distributed for voting. Target date for DIS distribution: September
                                           or October 2003.
         ONLINE VERSION:                   This document is also available on the ISO/TC 46/SC 9 Web site
                                           at: <http://www.nlc-bnc.ca/iso/tc46sc9/2108.htm>.

         With regards,

         [original signed by]

         Jane Thacker
         Secretary, ISO/TC 46/SC 9


ISO International Organization for Standardization                   ISO Organisation internationale de normalisation
TC 46 Information and Documentation                                  TC 46 Information et documentation
SC 9 Identification and Description                                  SC 9 Identification et description
                                                                                             ISO/TC46/SC9 N 360
                                                                                                     2003-07-25
                                       TABLE OF REPLIES
                ISO Committee Draft 2108, International Standard Book Number (ISBN)

      P-Members                Agree                Disagree       Abstain   Did not reply      Comments
   of ISO/TC46/SC9         to register as DIS                                                    submitted
Australia (SAI)           SAI                                                                SAI
Bulgaria (BDS)            BDS                                                                --
Canada (SCC)              SCC                                                                SCC
China, P.R. (CSBTS)                                                          CSBTS
Colombia (ICONTEC)        ICONTEC                                                            ICONTEC
Czech Republic (CSNI)     CSNI                                                               CSNI
Denmark (DS)              DS                                                                 --
Finland (SFS)             SFS                                                                SFS
France (AFNOR)            AFNOR                                                              --
Germany (DIN)             DIN                                                                DIN
Hungary (MSZT)            MSZT                                                               MSZT
Italy (UNI)               UNI                                                                --
Japan (JISC)              JISC                                                               --
Kenya (KEBS)                                                                 KEBS
Netherlands (NEN)                                                            NEN
Norway (NSF)              NSF                                                                NSF
Poland (PKN)                                                                 PKN
Portugal (IPQ)                                                               IPQ
Russian Fed. (GOST R)                                          GOST R                        GOST R
South Africa (SABS)                                            SABS
Spain (AENOR)                                                                AENOR
Sweden (SIS)              SIS                                                                SIS
U.K. (BSI)                BSI                                                                BSI
U.S.A. (ANSI)             ANSI                                                               ANSI

TOTAL (of 24)             16                    0              2             6
OTHERS: Thailand (approval, no comments); International Booksellers Federation
                                                                         ISO/TC 46/SC 9 N 360
                                                                                   2003-07-25
                                                                                       page 3

    RESPONSES TO COMMENTS ON ISO COMMITTEE DRAFT 2108

            as agreed at the ISO TC46/SC9 WG 4 meeting in Rome, May 19-20, 2003


GENERAL COMMENTS:

SIS (Sweden)

   The Swedish centre for ISBN is organized within the Royal Library of Stockholm as part of
   its department Collection Development & Documentation. The centre has discussed the CD
   with the Swedish representative in the working group and accepts the text as it stands in all
   parts. The only negative comment we want to propose is the following [see SIS comment on
   the definition of edition at 3.4, below]. On the other hand, the centre welcomes the libreral
   and understanding approach to bibliographic service illustrated by clause E.3 [Association of
   an ISBN with ISBN metadata].

SCC (Canada)

   Before or in conjunction with the next voting stage on this standard, additional guidance must
   be provided regarding the implementation of these changes.

   For example, Annex F gives the impression that all 10-digit ISBN should be converted to 13
   digits as of the implementation date. Would that also affect ISBN in existing MARC records
   (i.e., in library databases)? We assume that is not the intention but, clearly, a broader range
   of implementation issues covering more than just trade applications must be addressed in
   Annex F.4 before this standard is approved. Libraries probably have a larger "legacy" of
   ISBN than any other sector of the information supply chain and their specific context and
   concerns must be addressed in implementation guidelines.

   System vendors will also need to be made aware of the fact that the new check digit
   algorithm is completely different from the old one, and that X is no longer a valid check-
   digit. If 10 and 13 digit ISBN can co-exist in a database (e.g. in MARC records), any system
   that is used to validate those numbers will need to be capable of processing either form of
   ISBN.

WG RESPONSE: Agreed. Detailed implementation guidelines will be available before the DIS is
issued.

NSF (Norway)

   COMMENT: Positive to metadata.

   COMMENT: It is a general agreement that different online formats should be allocated
   different ISBNs. But there are two questions:
                                                                                     ISO TC 46/SC 9 N 360
                                                                                               2003-07-25
                                                                                                   page 4


   1. It seems as if ISSN does not allocate different ISSNs to different formats (source: The
      ISSN meeting 2002). Why do ISSN and ISBN have different rules?

WG RESPONSE: It is legitimate for different rules to apply to different standards. The ISBN
identifies individual products; ISSN is assigned at the title level.


   2. What about free digital (scanned) reproductions of printed publications? Are they ‘new
      editions’? (See also the ISSN manual – final draft, 2.2 - Note).
       [For information Note 2.2 from the ISSN manual reads as follows: "Micro and digital reproductions
       produced for the purpose of providing surrogates for the original materials are the exception and shall use
       the ISSN of the original continuing resources."]

WG RESPONSE: The issue is whether the organization involved is acting as a publisher. On that
basis, reproductions for internal purposes should not be treated as new editions.
This is covered in clause 3.7 by defining a monographic publication, for the purposes of ISBN, as
something that is "made available to the public".

International Booksellers Federation

   [From the IBF Secretariat]: I have circulated your document among EBF and IBF Members
   and I am happy to report that there is a general agreement that globally speaking the revisions
   seem to be well thought and that rules are clear.
   [Accompanied by comments from the President of the European Booksellers Federation, see
   relevant clauses below]

SFS (Finland)

   COMMENT: It is required that the change from the 10 digit ISBN to the 13 digit one will
   guarantee that the new ISBN numbers will last over 50 years.

WG RESPONSE: This is not appropriate to include in the standard. However the new syntax of the
ISBN does accommodate additional expansion of the numbering capacity when necessary.

   COMMENT: The transitional stage of the 13 digit ISBN will cause additional work for book
   stores and book wholesalers as well as the changes in the different data systems.

   COMMENT: The book branch feels a bit confusing with the two different ISBNs in new
   book registers during the transitional stage. That is why exact instructions are needed.

WG RESPONSE: Additional implementation guidance is being developed.
                                                                          ISO TC 46/SC 9 N 360
                                                                                    2003-07-25
                                                                                        page 5

SPECIFIC COMMENTS ARRANGED BY CLAUSE NUMBER

Introduction

SCC (Canada)

   The standard never actually states why the 978 and 979 prefixes are being incorporated
   within the ISBN syntax and how that will increase the number of available ISBN. While it
   may seem obvious, our reviewers felt that the reason for making a change of this magnitude
   should be recorded somewhere in the text of the ISBN standard. We suggest adding this
   information to the Introduction. Perhaps some text could be extracted for this purpose from
   the set of "Frequently Asked Questions" on the project's Web site.

WG RESPONSE: This explanation has been given in the Foreword.


1 Scope

BSI (United Kingdom)

   See U.K. comment on 3.4 (below), proposing the phrase "product form or edition" instead of
   "format or edition".

WG RESPONSE: The term "product form" will be used. This term will be adopted throughout the
standard, wherever appropriate.

NSF (Norway)

   Clause 1, paragraph 1:

   COMMENT: It is not clear what is meant by “descriptive information” (metadata).
   “Descriptive data” may also mean the administrative datas, not only the “metadatas” as we
   use the term in the standard.
   Maybe ‘metadata’ and ‘adminstrative data’ should be defined?

   PROPOSED CHANGE: (…) the metadata to be associated with the ISBN allocation (…)

WG RESPONSE: The decision at the meeting was to delete the phrase “descriptive information” and
use "metadata". Possible definitions of metadata were to be investigated.
NOTE FROM THE SC9 SECRETARIAT: ISO's editing directives state that "Common dictionary or
current technical terms shall be included only if they are used with a specific meaning in the relevant
context". "Metadata" is a current technical term that is being used in its conventional sense in the ISBN
standard. Furthermore, the ISO standard for Dublin Core metadata does not include a definition of
                                                                                       ISO TC 46/SC 9 N 360
                                                                                                 2003-07-25
                                                                                                     page 6

"metadata". For these reasons, the Secretariat suggests that there is no need for the ISBN standard to
include its own definition of "metadata".

For the record, here are the two ISO definitions of "metadata" that were found:
-- metadata: Data that is included in an entity or linked to an entity that describes the entity and assists in its
retrieval. [Source: ISO 8459-5, "Information and documentation — Bibliographic data element directory — Part 5: Data
elements for the exchange of cataloguing and metadata"]
-- metadata: Data that defines and describes other data. [Source: ISO/IEC 11179-1:1999, "Information technology --
Specification and standardization of data elements -- Part 1: Framework for the specification and standardization of data
elements]


MSZT (Hungary)

    1 Scope:
    This is the first place where the term „metadata” is used in the draft. We know that this term
    is widely used for descriptive and informative data on (first of all electronic) documents.
    However, our opinion is, that this term is rather general and does not express the content and
    purpose of these data. The correct term would be descriptive information. This comment
    will not be repeated when the term “metadata” appears in the text.
    See also our comments on Annex E.

WG RESPONSE: See above response to NSF comment.

