Discussion Paper on Non-ASCII Top-Level
Domain Policy Issues
13 June 2002
The purpose of this discussion paper is to outline the ICANN IDN Committee's
current preliminary thinking with respect to strategies for the selection
of non-ASCII top-level domains (TLDs). As
such, the paper deals with a speculative future that is possible, but
by no means guaranteed: namely, a future in which the IDNA standard
currently under consideration by the IETF becomes deployable at the TLD
level. For that future to become reality, a number of contingencies
would have to occur, including rigorous testing of non-ASCII TLD strings
(meaning, more accurately, their ASCII LDH encodings) in the root zone
environment. As part of its charter, however, the ICANN IDN Committee
is tasked with anticipating the policy issues that would arise if and
when ICANN confronts demonstrably deployable non-ASCII TLDs.
With that caveat in mind, this paper outlines the broad policy analysis
undertaken by the committee to date, including a preliminary framework
for selection of registry operators for non-ASCII TLDs. The paper
reviews some advantages and disadvantages of each of the proposed approval
mechanisms. It concludes by outlining a process designed to garner ICANN
community feedback and commentary on sequential drafts of this paper before
the committee submits its final report to the ICANN Board later this calendar
The committee welcomes feedback on the contents of this discussion paper.
Because the concept and technical implementations of Internationalized
Domain Names are "works in progress", the committee emphasizes
that the information and views contained in this discussion paper may
become inaccurate or outdated. Comments should be sent to <email@example.com>.
In simple terms, the committee's current thinking focuses on extending
to the IDN namespace existing policies and concepts for the creation of
ASCII generic TLDs (gTLDs) and ASCII country-code TLD (ccTLDs), which
have been developed and refined over time, while giving due consideration
to additions and variations in policy to take into account unique factors
related to the use of non-ASCII characters within the DNS.
This paper suggests a tentative framework for classifying possible non-ASCII
TLDs. The rationale for classification is a recognition that different
types of TLDs (whether ASCII or non-ASCII) may require different selection
mechanisms, depending upon the peculiar policy considerations that arise
in connection with each category. For example, as elaborated below,
current ICANN policy provides different selection mechanisms for ccTLDs
A comprehensive selection and implementation process for non-ASCII TLDs
would include a number of steps, including:
- Finalization of IDNA standard;
- Decision to proceed to adopt non-ASCII TLDs;
- Root zone implementation testing;
- Selection of registry operators; and
- Registry-level testing and deployment.
It is anticipated that the ICANN IDN Committee will publish a further
paper that considers the issue of potential non ASCII TLD selection processes
and criteria in the near future.
In thinking about the creation of non-ASCII TLDs, the committee began
with the existing ICANN policy baseline for the creation of new TLDs,
including the principles that (1) TLD expansion should occur in
a careful and controlled fashion, with regard for the overall stability
of the DNS; (2) the sudden introduction of a massive number of new
TLDs would be a bad idea; (3) a new TLD can only be created if there
is a willing and able registry operator to run it; and (4) different
categories of new TLDs may require different contractual, policy, and
selection frameworks; and (5) the selection process should be transparent,
allowing key stakeholders to participate in it.
The committee has generally agreed on two additional principles that
relate specifically to non-ASCII TLDs, namely: (6) the core purpose
of introducing non-ASCII TLDs would be to make the DNS service easier
to use for Internet users whose native languages include non-ASCII characters;
and (7) a new TLD should be introduced only if some sort of user demand
can be demonstrated to exist.
For purposes of this discussion paper, the committee takes as its hypothesis
the notion that potential new TLDs should logically be classified according
to the evident semantic meaning of the TLD string itself. In other
words, a given TLD string should be understood as having a certain intended
meaning, should be classified accordingly, and should be matched to an
appropriately tailored selection process.
The committee notes that the potential for semantic ambiguity exists
when different non ASCII TLDs are interpreted by Internet users who speak
different languages. While every reasonable attempt will be made to minimize
such ambiguities, it is impossible to eliminate this problem altogether.
The committee further notes that at least the following policy issues
are highly likely to require consideration in the future:
- Nothing within any future non ASCII TLD space constrains names or
labels to be in any language at all. For example, nothing in the
protocols would prevent a domain label from being created (at the top-level
or otherwise) that consists of a Chinese character, followed by a roman-derived
character, followed by a Thai character, followed by an Arabic character,
followed by a Cyrillic character, etc.