SFS (Finland)

    1 Scope
    COMMENT:
    We suggest that the BICI system ought to be mentioned as an alternative for numbering
    individual sections or chapters of the monographic publications.
    Maps should not be mentioned because they also have been removed from the Annex A.
    Examples of other products to which ISBN is applicable have been given in the Annex A
    and there is no need to repeat the list in the Scope chapter.
    PROPOSED CHANGE:
    Proposed new formulation of the second and third paragraphs:
        This International Standard is applicable to monographic publications (or their individual
        sections or chapters where these are made separately available, this type of usage of
        ISBN is an alternative for using BICI (Book Item and Component Identifier) once
        that identifier has been established) and certain types of related products.
        Details concerning the scope of ISBN and examples of applicable and non-applicable
        products are provided in Annex A.

WG RESPONSE: The SFS comment about BICI was withdrawn at the meeting.
                                                                           ISO TC 46/SC 9 N 360
                                                                                     2003-07-25
                                                                                         page 7

The examples in the second paragraph were deleted and the reference to Annex A in the 3rd paragraph
was appended to the 2nd paragraph of the Scope.


3 Definitions

SCC (Canada)

   [See SCC comment on Annex A.3, below.]
   We also note that the definition of a series was deleted from clause 3 when the final Working
   Draft (WG4 N26) was prepared as a Committee Draft. In its place we propose a simpler
   definition of "series", based on a definition in the Anglo-American Cataloguing Rules:
        series: A group of separately available publications related to one another by the fact
        that each of them bears, in addition to its own individual title, a collective title applying
        to the group as a whole. The individual items may or may not be numbered.

WG RESPONSE: Comment was withdrawn by SCC at the meeting.

NSF (Norway)

   Clause 3:
   COMMENT: We miss a definition of ‘e-book’ and of ‘internet publication’.

WG RESPONSE: No change. ISO's editing directives state that "Common dictionary or current
technical terms shall be included only if they are used with a specific meaning in the relevant context".
That does not apply in the case of these terms.

SFS (Finland)

   3 Term(s) and definition(s)
   COMMENT: definitions for terms publisher, producer and product should be provided to
   ensure sufficient clarity.

WG RESPONSE: No change. ISO's editing directives state that "Common dictionary or current
technical terms shall be included only if they are used with a specific meaning in the relevant context".
That does not apply in the case of these terms. However, SFS is invited to suggest definitions, if
desired, for possible inclusion in the Users' Manual.
                                                                           ISO TC 46/SC 9 N 360
                                                                                     2003-07-25
                                                                                         page 8

3.1 ("EAN.UCC prefix")

   [N.B.: Also see comments on clause 4.2, below.]

DIN (Germany)

   COMMENT: While the explanation of "EAN.UCC prefix“ is completely correct the
   standard only deals with those prefixes hidden in the small print note. These are currently
   called “Bookland/EAN”, a term that has been used in the ISBN community for almost 20
   years. Is there any need for changing this? If “EAN.UCC prefix” is considered preferable,
   then it should be used in the text as: “EAN.UCC prefixes allocated solely for the use of the
   ISBN system and made available through the International ISBN Agency”.
   Otherwise it may be very confusing in practice, and some publishers will use the country
   prefixes, or only regular EAN.UCC article numbers.
   PROPOSED CHANGE(S): “EAN.UCC prefixes allocated solely for the use of the ISBN
   system and made available through the International ISBN Agency”
   The (continued) use of “EAN/Bookland” is proposed: “EAN/Bookland – an international 3
   digit product number prefix made available by EAN International for the sole use in the ISBN
   system.”

WG RESPONSE: See response to the Canadian comment on clause 4.2, below.
It was also noted that particular attention will have to be given to the Japanese JAN code in the Users'
Manual and implementation guidelines. The JAN is Japan's version of the EAN prefix and a JAN may
include additional information such as price.


3.3 (definition of continuing resource):

CSNI (Czech Republic)

   In the note dealing with serials yearbooks and monographic series to which ISBN is assigned
   are not mentioned (see also CSNI comment on A.1.10, below).

WG RESPONSE: Clause 3.3 is not intended as an exhaustive list of applicable publications. More
details will be provided in the Users' Manual.

   There is no definition of electronic publications.

WG RESPONSE: No change. See response to NSF comment on clause 3, above.

   Is it really necessary to begin to use a new terminology instead of that being in use for thirty
   previous years (i.e., registrant instead of publisher, registration group instead of group agency
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                                                                                         page 9

   – and further in the text: registration group element instead of group identifier, registrant
   element instead of publisher identifier, and publication element instead of title identifier)?

WG RESPONSE: No change.

SCC (Canada)

   Not all loose-leaf publications are continuing resources; some are regarded as finite
   publications and are eligible for ISBN. The problem is that the wording of the note to the
   definition at clause 3.3 can be misinterpreted. For perfect clarity, it ought to read:
   "Continuing resources include … ongoing integrating resources such as loose-leaf
   publications that are continually updated and Web sites that are continually updated."


WG RESPONSE: Agreed. The wording of clause 3.3. has been revised as proposed.

MSZT (Hungary)

   3.3
   COMMENT: We know that nowadays the term "resources" is widely used instead the term
   documents. Probably the ISBD on electronic documents was the first case of using
   „resources” in the meaning of documents although it is absolutely clear from any standard
   definition of documents, that the meaning of „document” does not exclude electronic or any
   other documents recorded on any carrier. Probably it is to late but we however recommend
   the replacement of the term “resources”, by the term “documents”.

WG RESPONSE: No change. The term "continuing resource" has already been widely adopted (e.g.
by the ISSN Network, the ISBD, and AACR).


3.4 ("edition")

SIS (Sweden)

   The definition of edition, 3.4, should be expanded and run as follows:
      edition: All copies of a publication embodying essentially the same content, derived from
      essentially the same act of registration, and issued by the same entity.

WG RESPONSE: No change.

BSI (United Kingdom)

   It would help if the note attached to the definition of "edition" contained the same text as that
   at "product form". It might also help to give examples: "A single edition of a publication may
                                                                        ISO TC 46/SC 9 N 360
                                                                                  2003-07-25
                                                                                     page 10

   be published in multiple forms, for example the same edition of a novel may appear in the
   product forms of paperback, hardback, cassette audiobook, CD audiobook, braille book etc."
   And I'd prefer here "multiple product forms" to "multiple forms" too.

WG RESPONSE: The note formerly at 3.9 ("product form") was moved to 3.4 ("edition") and revised
as: "Note – A single edition of a publication may be published in multiple product forms." Examples
will be added to 3.9 in place of its former note.

   Further, the "Scope" statement refers to "format or edition" - we suggest this should be
   aligned with the definitions sections to read "product form or edition". The same problem
   arises in A.1.2: "different formats" should be "different product forms". The same problem
   also arises in A.1.7.

WG RESPONSE: The term "product form" has replaced "format" wherever appropriate throughout
the standard. See response to BSI comment under Scope, above.

GOST R (Russian Federation)

   Comment [accompanying abstention]: Some of the definitions are not clear enough.
   Alternative wordings are proposed below.
   3.4 edition - All copies of a publication embodying the same content and by the same entity
   at the same time.

WG RESPONSE: No change. All copies of an edition are not necessarily produced at the same time.

3.5 ("integrating resource")

GOST R (Russian Federation)

   Comment [accompanying abstention]: Some of the definitions are not clear enough.
   Alternative wordings are proposed below.
   3.5 integrating resource - A publication that integrates into the whole some previous
   publications or one previous publication with subsequent additions and/or updates to them.

WG RESPONSE : No change. The existing definition is more in line with the definition adopted by
the ISSN system.

3.7 ("monographic publication")

DIN (Germany)

   COMMENT: 3.7 “offered for general distribution”. Whether a publication is a monograph
   or not, has no connection with its distribution. Also, for the purpose of ISBN allocation,
   distribution should not be an important criteria.
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                                                                                  2003-07-25
                                                                                     page 11

   PROPOSED CHANGE: It is proposed to delete “offered for general distribution”.

WG RESPONSE: The wording "made available to the public" will be used instead.

MSZT (Hungary)
   3.7
   COMMENT: We recommend to insert the word “finite” before the word “number”
   (“…within a finite number of parts…) for a better distinction from serials.
   PROPOSED CHANGE: A publication conceived as a whole in one part or within a finite
   number of parts by publisher/author(s( and offered for general distribution in any product
   form.

WG RESPONSE: The word "finite" will be added to the definition. Also see response to DIN
comment, above. The definition (now numbered 3.8) reads:
"monographic publication: Publication conceived as a whole in one part or within a finite number of
partes by its publisher/author(s) and made available to the public in any product form."

GOST R (Russian Federation)

   Comment [accompanying abstention]: Some of the definitions are not clear enough.
   Alternative wordings are proposed below.
   3.7 monographic publication - A publication conceived as a whole in one part or within a
   predetermined number of parts by publisher/author(s).

WG RESPONSE: See response to MSZT comment above.

SFS (Finland)

   3.7 monographic publications
   COMMENT: The word finite is needed to be in accordance with the definitions of
   continuing resource and integrating resource.
   PROPOSED CHANGE: A publication conceived as a whole in one part or within a finite
   number of parts by publisher/author(s) and offered for general distribution in any product
   form

WG RESPONSE: See response to MSZT comment above.
                                                                          ISO TC 46/SC 9 N 360
                                                                                    2003-07-25
                                                                                       page 12

3.9 ("product form")

ANSI / NISO (U.S.A.)

   Section 3 Terms and definitions
   The term "Product form" requires further clarification to explain the expected level of
   granularity. If a publisher issues a talking book as regular audio tape, digital audio tape, CD-
   Audio, CD-ROM, DVD-ROM, DVD-Audio, DVD-RAM, MP3 file, WAV file, etc., how
   many different ISBNs will be assigned?