- Even if IDNs compatible with a given language at the second level
of the TLD are permitted, enforcement of a restriction at the third
or fourth level or beyond is likely to prove challenging.
These issues will be dealt with in greater detail in the committee's
final report to the ICANN Board.
The concept of semantic meaning is central to this analysis. For
example, the .info TLD was treated as global and unrestricted, on the
basis of the semantic link between the term "info" and the concept of
"information." The .biz TLD is restricted to business registrants,
on the basis of the semantic link between the term "biz" and the concept
of "business." The .museum TLD is restricted to museum registrants,
on the basis of the semantic link between the term "museum" and the community
of "museums." In the realm of the country-code TLDs, there is a
semantic link between the assigned two-letter codes and the name of the
associated geographic unit. Thus, .no is semantically linked to
Norway, .us to the United States, .za to South Africa, and .ch to Switzerland.
Under longstanding IANA policy (see RFC-1591 and ICP-1),
codes are taken strictly from the ISO-3166-1 table (with a few historical
exceptions), meaning that IANA/ICANN stays out of the business of determining
what is and is not a country (or geographically distinct territory), and
what name or abbreviation is semantically associated with any given geographic
unit. Those problems are properly excluded from the ICANN process,
and resolved by a politically expert, internationally-recognized body,
the International Organization for Standardization and its
ISO 3166 Maintenance Agency.
Following from these premises, the committee undertook to imagine the
DNS namespace as a whole (including ASCII and non-ASCII TLDs), and to
attempt a general (and probably incomplete) classification of potential
TLD strings, oriented around semantic meaning.
The following basic categories were identified:
- Semantic association with Geographic Units.
- Semantic association with Languages.
- Semantic association with Cultural Groups or Ethnicities.
- Semantic association with Existing Sponsored TLDs.
- Semantic association with Existing Unsponsored TLDs.
- Everything else.
More detailed definitions of these categories, as currently understood
by the committee, are set out below.
1. GEOGRAPHIC UNITS
By "semantic association with recognized geographic units", we mean
a TLD string that to a typical reader would be clearly linked to a recognized
geographic unit, as is the case with the existing ASCII ccTLDs.
A non-ASCII TLD consisting of Japanese characters semantically associated
with the recognized geographic unit of Japan would logically be <日本>.
- The existing ISO-3166-1 table provides a clear definition of recognized
geographic units. Use of that table allows ICANN to avoid the
problem of deciding what is and it not a country or geographically distinct
territory. It would be easy for ICANN to determine whether or
not the table includes the geographic unit with which a given proposed
TLD is associated.
- The process for delegating ASCII ccTLDs is well-defined, and could
simply be extended to the non-ASCII space. Under the terms of
RFC-1591 and ICP-1, an entity seeking to run a non-ASCII TLD semantically
associated with a recognized geographic unit would have to submit a
proposal demonstrating wide support among the Internet stakeholders
within that defined area, and establishing the technical competence
of the proposed registry operator. In the interest of transparency
and the testing of consensus, proposals for this category of non-ASCII
TLD could be posted publicly, and views sought from major stakeholders
(including, for example, ISP associations, the ASCII ccTLD registry
operator, and the government).
- In the area of geography, the use of the ISO-3166-1 provides certainty
both by inclusion and exclusion. In other words, ICANN can maintain
that only the geographic units recognized on that table are available
for non-ASCII TLDs with semantic association; the names of cities, counties,
provinces, and other geographic units would implicitly be excluded.
This principle would minimize ICANN/IANA having to make judgments about
the sovereign authority over a given geographic area.
- The use of the principles of RFC-1591 and ICP-1 in the context of
non-ASCII TLDs would also clarify that any TLD string semantically associated
with a given geographic unit would not be eligible for delegation (regardless
of the language or script) except under those principles. In other
words (by way of hypothetical example), the local Internet community
in New Kryptonia is the relevant decision maker for any terms semantically
associated (within reason) with its officially recognized name, whether
the string in question is in English, Japanese, Arabic, or Kryptonian.
- A limit to the total number of TLDs eligible for delegation to a given
geographic unit might be set at a number equal to the number of its
- The ISO-3166-1 table solves the problem of what is and is not a recognized
geographic unit (country or geographically distinct territory).
However, the table only provides two- and three-letter ASCII codes for
each such geographic unit. The table does
not solve the problem of what non-ASCII names (or abbreviations) should
be assigned to each recognized geographic unit. This is a very
serious disadvantage that might be approached in three ways:
(1) Locate (or ask a properly legitimate body like the ISO
to create) a table equivalent to ISO-3166-1, expanded to include names
in all non-ASCII scripts. This would be a massive undertaking
with enormous political complications.
(2) Allow proposers to designate their desired non-ASCII TLD string,
and rely upon a requirement of consensus within a local Internet community
to determine whether the proposed TLD string is appropriate.
This could potentially place on ICANN a massive and unsustainable
set of political burdens for which it is not well suited.
(3) Ask ICANN's Governmental Advisory Committee to sort the issue
out. This option may be very unappealing to the GAC for similar
- The committee believes that ICANN should not be placed in the role
of determining what is and is not an appropriate TLD string for a given
geographic unit. Accordingly, TLDs that correspond to geographic
units should only be created on the basis of an authoritative list defined
and maintained by a legitimate international organization, such as the
ISO. See footnote  for some options in this
- The committee believes that no automatic preference should be given
to current managers of ASCII ccTLD registries in the context of delegating
non-ASCII TLDs. The applicable requirements should continue to
be the support of the local Internet community, technical competence,
and acceptance of the responsibilities of service to the local and global
Internet communities. In some cases, the manager of an ASCII ccTLD
registry may be able to earn the support of the local Internet community
to operate a non-ASCII TLD for that same geographic unit; in other cases,
it will not. The requirements should be applied evenhandedly to
all, without giving any automatic preference to current ASCII ccTLD
managers. Among commentators, those who have taken the opposite
view have almost uniformly been managers of current ccTLD registries.
- Some commentators suggested that the national government alone should
be the determiner of a local Internet community's wishes with regard
to any non-ASCII TLDs corresponding to that geographic unit. This
would be an easy solution from an administrative standpoint; at a minimum,
in the absence of an authoritative reference list, the government's
views could be considered decisive as to the definition of the non-ASCII
TLD string itself. The committee nevertheless believes that ICANN
should rely on an appropriate, externally-defined authoritative list
for geographic unit TLD strings, meaning that government views should
be addressed to the organization that maintains the authoritative list
(for example, the ISO or a similar international entity), rather than
asking ICANN to address them.
- Several commentators urged that ICANN defer to "recognized regional
bodies" or "recognized language organizations" to handle tasks such
as the determination of TLD strings and the delegation of registry managers,
on the theory that each language comprises a distinct namespace.
There are a number of problems with this point of view. First,
many languages share characters and code points in common, making clean
divisions of "namespaces" by language impossible. Second, though
the committee supports the principles of localization and decentralization
in decision-making, the committee believes that these decisions should
primarily rest with local Internet communities. It is not clear
why regional or language-specific bodies would be free from the complex
political and other pressures that could be brought to bear on ICANN.
The committee favors a simple approach that minimizes the discretionary
role of ICANN. As to the determination of TLD strings, the committee
strongly believes that ICANN should maintain its policy of deferring
to ISO or an similarly-qualified international body. As to the
delegation of registry managers, that is a more complex issue that should
primarily be addressed within the local Internet community. Whether
there is a role or regional or language-specific organizations should
be assessed on the basis of the wishes of the local Internet community.
- In view of these many difficult and complex issues, some commentators
have argued against the creation of any non-ASCII TLDs semantically
associated with geography, language, or culture, instead favoring non-ASCII
TLD strings consisting of generic terms.
By "semantic association with language" , we
mean a TLD string that to a typical reader would be clearly linked to
the name of a language -- for example, the Arabic word for "Arabic."
- If the objective of IDNs is to enable users to easily type domain
names in familiar, non-ASCII scripts (while preserving universal uniqueness
and resolvability), it might be easiest to simply create a single TLD
for each non-ASCII script, allowing the registry operator to make decisions
about lower-level naming conventions.
- A language-associated TLD string may assist in the development of
global language-based Internet communities, particularly where the language
speakers are widely distributed around the world, for example, the various
- An authoritative international list of the world's languages exists
in the international standard ISO 639, which consists of two parts.