WG RESPONSE: If the intention is that a particular format of an item will be made separately
available for trade then it will require its own ISBN. See clause 5.5.

MSZT (Hungary)

   3.9
   COMMENT: We recommend the wording “…medium and/or data…” instead of “medium
   or data”
   PROPOSED CHANGE: "The size, binding, medium and/or data structure of a publication"

WG RESPONSE: See response to GOST R comment, below.

GOST R (Russian Federation)

   Comment [accompanying abstention]: Some of the definitions are not clear enough.
   Alternative wordings are proposed below.
   3.9 product form - The size, binding, medium or data format of a publication.

WG RESPONSE: The definition was changed to: "The size, binding, medium and/or data format of a
publication." Examples were added for further clarification.


SFS (Finland)

   3.9 Product form
   COMMENT: In 5.5, it should be made clear that product form also encompasses different
   formats of an electronic publication. Term document format should be defined as a
   specification of a document’s data structure.


WG RESPONSE: See above response to GOST R comment on this clause.

   COMMENT: A 1.3 and 1.7 should be synchronized with the specification in 5.5.
                                                                          ISO TC 46/SC 9 N 360
                                                                                    2003-07-25
                                                                                       page 13

WG RESPONSE: The draft was reviewed to ensure consistency in the use of "product form" vs.
"format" throughout the text.


Clause 4.1 (General structure of an ISBN)

CSNI (Czech Republic)

   After this text only hyphens are allowed for separation the elements of the ISBN; but further
   in the text (see Annex C, C.4) spaces are also mentioned. We should prefer the first
   possibility: separation only by hyphens.

WG RESPONSE: Hyphens are the recommended approach. See response to ANSI/NISO comment,
below.


ANSI / NISO (U.S.A.)

   The standard must be explicit and consistent in its direction on the use of hyphens in display
   of the ISBN. Section 4.1 states that the hyphen "should" be used. Section C.4 states that
   hyphens "may" be used.
   It is suggest that "should" be used in Section C.4.

WG RESPONSE: Agreed. The wording of Annex C.4 was changed to read "hyphens should be
used…".
An explanation of "human-readable form" was added in parentheses at clause 4.1 where the term is
used for the first time: "…in human readable form (i.e. a form meant primarily to be read or written by
a person, in contrast to a form primarily meant to be used by data processing equipment)".

MSZT (Hungary)

   4.1 footnote 2
   COMMENT: Instead of "… inconjuction with …" we recommend the text: corresponding to
   (according to the relevant conversion standard)…"
   PROPOSED CHANGE: "In countries where the Latin alphabet is not used, the appropriate
   abbreviation for "International Standard Book Number" in the local script may be given
   corresponding to (according to the relevant conversion standard) the required letters ISBN in
   the Latin alphabet."

WG RESPONSE: No change. It is important for global trade to ensure that the ISBN is always
identified in the Latin alphabet, in addition to any local scripts.
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                                                                                        page 14

Clause 4.2 (EAN.UCC prefix)

   [NOTE: Also see comments on clause 3.1, above.]

SCC (Canada)

   The Committee Draft no longer uses the concept of the "Bookland EAN". Although we
   realize that EAN International is responsible for allocating the ISBN prefix, it should not do
   so arbitrarily. The Registration Authority must determine which of any reserved EAN.UCC
   prefixes are "active" for ISBN use at a given time. A valid ISBN should contain a prefix that
   has been authorized for ISBN use by the International ISBN Agency.

   We would also prefer a more generic heading for this clause, such as "Prefix element" or
   "Product number prefix". It is not necessary to name any of the component elements of an
   ISBN for the organization which originally allocated it.

   We propose changing the heading and content of clause 4.2 as follows:

       4.2 Prefix element [or Product number prefix]

       The first element of a 13 digit ISBN shall be a 3 digit prefix specified by the International
       ISBN Agency in conformance with the global EAN.UCC product numbering system. This
       3 digit prefix shall be reserved for ISBN purposes within the global EAN.UCC system. It
       indicates that the ensuing product number originates with and is part of the ISBN system.

       Technical information specifying valid EAN.UCC prefixes for ISBN use shall be
       available from the International ISBN Agency.

   If this change is accepted then the 1st indent under clause 4.1 should also be changed to: "--
   prefix element;" [or "-- Product number prefix"].

WG RESPONSE: The heading of clause 4.2 was changed to "Prefix element". The wording proposed
by SCC was adopted with the following changes to the 1st paragraph:
       "The first element of a 13 digit ISBN shall be a 3 digit prefix specified by the International ISBN
Agency in conformance with the global EAN.UCC product numbering system. This prefix is made
available to the International ISBN Agency by EAN International. It indicates that the ensuing 13 digit
product number originates with and is part of the ISBN system."

DIN (Germany)

   PROPOSED CHANGE: It is proposed to change this to:
   “The first element of a 13 digit ISBN shall be the Bookland/EAN prefix. It shall be used to
   establish that the following identification number is an ISBN. Technical specifications shall
   be available from the International ISBN Agency”.
                                                                        ISO TC 46/SC 9 N 360
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                                                                                     page 15


WG RESPONSE: See response to SCC comment above.

MSZT (Hungary)

   4.2
   COMMENT: We recommend to replace in the second paragraph the word “establish” by the
   word “prove” or any other appropriate word. No meaning of “establish” is adequate in the
   given context.

   PROPOSED CHANGE: "The EAN.UCC prefix shall be used to prove that the product
   number which follows is conformant with the ISBN sstem and is reserved for that purpose
   within the global EAN product numbering system."

WG RESPONSE: See response to SCC comment, above.

SFS (Finland)

   4.2 EAN.UCC prefix
   COMMENT: The relationship between EAN International and ISBN organization should be
   declared in a separate Annex as well as the future cooperation with the new three digit
   EAN.UCC prefixes.

WG RESPONSE: This matter will be addressed in separate governance procedures for the ISBN
system. Contractual arrangements between EAN International and ISBN are not appropriate for the
standard.


   COMMENT: Some clarifying remarks in a separate Annex about the planned usage of
   EAN.UCC prefixes 978 and 979 would be most helpful.

WG RESPONSE: This is more suited to implementation guidelines. Matters such as when the "979"
prefix comes into effect will be dealt with by the governing body of the ISBN system when the timing
is appropriate.


Clause 4.4 (Registrant element):

DIN (Germany)

   COMMENT: 4.4 “This element identifies the publisher or producer number …” The
   second part of the sentence is duplicated by the following paragraph: “The registrant element
   shall be allocated by the ISBN registrant agency …”
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   PROPOSED CHANGE: should read: ”This element is the publisher or producer number”.

WG RESPONSE: The sentence was changed to: "This element shall be allocated by the ISBN
registration agency appointed for this purpose within each registration group." and the duplicate 2nd
paragraph was deleted.

   COMMENT: There is a lack of consistency in the references to ISBN agencies: “the
   specified ISBN registration agency” (4.4), “the ISBN registration agency designated for this
   purpose” (4.4), “registration group ISBN agencies” (4.5), “designated ISBN registration
   agency” (5.1), “relevant ISBN registration agency or its designated registration service” (5.2),
   “appointed ISBN registration agencies” (7), etc.
   While we know what is meant by the “designated registration service” (usually the national
   bibliography) this term is not explained and may cause confusion.
   PROPOSED CHANGE: There is need for more consistency, especially with regard to
   “designated, relevant, specified, appointed”

WG RESPONSE: Consistency was reviewed throughout the standard. In most cases the word
"designated" was changed to "appointed" and the term "ISBN registration agency" was preferred.

The terms "registration service" and "bibliographic services" in Annex E were changed to
"bibliographic agency" (see Canadian comments on Annex E, below). The same change was made in
clause 5.2. The second sentences of annexes B.3.4 and B.3.5 were also reworded as follows: "Tasks
involving ISBN metadata may be delegated to a designated bibliographic agency acting in compliance
with the specifications of this International Standard."

MSZT (Hungary)

   4.4
   COMMENT: We recommend to change the last sentence of the first paragraph by the text
   as follows: Registration group ISBN agencies may choose to issue an individual

   PROPOSED CHANGE: "Registration group ISBN agencies may choose to issue an
   individual ISBN to single title producers from a common registrant element block reserved
   for that purpose."

WG RESPONSE: . Agreed, although the phrase "single title publishers" will be used instead of
"single title producers". See response to Finnish comment under clause 3, above.

   EDITORIAL COMMENT: There is a misprint in the third line: publisher or

WG RESPONSE: . The words "or producer" have been deleted. See response to Finnish comment
under clause 3, above.
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Clause 4.5 (Publication element)

DIN (Germany)

   COMMENT: 4.5 “The publication element is allocated by the publisher …” This is true in
   many countries but not all, and for good reasons.
   PROPOSED CHANGE: It is proposed to add “usually”: “The publication element is usually
   allocated by the publisher”.

WG RESPONSE: Agreed – but to ensure that the word "usually" does not modify the requirement to
adhere to the specifications of Annex A, the 2nd sentence was revised to read: "The publication element
shall be allocated in accordance with the specifications of Annex A and is usually allocated by the
publisher of the monographic publication."

MSZT (Hungary)

   4.5
   COMMENT: Concerning the last sentence of the first paragraph see the commend ad 4.4

WG RESPONSE: Agreed. The last sentence was revised to read: "In certain cases, ISBN agencies
may choose to assign an individual ISBN to single title publishers from a common registrant element
block reserved for that purpose."


Clause 5 (Issuance of an ISBN)

Clause 5.1

MSZT (Hungary)

   5.1
   COMMENT: The term ISBN prefix is not defined as such and therefore it is disturbing to
   speak about "An ISBN or ISBN prefix …"

WG RESPONSE: Wording changed to: "A registrant element shall be allocated …".


Clause 5.5

SCC (Canada)

   We propose modifying clause 5.5 as follows (changes are shown by underlining):
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       5.5 Different product forms (e.g. Braille, audio book, video, online electronic
       publication) shall be assigned separate ISBNs. Each different format of an electronic
       publication that is published and made separately available shall be given a separate
       ISBN. For example, the PDF, Microsoft Word, and HTML versions of an electronic
       publication shall have separate ISBNs.

   The underlined sentence is based on one which formerly appeared in Annex A.7.4 of the final
   Working Draft but disappeared when most of A.7 was replaced by a general reference to
   clause 5. It is a useful elaboration of the general principle and should be restored at clause
   5.5.

WG RESPONSE: Examples have been included in the second sentence of clause 5.5 which now
reads: "Each different format of an electronic publication (e.g. ".doc", ".pdf" ".html") that is published
and made separately available shall be given a separate ISBN."

NSF (Norway)

   Clause 5.5
   COMMENT: More examples on formats
   PROPOSED CHANGE: (…)Different formats of publications, i.e. cloth, paperback, discette,
   shal be given individual ISBNs. Each different format (…)

WG RESPONSE: Hardcover and paperback were added to the examples.

MSZT (Hungary)

   5.5
   COMMENT: The enumeration should start by printed documents. The present form is
   misleading (i.e. it gives the impression that printed documents would be excluded)

WG RESPONSE: Agreed. See above response to NSF comment.

SAI (Australia)

   5.5 To remove uncertainty, this section could specifically refer to the need to allocate a new
   ISBN when an electronic publication is reformatted (e.g. when the format in which
   documents were originally on a web site become obsolete, and the publisher reformats them
   to a current format).
   Addition of a final sentence: "Electronic publications should be given an individual ISBN
   when reformatted."

WG RESPONSE: Not done. Reformatting alone does not imply publication.
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Clause 5.6

SCC (Canada)

   We propose modifying clause 5.6 as follows:

      5.6 A new ISBN shall be assigned if there have been significant changes to any part or
      parts of a publication or to its title. Small changes such as corrections of misprints shall
      not require new ISBN. A new ISBN shall not be assigned to a publication unchanged in
      edition or product form or publisher. A new ISBN shall not be assigned for changes in
      the price of a publication.

   The underlined specification formerly appeared in Annex A.7 of the final Working Draft. It
   disappeared when most of the section on electronic publications was replaced with a general
   reference to clause 5. Nevertheless it is a valid specification and should be restored as a
   general principle for issuance of an ISBN.

WG RESPONSE: Agreed. The last sentence of 5.6 was changed to: "A separate ISBN shall not be
assigned for changes in the price of a publication or for small changes such as corrections of
misprints."

European Booksellers Federation [via the International Booksellers Federation]

   Comment on point 5.6.
   One of the most difficult matters for booksellers are the issuing of ISBN-numbers for new
   editions of a book. The practices of publishers within a country varies, without even
   mentioning from country to country.

   5.6 states that: “A new ISBN shall be assigned if there have been significant changes to any
   part of parts of a publication or to its title. A new ISBN shall not be assigned to a publication
   unchanged in edition”.

   Some examples are given but it would be good if significant changes could be specified
   even more.

   The difficulty arises especially with schoolbooks. The publisher may give a new ISBN even
   is there are no significant changes and it might lead to situations were a teacher may not
   approve that a student uses an old book even if the contents do not differ.

WG RESPONSE: This will be elaborated in the Users' Manual which will explain the commercial
implications of using a new ISBN in such cases.

   Another difficulty arises with Print On Demand: how much should a book be changed to be
   defined to be a new edition and when should it be given a new ISBN?
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WG RESPONSE: For print on demand materials, changes in the product form and/or the content
and/or the pagination would necessitate a new ISBN. Changes in the cover and/or insignificant changes
in trim size would not. Guidelines will be provided in the Users' Manual.


Clause 6 (Location and display of ISBN on electronic publications)

SCC (Canada)

   Some useful specifications disappeared when parts of Annex A.7 (on electronic publications)
   in the final Working Draft were replaced or transferred to other sections of the standard. One
   of those was a specification concerning the display of multiple ISBNs for different formats of
   a publication.

   We propose restoring that specification somewhere in clause 6, perhaps by adding a new
   clause 6.4 that would apply to any type of publication (although most often to electronic
   publications):

       6.4 Display of multiple ISBNs
       In cases where ISBNs for different formats of a publication appear together on a
       publication (as may be the case with some types of electronic publication), the individual
       ISBNs should be listed below each other. Each ISBN in a list of multiple ISBNs shall be
       qualified by information on the specific format to which it refers.


WG RESPONSE: A new clause 6.4 on "Display of multiple ISBNs" was added, with some changes to
the proposed wording to remove the parenthetical statement since the specification should apply to
more than just electronic publications. The term "format" was also changed to "product form".
It was noted that metadata should also distinguish between multiple product forms and their respective
ISBNs.


Clause 6.2.2

DIN (Germany)

   COMMENT: 6.2.2 “The ISBN shall also be printed at the foot of the outside back cover if
   practicable.”
   PROPOSED CHANGE: It is proposed to delete: “if practicable”; the following sentence
   advises on what to do if it is not possible.

WG RESPONSE: Not done. The deletion would turn this specification into a requirement which
would then negate the sentence that follows.
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Clause 6.3.1

SAI (Australia)

   The instructions regarding where the ISBN should appear are sufficient for this standard.
   However, it might be advisable to provide further guidance on the concept of the title screen
   as a title page equivalent in the ISBN Users' Manual

WG RESPONSE: Clause 6.3.1 was changed to: "the page or screen that displays the title or its
equivalent (e.g. the initial screen displayed when the content is first accessed and/or on the screen that
carries the copyright notice)."

Clause 6.3.2 (Non-print product forms)

DIN (Germany)

   COMMENT: 6.3.2 “Non-print product forms”. The term is hardly appropriate here as
   electronic publications are also non-print.
   PROPOSED CHANGE: If the sub-heading should be kept, one would have to say something
   like: “Physical (or, perhaps: tangible) non-print product forms”

WG RESPONSE: The headings for clauses 6.3.2 and 6.3.3 were deleted.

Clause 6.3.3 (Visual display of content stored in electronic form)

DIN (Germany)

   COMMENT: The first paragraph largely duplicates 6.3.1.
   PROPOSED CHANGE: It is suggested to merge and consolidate both paragraphs.

WG RESPONSE: Done. Clause 6.3.1 was deleted and replaced with the former 1st paragraph of
6.3.3. The remaining specification of clause 6.3.3 (ISBN should be included in any metadata embedded
in the publication) will need further elaboration in the Users' Manual.


Clause 7 (Fees):

ANSI / NISO (U.S.A.)

   Section 7: Suggest that this section be re-written as follows:
       Fees may be charged for the assignment of ISBNs by appointed ISBN registration
       agencies. Any such fees shall be reasonable.
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   Rationale: This restatement separates the issue of charging a fee and the requirement that
   fees (if charged) must be reasonable.

WG RESPONSE: Agreed. The clause has been changed as proposed.


Clause 8 (Administration of the ISBN system):

DIN (Germany)

   COMMENT: The name (and address) of the International Agency are not given.
   PROPOSED CHANGE: This might actually go into Annex B.

WG RESPONSE: Because the governance procedures and funding model for the International
Agency are still under discussion, the name and address of the Registration Authority was not included
in the Committee Draft. This information will be specified at a later approval stage.

NOTE from SC 9 Secretariat: A description of any significant changes to the RA should accompany the draft
standard when it is circulated for approval by the ISO member bodies.

SCC (Canada)

   We note the (accidental) omission of the name and address of the Registration Authority for
   ISO 2108 (i.e. the International ISBN Agency) from this Committee Draft. This information
   must be specified in the text before it is distributed for approval as a Draft International
   Standard (DIS 2108).

WG RESPONSE: See response to DIN comment, above.

   Canada also hopes to see specifications accompanying DIS 2108 that will regulate the
   governance of the ISBN system and ensure adequate representation from national and
   regional ISBN agencies in the decision-making process for issues that affect the
   administration, scope, resources, and integrity of the ISBN system.

WG RESPONSE: Agreed. See response to DIN comment, above.


Annex A (Principles for the assignment and use of ISBN)

SCC (Canada)

   Loose-leaf publications: Annex A does not provide any explicit guidance on whether or not
      loose-leaf publications are eligible for ISBN. We doubt that the average user would think
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       to look for such guidance under the definitions of "continuing resource" and "ongoing
       integrating resource" in clause 3.3 and 3.5.

       A specific statement about which type of loose-leaf publication is eligible for ISBN and
       which is not should be added to the standard, either to the lists of inclusions and
       exclusions at A.1.9 and A.1.10 or as a new subclause somewhere between A.2 through
       A.7.
       For instance, the relevant indented items at A.1.9 and A.1.10 could be modified as
       follows. Changes are indicated by underlining:
            A.1.9 (list of inclusions): …
                -- publications which are not intended by the publisher to be regularly updated
                or continued indefinitely;
                -- individual sets of looseleaf additions or replacement sheets for updating a
                specific edition of a publication;

            A.1.10 (list of exclusions): …
                -- continuing resources including serials and ongoing integrating resources
                such as continually updated loose-leaf publications;

       For information, section 5.4 of the International ISBN Agency's Users' Manual says the
       following about loose-leaf publications that are eligible for ISBN.
          "5.4. Loose-leaf publications
          If a publication appears in loose-leaf form an ISBN is assigned to identify an edition at a given time.
          Individual issues of additions or replacement sheets will also be given an ISBN, when they are
          separately stocked."