ISO 639 specifies a two-letter code identifying languages. (This standard
is presently under revision and will be published later this summer
as ISO 639-1). ISO 639-2 specifies a three-letter ASCII code identifying
languages. Both standards are updated by Registration Authorities
-- an ISO office similar to the Maintenance Agencies. For example,
is the Registration Authority for ISO 639-1, and the Library
of Congress, Washington D.C., USA, acts as the Registration Authority
ISO 639-2. However, one commentator has noted that the ISO 639 list
of languages is "not even close to exhaustive." Other commentators
pointed to the Ethnologue list,
which conflicts in some respects with ISO 639. The committee has
been informed that ISO's TC 37/SC 2 has initiated a process that is
intended to lead to extension of the ISO 639 standard; one of the apparent
objectives is to generate a comprehensive list of language identifiers.
Finally, it is noteworthy that RFC 3066 specifies Internet best current
practice for tags for the identification of languages.
- In a sense, a language-associated TLD string would be redundant:
if a domain name consists of Chinese characters, a user might find no
added value to require the term "Chinese" (in Chinese characters) as
the final label.
- There does not appear to be a recognized list of all human languages
analogous to the ISO-3166-1 table. While the ISO 639 list is comprehensive,
authoritative, and broadly accepted, it is not universally complete;
moreover, as with ISO 3166-1, the three-letter codes associated with
each language are given in ASCII characters.
- Language communities cross sovereign national boundaries. The
problem of identifying and achieving consensus among the stakeholders
of a given set of language communities may be extremely difficult.
ICANN/IANA might be left with competing claims backed by different stakeholders,
or, worst, different national governments. ICANN/IANA is not well-suited
to resolve those kinds of disputes.
- Languages are the products of thousands of years of history, generate
tremendous emotional attachments among people, and have been sources
of enormous political controversy. For these and other reasons,
the IETF has focused, as much as possible, exclusively on characters
and code points, not on languages (which cross boundaries, share scripts
and characters, and can differ from place to place).
- Attempting to create TLDs semantically linked to languages would raise
a large number of extremely difficult political problems. The
Chinese-speaking community, for example, includes 1.2 billion people
in mainland China, 22 million in Taiwan, and millions more in Singapore,
Malaysia, and the United States. To select a single registry operator
in such a complicated and sensitive political environment might simply
be an impossible task for a technical coordinating body like ICANN.
- The linkage of language based non-ASCII TLD rights to a country’s
list of official languages may well result in highly charged political
debates between different national stakeholders, or, worst, different
national governments revolving around the relative approval priority
associated with competing non-ASCII TLD bids.
- The linkage of language based non-ASCII TLD rights to a country’s
list of its official languages may also result in a number of non-ASCII
TLDs being commercialized in a way that results in the needs and requirements
of the originally intended users of those official languages being ignored
or forgotten in the pursuit of profit.
- Due to all the foregoing points, defining the community of interest
for a language-associated TLD is extremely complex. Likewise,
ICANN does not seem to be an appropriate forum for fostering language-community
consensus on these issues; among possible alternatives would be the
ISO, the ITU, and UNESCO.
3. CULTURAL GROUPS / ETHNICITIES
By "semantic association with a cultural group or ethnicity," we mean
a TLD string that to a typical reader would be clearly linked to a cultural
group or ethnicity that is not defined or limited by recognized national
boundaries – for example, the Kurdish or Swahili peoples.
- All of the problems with language-associated TLDs would apply to this
set of TLD strings, as well. There appears to be no internationally-recognized
and legitimate list of cultural and ethnic groups. These groups
cross national borders. The attempted to identify and verify consensus
among stakeholders in these communities would be extremely difficult.
- As with languages, the names of cultures and ethnicities are the subjects
of great emotion and, often, political controversy. For ICANN
even to consider creating TLD semantically associated with such groups
would be to invite a storm of controversy.
4. EXISTING SPONSORED gTLDs
By "semantic association with an existing sponsored gTLD," we mean
a non-ASCII TLD string that to a typical reader would be clearly linked
to an existing ASCII sponsored TLD. Currently, that list includes
.aero, .coop, and .museum. For purposes of this paper, the category
arguably includes .edu and .int also. A example of a non-ASCII
TLD semantically associated with .museum would be the TLD string consisting
of the Hangul (Korean) characters meaning "museum" in Korean.