WG RESPONSE: No change. Looseleaf publications are covered by the existing wording at A.1.9.
Specific details about eligible and ineligible types of looseleaf publications are better suited for the
Users' Manual.


Annex A.1.2

BSI (United Kingdom)

   [See U.K. comment on 3.4 (above) proposing that "different formats" should be "different
   product forms".]

WG RESPONSE: Agreed.

ANSI / NISO (U.S.A.)
   Editorial comment: A.1.2 "A separate ISBN..." may be "A unique ISBN. . . . " this change
   would eliminate the need for A.1.3.
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WG RESPONSE: Not done.

SFS (Finland)

   A.1.2
   "Different formats of a publication where these are made separately available shall be
   assigned separate ISBNs."
   PROPOSED CHANGE: - the more preferable sentence would be:
       …Versions of a publication in different product forms where these are made…

WG RESPONSE: No change; the existing wording is preferred.

Annex A.1.3

SFS (Finland)

   Annex A
   COMMENT: As declared in the later comments concerning the chapter 3 point 3.9 the logic
   between terms format and product form should be clarified in points A.1.3 and A.1.7.

WG RESPONSE: Done. See response to BSI comment, above.

Annex A.1.5

CSNI (Czech Republic)

   Each following edition – not only a revised one – should be assigned a separate ISBN,
   because a following edition can be unchanged and still not a reprint.

WG RESPONSE: No change.

SFS (Finland)

   Annex A
   COMMENT: As declared in the later comments concerning the chapter 3 point 3.9 the logic
   between terms format and product form should be clarified in points A.1.3 and A.1.7.

WG RESPONSE: Done. See response to BSI comment under "Scope" above.
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Annex A.1.8

DIN (Germany)

   COMMENT: “A new and separate ISBN” should read: “A separate ISBN”
   PROPOSED CHANGE: “A separate ISBN”

WG RESPONSE: Agreed.

Annex A.1.9 (examples of material to which ISBN may be assigned)

DIN (Germany)

   COMMENT: A.l.9: “including some types of publications available through print of
   demand”. The printing process is irrelevant for ISBN allocation; nevertheless it may be
   helpful for users to know that publishing on demand qualifies.
   PROPOSED CHANGE: Perhaps: “(in their various binding or formats; also print on demand
   items)”

WG RESPONSE: The reference to print on demand publications was deleted from A.1.9.

NSF (Norway)

   A.1.9 /A.1.10
   COMMENT: What about computer games based on literature? E.g. children’s literature,
   like Harry Potter. Should these games be included?

WG RESPONSE: The words “(e.g. computer games)” were deleted from A.1.10.

MSZT (Hungary)

   Annex A.1.9, Examples
   “publications which are not intended by the publisher to be regularly updated”.
   COMMENT: This excludes monographic publications to which update pages are supplied
   regularly, although these are monographic publications and not serials.

WG RESPONSE: See response to SCC comments regarding loose-leaf publications under Annex A.,
above.

    “educational/instructional films, videos and transparencies”.
   COMMENT: Probably these are educational (training) kits. The present description,
   however, is not clear because immediately the question appears: ”why other films, videos and
   transparencies are then excluded?”
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WG RESPONSE: No changes to the draft. The UNESCO Florence Agreement on the Importation of
Educational, Scientific and Cultural Materials (1950) allows books and similar educational materials
including educational films, videos and transparencies to be imported without customs barriers or
duties in countries that are signatories. Educational films, videos, and transparencies can also be
included with mixed media educational publications.

SFS (Finland)

   A.1.9
   Some examples of types…
   PROPOSED CHANGE:
       -printed books and pamphlets (and their various product forms)
       More detailed guidance is provided in a User’s Manual…

WG RESPONSE: A statement that "Further information is provided in the Users’ Manual available
from the International ISBN Agency" was added at the end of A.1.9.
The list of examples was rearranged according to medium and content.

Annex A.1.10 (examples of material to which ISBN shall not be assigned)

CSNI (Czech Republic)

   Even some serials can be assigned an ISBN [see above CSNI comment on 3.3] – e.g.
   yearbooks or monographic series).

WG RESPONSE: It is accepted practice for some publications to carry both an ISBN and an ISSN.
The ISSN is assigned to the title of the serial as a whole; the ISBN can be assigned to individual
volumes within the serial. Details will be provided in the Users' Manual.

DIN (Germany)

   COMMENT: A.1.10 “continuing resources including serials and ongoing integrating
   resources”. This is an unnecessary tautology (see 3.3).
   PROPOSED CHANGE: Therefore: “continuing resources” or “serials and onging integrating
   resources”.

WG RESPONSE: No change. The wording provides useful clarification for users.

BSI (United Kingdom)

   'Music sound recording' in A.1.10 should be changed to "sound recordings as abstract
   entities, although an ISBN may be assigned to a publication embodying a recording".
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   (NB This is to differentiate between items requiring ISRC and ISBN)

WG RESPONSE: No change. Music recordings, whether abstract or not, are excluded from the
ISBN.

SCC (Canada)

   1. Web sites: We note that Web sites were listed as exclusions in section A.1.10 of the final
   Working Draft (WG4 N26) but were removed from that list after the January 2003 meeting of
   the Working Group. There is no explanation as to why Web sites were removed from the list
   at A.1.10. The standard should state explicitly whether or not (or which) Web sites are
   eligible for ISBN.
   If the removal of Web sites from the list of exclusions was the result of a deliberate decision
   that ISBN should be assigned to some types of Web sites, then the difference between a finite
   (i.e. monographic) type of Web site and those which are "continuing resources" needs to be
   made very clear in section A.7.3 of the standard.
   However, the Canadian ISBN Agency would prefer that Web sites are excluded from the
   scope of the ISBN system and suggests restoring them to the list of exclusions at A.1.10.
   See also our comment on Annex A.7, below.

WG RESPONSE: The term "Web site" is a broad term that can encompass monographic publications
as well as continuing resources. For that reason, the standard will not refer specifically to "Web sites"
some of which would be eligible for ISBN as monographic publications. The treatment (i.e. inclusion
or exclusion) of Web-based publications will be handled in the Users' Manual.

   2. Print on demand publications: We note that the list at section A.1.10 of the final
   Working Draft (WG4 N26) specifically excluded customized print on demand publications
   from being eligible for ISBN, as follows:
       "[Some examples of the types of material to which an ISBN shall not be issued are:]
        – publications qualified in terms of content but available only on a limited basis, such as print on
       demand publications where the content is determined by the customer and not the publisher (e.g.
       it may comprise sections requested from several different publications), private or society
       publications where these are only available to members.".
   There is no explanation as to why this type of material was removed from the list of
   exclusions at A.1.10. Is it intended that some of those materials should be eligible for ISBN?
   If so, then additional guidance must be provided on how they are handled (e.g. in terms of the
   ISBN registration metadata in Annex E).
   We suggest that these materials be restored to the list of exclusions at A.1.10. Also see our
   comments on Annex A.6 (Print on demand publications), below.

WG RESPONSE: See response to SCC comment on A.6, below. Additional guidelines for print on
demand publications will be covered in the Users' Manual.
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   3. Ephemeral materials: The Canadian ISBN Agency suggests adding the following items
   to the list of types of material which shall not be assigned an ISBN:
         greeting cards (e.g. birthday cards, Christmas cards);
         calendars (including those which contain text);
         bookmarks (including those which contain text).
   We note that calendars and diaries are excluded from the scope of ISBN in the Users' Manual
   published by the International ISBN Agency. These items also appeared as exclusions in
   section A.1.10 of the final Working Draft (WG 4 N26). Is there a reason for removing them
   from the list of materials to which ISBN are not assigned?

WG RESPONSE: Greeting cards will be added to the list of exclusions at A.1.10. Calendars will not
be specifically listed as either an inclusion or exclusion.

ANSI / NISO (U.S.A.)
   Editorial comment: A.1.10, should be "assigned" not "issued"

WG RESPONSE: Agreed.

MSZT (Hungary)

   Annex A.1.10: “abstract creations such as textual, audiovisual and musical works”
   COMMENT:: The term “abstract creation” is not defined. An abstract textual work can be
   e.g. a monograph.

WG RESPONSE: Because, strictly speaking, abstract creations have no physical or electronic
embodiment and therefore are not "types of material" they were removed from the list at A.1.10. A new
clause A.1.11 was added as follows:
        "A.1.11 ISBN shall not be assigned to abstract entities such as textual works and other
abstract creations of intellectual or artistic content. For example, each specific product form of the
novel "Moby Dick" is eligible for an ISBN but the novel itself, as an abstract textual work, shall not be
assigned a separate ISBN."
If necessary, further guidance can be provided in the Users' Manual.

Annex A.2 Multi-volume publications

ANSI / NISO (U.S.A.)

   Editorial comment: A.2, third sentence "title verso" should be "title page verso"

WG RESPONSE: Agreed.
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Annex A.3 Publications issued as part of a series

SCC (Canada)

   We suggest modifying A.3 as follows (changes indicated by underlining):
       "A.3 Publications issued as part of a series
       When a publication is issued both as an individual publication and as part of a series,
       each aspect of that publication shall be treated as a separate edition, each of which shall
       be assigned its own ISBN."

   We also note that the definition of a series was deleted from clause 3 when the final Working
   Draft (WG4 N26) was prepared as a Committee Draft. In its place we propose a simpler
   definition of "series", based on a definition in the Anglo-American Cataloguing Rules:
        series: A group of separately available publications related to one another by the fact
        that each of them bears, in addition to its own individual title, a collective title applying
        to the group as a whole. The individual items may or may not be numbered.

WG RESPONSE: The wording of A.3 was changed to: "When a publication is made available to the
public both individually and as part of a series that will be completed within a finite number of parts it
should be regarded as two separate publications, each of which should be assigned a separate ISBN."

The item on "continuing resources" in the list of exclusions at A.1.10 was amended to read: "continuing
resources (e.g. serials, series without predetermined conclusion and ongoing integrating resources;".

ANSI / NISO (U.S.A.)

   Section A.3: This section needs clarification as it is not clear if the intention is to identify a
   series or a set (a group of publications that are a single unit). It may be necessary to add a
   definition to Section 3.

WG RESPONSE: See response to SCC comment above.


Annex A.4 (Co-publication)

DIN (Germany)

   COMMENT: While the present wording is certainly correct, we have many co-publication
   projects that cover several countries, or continents, and publishers divide their marketing
   areas: A fills orders from America, B from Asia.
   PROPOSED CHANGE: The wording should make allowance for the fact that there may be
   two or even more publishers responsible for distribution.
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WG RESPONSE: Clause A.4 was changed to read:"When a publication is published jointly or as a
co-edition by two or more publishers, each of the co-publishers may assign its own ISBN and display
each of them on the copyright page. However, only one ISBN shall be displayed as a bar code on the
publication."

ANSI / NISO (U.S.A.)
    Editorial comment: A.4, 2nd line, "may also assign its own ISBN"

WG RESPONSE: Done. See response to DIN comment, above.

SCC (Canada)

    With the increase in self-publishing, the Canadian ISBN Agency has seen a number of cases
    where a self-publisher arranges for the printing of their publication by two separate printers in
    different countries. Although the imprint of both printed versions is identical, the publisher
    assigns separate ISBNs to each printing for the purposes of their internal inventory control.
    The recommended procedure, however, should be to assign only one ISBN in the case of co-
    printing a single edition of a title. Could the issue of "co-printing" also be addressed in this
    section of the standard?

WG RESPONSE: This can be addressed in the Users' Manual, rather than in the standard itself.

European Booksellers Federation [via the International Booksellers Federation]

    Comment on A.4 Co-publication:
    This rule works well within one country but there are also co-editions with publishers from
    different countries. Enclosed is a copy of the back page of a co-edition of the Finnish
    publisher Söderström C:o and the Swedish publisher Atlantis. You can see that the country
    code for Finland is 951 and for Sweden is 91. It is very important for the booksellers in these
    countries that the ISBN and the bar code is printed on the back cover so that it can be read by
    the POS (Point of Sale = cash register). It should therefore be allowed to have more than
    one ISBN number + bar code if the publishers are from different coutnries.
    [NOTE: An image was also supplied with the above EBF comment, showing a co-published book with two
    ISBNs and barcodes, one set below the other]

RESPONSE: The EBF comment was withdrawn.
         "EBF has done some further investigations concerning using two EAN bar codes for a book co-
published in two countries. It seems that it is only used between some publishers in Sweden and Finland and
that so far it concerns only a handful of titles. As this is an exception from the main rule and only concerns an
exceptional case and as two EAN bar codes might cause confusion EBF is withdrawing its proposal and
accepts that there should only be one bar code at the back of a book. However, it is important that it is allowed
to use two different ISBN codes for a co-publication."

ICONTEC (Colombia)
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   Annex A. 4 - CO- PUBLICATION: This clause shall be as follows:
      "If a publication is published jointly or as a co-edition by two or more editors, the ISBN
      will be assigned to the editor responsible for distribution."

   The request is made since in the case of national co-publications, if the ISBN is assigned to a
   same title by each co-editor, the statistics derived from this ISBN (such as production of
   titles, number of copies, etc) would be altered. Additionally, a title would be identified with
   more than one ISBN.

WG RESPONSE: No change. See response to DIN comment above.

Annex A.5 (Reprints)

DIN (Germany)

   COMMENT: A 5.1 and A 5.3 are widely identical and should be merged.
   PROPOSED CHANGE: should be merged

WG RESPONSE: Clause A.5.1 was deleted.

ANSI / NISO (U.S.A.)

   Section A.5.2: This section requires clarification. It is not clear why this would be needed if
   the new imprint is encompassed by the same publisher entity.

WG RESPONSE: The wording was changed to "A separate ISBN may be assigned if …".

Annex A.6 (Print on demand publications)

SCC (Canada)

   Annex A.6, 1st paragraph (and definition in 3.8): The draft needs to be clearer about the
   distinction between the two different aspects of "print on demand", i.e. those which support
   "just in time" inventory supply vs. those which involve customisation of the product. Since
   customised products should not receive ISBN, the standard should clearly distinguish
   between these two aspects when it uses the term "print on demand".
   The definition at 3.8 could continue to cover both aspects of print on demand. However, the
   1st paragraph of A.6 should be elaborated to explain that print on demand publications which
   are eligible for ISBN generally entail a process where a limited print run of exact copies is
   produced at a client’s request from a master version.

WG RESPONSE: No change.
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   We also propose changing "should" back to "shall" in the 2nd paragraph of A.6 (i.e. exclude
   customised and personalised products). If not, please illustrate how such materials would be
   handled in terms of the recommended metadata for ISBN assignments.

WG RESPONSE: Agreed. The second sentence of A.6 now reads:
   "A print on demand version of a publication where the content has been specifically customized or
personalised for a user and which has limited availability shall not receive an ISBN."

   This section of the final Working Draft also contained some useful guidance on when to
   assign ISBN to print on demand publications in situations involving the transfer or sale of
   rights to an edition. Those specifications disappeared from the draft standard when most of
   section A.6 was replaced by a simple reference to clause 5.5. We suggest either restoring
   those specifications to A.6 or adding them to clause 5.5. They should also be rephrased
   slightly for the sake of clarity.

   For reference here is what appeared in section A.6 of the final Working Draft (WG4 N 26).
   The missing specifications are indicated by underlining.
        A.6 Print on demand publications
        A new ISBN shall be assigned to a print on demand version of an edition of a publication where
        the text remains the same but the edition by the same publisher is in a different format.
        A new ISBN shall be assigned to a print on demand version of an edition of a publication where
        the print on demand rights have been bought by a publisher to another publisher's publication.
        A new ISBN shall be assigned to a print on demand version of an edition of a publication when it
        is produced by an organization other than the publisher on behalf of that publisher (no rights have
        changed hands), and where the print on demand edition takes the place in the market place of
        the publisher's printed edition in a different format.
        A print on demand version of a publication where the content has been specifically customised or
        personalised for a user and which has limited availability shall not receive an ISBN.
   Also see our comments regarding print on demand publications in section A.1.10, above.

WG RESPONSE: No further changes. The basic rules in clause 5 apply to print on demand
publications. Additional guidance on handling these materials can be provided in the Users' Manual.

Annex A.7 (Electronic publications)

SCC (Canada)

   We propose that Annex A.7 be revised as follows. Changes from the current wording are
   underlined.

       A.7 Electronic publications
       A.7.1 Electronic publications are subject to the basic rules specified in clause 5 for
       issuance of an ISBN.
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       A.7.2 Where a monographic publication is available electronically (e.g. an e-book, CD-
       ROM or publication available on the Internet) it will qualify for ISBN provided that it is
       offered for general distribution.
       A.7.3 Continuing resources issued in electronic form shall not be assigned an ISBN.

WG RESPONSE: Clauses A.7.2 and A.7.3 were deleted. Clause A.7 now reads: "Electronic
publications are subject to the basic rules specified in clause 5 for assignment of an ISBN."

   See our comment on A.1.10 concerning the eligibility of Web sites. If the intention is that
   ISBN should be assigned to some types of Web sites, then the difference between a finite (i.e.
   monographic) type of Web site and those which are a "continuing resource" needs to be made
   clear in the standard.

WG RESPONSE: These distinctions are better suited for elaboration in the Users' Manual.

   For the record, the Canadian ISBN Agency would prefer to have Web sites excluded from the
   scope of the ISBN system and suggests restoring Web sites to the list of exclusions at A.1.10.

WG RESPONSE: See earlier response to similar SCC comment on A.1.10, above.

   We are also proposing that some of the detail which formerly appeared in this section at the
   Working Draft stage should be restored. See our comments on clauses 5.5 and 5.6 (above).

DIN (Germany)

   COMMENT: A 7.1 covers also A 7.2 and A 7.3. The additional feature of A 7.2 is that it
   should be “offered for general distribution”. On “distribution” see comment on 3.7. In the
   Internet it would not so much be a matter of “distribution” but of access. Many people may
   neither have the hardware nor the funds to access high priced scientific material in electronic
   form while they would be able to access it in bookshops or libraries. This could be interpreted
   as “limited access”.
   PROPOSED CHANGE: It is proposed to delete A.7.2 in its present form, as well as A.7.3
   which was explained before.

WG RESPONSE: Agreed. A.7.2 and A.7.3 were deleted.