The issue with this group is twofold: Firstly should existing registry
sponsors have a right to TLD strings in non-ASCII characters with the
same semantic meaning as their ASCII TLD string? In other words,
should they be given a preference, or be treated the same as any other
proposer? Secondly, if one language variant is approved for a given
sponsored TLD does this automatically imply a right to all other language
Advantages of incumbent preference:
- Giving a preference for equivalent non-ASCII strings to existing ASCII
sponsored registries would be simple, and somewhat logical. Once
ICANN has concluded that a given sponsor is an appropriate proxy and
policymaker on behalf of the community to be served by the TLD, it could
logically be considered to have equivalent legitimacy across non-ASCII
TLD strings as well. This might also lead to less confusion among
users, in that registration rules and registries policies would be consistent.
Disadvantages of incumbent preference:
- The selection of TLD registries is complicated. A representative
sponsor for an ASCII TLD may not be best for all communities, particularly
where the scope of a given script's use is highly localized. For
that reason, it may be best to place no hard rights or prohibitions
on the allocation of TLD strings with semantic association to existing
sponsored TLDs, treating them as any other new TLD, open to any proposer,
but also allowing the existing ASCII TLD registry sponsors to present
proposals for equivalent non-ASCII TLDs, with relevant justification
for their role.
- Each TLD string should be treated differently, and should be open
for proposals to any potential registry operator that can establish
the basic requirements for a sponsored TLD, including support within
the community to be served. At the same time, it may be possible
for a single organization to demonstrate its legitimacy and capacity
to serve as a global coordinating registry for a given term (i.e., "museum")
as to all non-ASCII strings consisting of characters that have the equivalent
semantic meaning in some language.
5. EXISTING UNSPONSORED gTLDs
By "semantic association with existing unsponsored gTLDs", we mean
a non-ASCII TLD string that to a typical reader would be clearly linked
to the an existing unsponsored ASCII gTLD, such as .com, .net, .org,
.info, .biz, or .name.
Here again, the issue is whether to give any advantage to the current
registry operators of the existing ASCII unsponsored gTLDs.
Advantages of incumbent preference:
- There appear to be few notable advantages, other than for the existing
registry operators themselves.
- It should be noted that several current operators of gTLD registries
have pointed to a range of arguable advantages, from their perspective,
including: ease of transition, single-point-of-registration services
for registrants, consistency and stability of applicable registration
rules and policies, and minimization of consumer confusion between semantically-equivalent
ASCII and non-ASCII TLDs.
Disadvantages of incumbent
- Given the generic nature of the terms at issue, and the wide-ranging
complexities of meaning across languages, it would be extremely difficult
to determine which non-ASCII words and abbreviations should qualify
for the preference; indeed, it is not clear why the preference would
not also logically extend to ASCII TLD strings, such as "company" for
the .com registry operator.
- The principles of registry-level competition and geographic distribution
of registries both argue strongly against giving any preference to existing
ASCII gTLD registry operators. Such a preference would promote
market concentration, rather than competition.
6. EVERYTHING ELSE
In this category, we mean to include every non-ASCII word, abbreviation,
or other string that is not semantically associated with one of the
above 5 categories.
For this category (and perhaps in categories 4
and 5, above), the committee concludes that no distinctions
should be drawn between ASCII and non-ASCII new TLDs – the process
that is used for new ASCII TLDs (as refined over time and with experience)
should equally apply to new non-ASCII TLDs (once the technical standard
is completed and deployable at the TLD level).
The key elements of that process are: open call for proposals,
defined criteria for selection, independent review by technical and
financial experts, and full transparency of all proposals. The
committee sees no reason why these elements could not apply equally
to non-ASCII TLD proposals, with some added criteria for selection,
perhaps focusing on the proposed registry's plans to meet the needs
of (and make policy for) the language communities to be served by a
given TLD string in a given script.