ANSI / NISO (U.S.A.)
   Editorial comment: A.7.1 "assignment" not "issuance"
   Editorial comment: A.7.2: "for ISBN" -> "for an ISBN"

WG RESPONSE: A.7.1 was changed to "assignment" as suggested. The same change was also made
to the title of clause 5. A.7.2 was deleted (see response to DIN comment, above).
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SAI (Australia)

   A.7.1 and A.7.3 Each of these requirements is a re-statement of the guidance previously
   given in clause 5 and A.1.10. Review the need for a separate requirement.

WG RESPONSE: A.7.3 was deleted. A.7.1 is a reference to the basic rules in clause 5.

   A.7.2       The requirement that publications be "offered for general distribution" to be
   eligible for an ISBN is not specific to electronic publications. Add final sentence to A.1.2:
   Publications are only eligible for an ISBN if they are offered for general distribution.
   "General distribution" is not defined in the standard. Consider adding sentence to define
   "General distribution".
   This category could usefully be added to the exclusions in A.1.10. Add category to A.1.10:
   "Documents intended for internal distribution only, e.g. electronic documents published on an
   Intranet."

WG RESPONSE: A.7.2 was deleted.


Annex B (Administration of the ISBN system)

Annex B.2.3

ICONTEC (Colombia)

   ANNEX B - Administration of the ISBN system
   B.2.3. In this clause, it shall be taken into account that in Colombia, the ISBN is granted by
   the Cámara Colombiana del Libro (Colombian Chamber of the Book) by the Law 98 of 1993,
   Chapter III - Article 11: "Every book edited and printed in the country shall have printed on it
   the International Standard Book Number ISBN (standard number of book international
   identification), granted by the Cámara Colombiana del Libro (Colombian Chamber of the
   Book), without which, the editor will not be able to invoke the benefits of this law".

WG RESPONSE: No change to the standard. As the Registration Authority for ISO 2108, the
International ISBN Agency appoints ISBN registration agencies.
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Annex B.2.5

CSNI (Czech Republic)

   In addition to maintaining an accurate register of „publisher identifier“ (registrant element)
   the International ISBN Agency should make available also international publishers´ directory
   (PIID) to other ISBN agencies like it has been so far.

WG RESPONSE: Not done.

Annex B.2.9

ANSI / NISO (U.S.A.)
   Editorial comment: B.2.9 "assignments" not "applications"

WG RESPONSE: Agreed. See response to DIN comment, below.

DIN (Germany)

   COMMENT: [At B.2.9] “ISBNs for monographic publications” – this wording might imply
   that ISBN may be given to non-monographic publications.
   PROPOSED CHANGE: Delete “for monographic publications”

WG RESPONSE: Agreed. The sentence now ends: "… of duplicate assignments of ISBNs."

Annex B.2.10.

ICONTEC (Colombia)

   B.2.10. When the Cámara Colombiana del Libro (Colombian Chamber of the Book) rejects
   an ISBN and the editor appeals the decision to the International Agency, the latter shall take
   into account that the Law of Book (Law 98 of 1993) grants tax benefits to publications with
   scientific and cultural character that have the ISBN. Chapter V - Article 23: "Books,
   magazines, brochures or seriate collections of scientific or cultural character, newspapers and
   periodic publications, whatever their origin, will be continuously exempted of sales tax
   payment". For this reason, we suggest that when any of these cases described in B.2.10
   occurs, the decision should be agreed by the two parties.

WG RESPONSE: No change to the standard. As the Registration Authority for ISO 2108, the
International ISBN Agency has responsibility for arbitrating the matters described in B.2.10.
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Annex B.3.4.

DIN (Germany)

   COMMENT: [At B.3.4] “Correct inaccurate ISBN metadata”
   PROPOSED CHANGE:               should probably read “correct inaccurate ISBN and ISBN
   metadata”

WG RESPONSE: Agreed (this clause renumbered as B.3.6).

SFS (Finland)

   Annex B.3
   COMMENT: We suggest that the point 3.4 and 3.6 should change places with each other in
   order to make the chronology more specific.

WG RESPONSE: Agreed.

   Annex B.3.4
   COMMENT: We suggest that the word valid is added to clarify the purpose.
   PROPOSED CHANGE: Correct inaccurate ISBN metadata if valid proof of such inaccuracy
   is provided

WG RESPONSE: No change.


Annex C (Check digit for the 13 digit ISBN)

ANSI / NISO (U.S.A.)

   [See comment on clause 4.1, above, regarding consistency on the use of hyphens]
   Section C.4 states that hyphens "may" be used.
   It is suggest that "should" be used in Section C.4.

WG RESPONSE: Agreed. The wording was changed to "hyphens should be used".

SCC (Canada)

   Is there another way of explaining the check digit calculation than this formula which
   appears with the Table at C.4:
      "Check digit = mod10 (10 – mod10 (Product Total)) = mod10 (10-mod10 (81)) = 9"
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    Could this formula be supplemented by a more "user-friendly" explanation? This is an
    important implementation issue. Ensuring that users understand the method of check digit
    calculation will help them to create and/or distinguish valid (i.e. correctly converted) 13-digit
    ISBN.

    As a starting point, here is the explanation of the 10 digit ISBN check digit from the
    Canadian ISBN Agency's 1984 Users' Manual:
       _________ Start of excerpt: Canadian ISBN Users' Manual (1984) __________

       A check digit is a device that guards against a computer accepting a “wrong number”, and in
       consequence supplying the wrong book.

       When an ISBN is fed to a computer, the first operation of the machine is to ensure that the
       number is a valid one. It does this by performing an exercise in multiplication by which every digit
       in the group, prefix and title parts of the ISBN is successively multiplied by the numbers, 10, 9, 8,
       7, 6, 5, 4, 3, 2; these multipliers are called “weights” (see example below). After the
       multiplications have been done, the results are added together to form a total to which is added
       the check digit itself. This final total is then divided by what is termed a modulus. The ISBN
       system will always use modulus 11. If there is no remainder after the total has been divided by 11,
       then the ISBN has been proved valid and is accepted by the computer. If there is a remainder, the
       number is rejected.

       EXAMPLE

       Products           Group identifier   Publisher Prefix   Title Number       Check Digit
       ISBN                   0                  8020                4612                   6
                          x                  x                   x
       Weight                 10                 9876                5432
       Products               0 +                72+0+14+0           20+24+3+4     plus 6

                         Total: 143
       As 143 can be divided by 11 without a remainder, 0-8020-4612-6 is a valid International
       Standard Book Number.

       _________ End of excerpt: Canadian ISBN Users' Manual (1984) __________

WG RESPONSE: The above explanation from the Canadian manual is written from a different
premise, i.e. validating that the check digit is correct (instead of how to actually calculate the check
digit). . The formula given in the standard is what is needed for programming purposes. The Users'
Manual would be the appropriate place for further explanation. A reference to the Users' Manual was
added to Annex C.
For reference, the EAN.UCC has a Web site on its method of check digit calculation at:
<http://www.ean-int.org/cdcalcul.html>. A similar site for the 13-digit ISBN will be considered as part
of the implementation plans.
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ANSI / NISO (U.S.A.)
   C.4: The formula could be explained more simply as:
      Check digit = 10 - mod10 (Product Total)
   Rationale: 10 minus a mod10 number is by definition mod10 already.
   Editorial comment: Some column lines seem to be missing from the chart in C.4.

WG RESPONSE: No change. Missing column lines only occur in PDF prints on the standard.

SFS (Finland)
   Annex C
   COMMENT: A reference to the Annex F.2 is needed here as follows.
   PROPOSED CHANGE: Calculation of the check digit for a 10 digit ISBN is represented in
        the Annex F2

WG RESPONSE: No change. All matters relating to the 10-digit ISBN are covered in Annex F.
There is no need to add a reference in this particular section.


Annex D (Method for assigning ranges of ISBN)

SFS (Finland)

   Annex D, Tables 2, 4, 6
   COMMENT: The interpretation of the tables ( especially 2, 4 and 6) is difficult to follow for
   those who are not quite involved with the method of deriving the internal structure for
   registration groups. Therefore more explanation with text and concrete examples would be
   requested.

WG RESPONSE: Examples have been added, along with an introductory paragraph clarifying the
intended purpose and audience of this Annex.

   Annex D, Tables 3, 5
   COMMENT: The first heading in tables D.3 and table D.5 should be corrected for example
   as follows.
   PROPOSEDCHANGE: Registration group Element
                   (978)-0
              or
                   EAN.UCC prefix element and registration group element

WG RESPONSE: The word "element" was removed from the header of the first columns of Tables
D.3 and D.5.
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CSNI (Czech Republic)

    There is no structure of ranges of ISBN with the prefix 979 and examples presented. With
    the ISMN system retained, using some ranges of numbers from the block of 979, these two
    blocks (with 978 and 979) cannot be identical and the structure and examples as presented
    for 978 cannot be used also for 979.

WG RESPONSE: The 979 prefix range is not yet in use so examples would be misleading at this
point in time. However, the last two sentence of the 2nd paragraph (now D.2) have been revised for
clarification. As ranges are defined within the 979 prefix, they will follow the same pattern described
in Annex D.

DIN (Germany)

   Annex D provides helpful tables and explanations to interpret ISBN and their ranges. But it is
   hardly, as the heading implies, a “Method for assigning ranges of ISBN”. It is suggested to
   change the heading, perhaps to “Ranges of ISBN”

WG RESPONSE: Agreed.

   Also, a note may be useful to state that the examples given reflect the state of affairs in a
   given year because there will be changes, e.g. for group no. 6. It would probably not be useful
   to initiate a standard revision because of this.