The IDN Committee received a number of thoughtful and helpful comments
on this draft. In particular, the committee thanks Asaad Alnajjar
of Millennium Inc. and the Arabic Internet Names Consortium (AINC);
Marilyn Cade of AT&T; Prof. Kilnam Chon; Roger Cochetti
of VeriSign; Peter Constable of the Non-Roman Script Initiative,
SIL International; Håvard Hjulstad, chairman of ISO/TC37
and convener of ISO/TC37/SC2/WG1; Hiro Hotta of JPRS; Cary
Karp of the Museum Domain Management Association; S. Maniam of
the International Forum for IT in Tamil (INFITT); Jeffrey J. Neuman
of NeuStar, Inc.; Stefan Probst; James Seng;
Konstantin Vinogradov of the International Centre for Scientific and
Technical Information (ICSTI); Eric Brunner-Williams of Wampumpeag LLC;
Cord Wischhöfer of the ISO 3166 Maintenance Agency; Yoshiro Yoneda;
and Danny Younger.
The committee welcomes feedback from stakeholders regarding this second
draft paper. Comments for the committee's consideration should be sent
to firstname.lastname@example.org .
13 June – Publish Second Draft of non-ASCII TLD Paper
13 June to 20 June - Second Public Comments Period.
22 June - IDN Committee Report to the Board
28/29 June – Consideration of IDN Committee Report by ICANN
 By "non-ASCII TLDs" we mean top-level
domains that include in the TLD string itself characters other than
the currently allowed ASCII "LDH code points" repertoire (meaning the
code points associated with ASCII letters, digits, and the hyphen-minus;
that is, U+002D, 30..39, 41..5A, and 61..7A). "LDH" is a commonly-used
abbreviation for "letters, digits, hyphen." In this paper, we
use the term "non-ASCII" as a shorthand for "characters other than ASCII
 The Committee wishes to make it abundantly clear
to all readers that in no sense is there an implied guarantee in this
paper that non-ASCII TLDs will become a reality. Much technical and
policy work remains to be undertaken before it is possible to contemplate
such a reality with any certainty, let alone have any sense of the actual
outcome, one way or the other.
 The statement that ISO-3166-1 exists only in
French and English is correct, but some significant qualifications must
First qualificiation: One of the two United Nations sources of the
country and territory names listed in ISO 3166-1 is the UN Terminology
Bulletin entitled "Country Names," which lists about 180 country names
in each of the six official languages of the UN: Arabic, Chinese,
English, French, Russian, and Spanish. UN Terminology Bulletin
Country Names, United Nations New York, 1997. (Ref.: Sales No. A/C/E/F/R/S.97.I.19
(ST/CS/SER.F/347/Rev.1)). As noted by Cord Wischhöfer of
the ISO 3166 Maintenance Agency, "this document could well serve as
a reference basis for authoritative input into a possible future list
of non-ASCII country/territory names for Russian, Arab and Chinese name
forms. For those entities not listed in the UN Terminology Bulletin
-- 99 percent of those not listed are dependent territories -- another
solution would have to be found."
Second qualification: Each national standards organization that
is a member of ISO may adopt ISO standards nationally. By this process
– known as "national adoption" – the ISO standard becomes
a national standard recognized in that country. In many cases, this
adoption entails the translation of the English version into the national
language. As a result, ISO 3166-1 has been translated into a number
of the larger languages utilizing non-ASCII scripts. For example,
ISO 3166-1 is national standard JIS X 0304 in Japan, and standard KS
X 1510-1 in the Republic of Korea.
These qualifications lend support to the proposition that ISO might,
in fact, be able to undertake the creation and maintenance of a non-ASCII
extension to ISO 3166-1. More significantly, they suggest that
ICANN could rely on national adoptions of ISO 3166-1, where they exist.
For any given geographic unit recognized on ISO 3166-1, ICANN could
refer to the relevant national adoption(s) to ascertain the appropriate
string (which, by virtue of its presence on the version adopted locally
by the national ISO member standards organization, should be acceptable
to the local Internet community). Where conflicts arise between
national adoptions, ICANN could simply defer action until the national
standards bodies and their respective governments act to resolve the
 The terms "language," "script," and related concepts
are commonly mis-defined and therefore misunderstood in discussions
regarding internationalization of computers and the Internet.
Readers are referred to Paul Hoffman's Internet Draft entitled
"Terminology Used in Internationalization in the IETF " for a comprehensive
list of definitions. Also, see the
IANA language registry , which is defined by
RFC 3066 .
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