WG RESPONSE: Shifting ranges is a problem. The derivation of ranges should be regulated to
ensure the ability to programmatic validation of any component of the ISBN. This will be addressed in
an introductory clause.




Annex E (Metadata for the registration of assigned ISBN)

Annex E.1

SCC (Canada)

   Annex E.1.1. In terms of the 2nd sentence of E.1.1, the Canadian situation is that "core
   metadata associated with each ISBN assignment" is captured principally through the national
   Cataloguing In Publication program and is maintained by the national bibliography. This
   situation is not unique to Canada; most ISBN agencies hosted by national libraries would
   probably have similar arrangements.
   Our concern is that this situation does not appear to be covered by E.1.1 which specifies that
   core metadata should be maintained either by the registration agency "or by its designated
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   registration service". It is not clear whether the term "registration service" would cover a
   national bibliography. We suggest changing the wording to:

       "The core metadata associated with each ISBN assignment should be maintained by the
       ISBN registration agency or by its designated bibliographic agency."

WG RESPONSE: Agreed. An equivalent change was also made to the second sentences of annexes
B.3.4 and B.3.5 which were reworded as follows: "Tasks involving ISBN metadata may be delegated to
a designated bibliographic agency acting in compliance with the specifications of this International
Standard."

SAI (Australia)

       Quality, accuracy and consistency of metadata content are not mentioned. Some general
       observations are: typographical errors cause problems in matching records; variations in
       the use of upper and lower case present poorly in bibliographic services based on this
       data. Add clause to E.1 to specify quality, accuracy and consistency requirements.

WG RESPONSE: No change.

Annex E.2

SCC (Canada)

   Annex E.2. See our comments about print on demand materials at A.1.10 and A.6, above. If
   customised and personalised products may be eligible for ISBN (although please note that we
   would prefer to have them excluded), how would such products be differentiated in terms of
   the ISBN metadata?

WG RESPONSE: Comment taken care of by the decision that personalized materials are not eligible
for ISBN. See response to A.1.10, above.

ANSI / NISO (U.S.A.)
   Annex E, Section E.2.2. (chart):
   Publisher: Suggest it be rewritten as follows:
      The legal entity. . . .

WG RESPONSE: The wording was changed to “person or organisation”.

   Editorial comment: E.2.2 chart: "Imprint" uses the word "imprint" in the definition;
   suggest that "publication, distribution, etc." be used instead.

WG RESPONSE: The word "imprint" was replaced by the term "brand name”.
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   Editorial comment: E.2.2 chart: Publication date: Thedate -> The date
   [Secretariat's note: The same editorial correction was submitted by MSZT (Hungary), edmm]

WG RESPONSE: The correction will be made.

MSZT (Hungary)

   Annex E.2.2:
   COMMENT: Imprint – Publisher - The relation between "publisher" as such and publishers
   name as a part of imprint data is mixed up.

WG RESPONSE: See response to the U.S. comment, above.

NSF (Norway)

   E.2.2
   COMMENT: The title field: Series title should be separated in its own field.

WG RESPONSE: A separate field will be added for "Series title and enumeration" with the
annotation "When applicable".

SFS (Finland)

   PROPOSED CHANGE:
       E.2.2 Elements of ISBN metadata shall include, at a minimum, the following
       Publisher
       the legal person or organization that owns the imprint at the date of publication

WG RESPONSE: The wording was changed to "Person or organization that owns…". See response
to U.S. comment, above.

SAI (Australia)

       E.2.1 To be usable, the coding for product form and contributor role model need to be drawn from a
       standard list. This paragraph should state that they should comply with the ONIX International product
       information standards, rather than just be compatible with them. Add final sentence: Coded data should
       comply with ONIX Product Information Guidelines codelists.

WG RESPONSE: No change. Compliance could be a problem for ISBN agencies tied to national
bibliographies. A reference to the complete ONIX code list will be given in the Users' Manual.
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       E.2.2 Variations in the form of contributor names in ISBN metadata may result in
       records failing to match when loaded to bibliographic services such as national union
       catalogues. Depending on the system, records may load and create multiple index entries
       for the same author, or may be routed to human review. Contributor names need to
       comply with a recognised authority file.
       Add a requirement to provide names that comply with a recognised authority file which is
       appropriate to the country of publishing or the ISBN Agency.

WG RESPONSE: Not done.

       E.2.2 Country codes as specified in ISO 3166-1 are insufficient for Australian usage.
       Codes at the state level are critical for efficient exchange and loading of data, and to the
       retrieval of Australian materials. ISO 3166-2 Country subdivision codes would provide
       an appropriate level of granularity for Australian materials.
       Specify ISO 3166-2 codes for Australia, and consider using ISO 3166-2 codes for all
       countries.

WG RESPONSE: This can be by individual ISBN agencies if desired but it will not be required as
part of the minimum set of ISBN metadata.

Annex E.3

SCC (Canada)

   Annex E.3, 2nd line: We suggest changing "work with bibliographic services" to "work with
   bibliographic agencies"

WG RESPONSE: Agreed. The change will be made.


Annex F (ISBN in the 10-digit format assigned prior to implementation of the
fourth edition of ISO 2108)

CSNI (Czech Republic)

   Because the method of calculation the check digit in the 10-digit format for its converting
   into a bar code is different then its calculation for the 13-digit format it will not be possible to
   change automatically all 10-digit ISBNs in present databases into 13-digit ones. Will the
   standard advise how to do it?

   At the same time it will not be possible to preserve the present method of conversion the eye-
   readable ISBN into a bar code; it will be necessary to prepare for publisher quite new blocks
   of 13-digit ISBNs and replace the old ones which they use.
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WG RESPONSE: The current Annex F.3 shows how to recalculate the check digit. Further
guidelines will be developed and made available as part of implementation planning.

DIN (Germany)

   Annex F (which is only “informative”, however) raises grave concerns of a general nature:
   The problem is the implementation of the 13 digit ISBN and the compatibility with the 10
   digit ISBN. It may justly be said that this will be a challenge for the worldwide ISBN network
   and that the issue will have to be dealt with on a practical, not the standard level. Right. The
   present CD, however, widely ignores the existence of the 10 digit ISBN and thus tacitly
   implies that of a date X only 13 digit ISBN will be there.
   It is mainly the not normative Annex F which makes reference to the 10 digit number and
   gives useful advice on the conversion process. In addition it says (F 1): “For this reason the
   10 digit ISBN, should only be used for historical purposes”. While the “historical purposes”
   are not specified, F 4.3 says cautiously: “It is recommended that for trade applications all
   existing references to the 10 digit ISBN structure … be converted to the associated 13 digit
   ISBN structure”. These recommendations make a lot of sense because every ISBN user must
   be interested in having one homogenous system.
   The discussion on conversion and implementation is still going on, and it would not be useful
   to make long statements here on this issue which, to a large extent, will have to be detailed
   somewhere else. For the purpose of this CD, it may suffice to make a few points:
       - While the proposals of Annex F are perfectly reasonable, they are hardly practical:
          There are millions of ISBN around, and there is no way of converting them all.
       - Libraries and catalogues have been using the ISBN for decades, and there would be
          no benefit in converting the numbers – especially as they are printed in 10 digit form
          on the publications themselves.
       - If the ISBN system consisted of the G 7 countries only there might be some chance of
          getting to the Annex F solution. But there are more than 160 countries in the network.
          Who is going to instruct the publishers and booksellers in Egypt, Georgia, Ecuador …

   The most PRACTICAL approach would be:
      -    To leave the currently used ISBN contingent (978) as is.
      -   The trade has no problem with reading (bar code!) and handling the ISBN of this
          contingent.
      -   All assignments from the 979 contingent would be exclusively 13 digit.
      -   Conversions would not be necessary.
      -   Many countries and many publishers will have enough ISBN for many years to go –
          benefit: no cost for major changes.
      -   The 13 digit ISBN is compatible with the regular EAN article numbers, and therefore
          processing should not necessitate huge changes.
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   In this context there is no need to go deeper into the subject. For the mentioned reasons it is
   proposed to leave out or modify the last part of the 2nd § of F 1 and drop, or re-phrase F 4. It
   might be stated, for example that the implementation of the 13 digit ISDBN and the
   compatibility with the 10 digit ISBN would be dealt with in a special document on the level
   of the ISBN User’s Manual.

WG RESPONSE: Suggested changes to F.1 or F.4 not done. However, the general concerns will be
dealt with in developing implementation guidelines.

SFS (Finland)

   COMMENT: A reference to the Annex C from the Annex F.2 is needed.

WG RESPONSE: Not done. There is no reason to link the check digit for the 10-digit ISBN to the
method of check digit calculation for the 13-digit ISBN.

SCC (Canada)

   Annex F.2 (p. 16): Is there another way of explaining the check digit calculation than the
   formula which appears with the Table at F.2, i.e.:
       "Check digit = mod11 (11 – mod11 (Product Total)) = mod11 (11-mod11 (144))= 10"
   Could this formula be supplemented by a more "user-friendly" explanation?               See our
   comment on Annex C.4, above.


WG RESPONSE: See earlier response to same Canadian comment on Annex C.

ANSI / NISO (U.S.A.)
   Editorial comment: F.1, last sentence: delete the comma

WG RESPONSE: The change will be made.


Bibliography

SFS (Finland)

   COMMENT: The reference to the DOI (Digital Object Identifier) should be cancelled.

WG RESPONSE: The DOI reference in the Bibliography will be retained. A reference to the URN
will be added.


                                           _____________
ISO TC 46/SC 9 N 360
          2003-07-25
             page 45

				
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