   
  
G/SPS/GEN/2004  
 
4 April  2022 
(22-2677) Page: 1/1 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
 
CHINA 'S ADMINISTRATIVE MEASURES FOR REGISTRATION OF OVERSEAS 
MANUFACTURERS OF IMPORTED FOOD (26 NOVEMBER 2019)  
– SPECIFIC TRADE CONCERN 485  
SUBMISSION BY THE UNITED STATES  OF AMERICA  
The following submission , received on 28 March 2022, is the statement made by the United States  
of Amer ica at the 23-25 March  2022 WTO SPS Committee, and is being circulated at the request of 
the Delegation of the United States  of America . 
 
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1.  The United States notes that China's Decrees 248 and 249 came into effect on 1 January 2022. 
The United States is concerned with China's lack of response to requests for scientific justification 
for these measures and explanation of how these measures will address food safety and public health 
concerns. The United States again requests China to provid e any risk assessments that informed the 
development of these decrees. The United States is particularly interested in assessments that justify 
the identification of high -risk products and the application of these measures to low -risk products.  
2.  The lack of  guidance provided by China is causing considerable confusion for exporters and 
competent authorities. This confusion is leading to inconsistencies in China's implementation and 
enforcement of the measures and causing negative trade impacts. While China ha s provided some 
clarification, much more is needed.  
3.  In addition, US agencies have been working to resolve issues with shipments frequently being 
held up at ports in China due to the repeated broadening of the scope of harmonized tariff codes 
subject to the  measures. Meanwhile, companies accumulate demurrage and other port fees while 
they await resolution, and Chinese consumers face higher prices for safe food.  
4.  As we have raised in interventions at every meeting of this Committee since June 2020, any 
measure  of this magnitude requires far more time for producers, exporters, and competent 
authorities to implement. Therefore, we ask that China take the following steps to facilitate trade:  
− First, allow entry of all products from registered facilities until 1 July 2023. This additional 
time will allow facilities to accurately enter or update product information in their online 
registration;  
− Second, provide a point of contact at the General Administration of Customs of China (GACC) 
for facilities to contact directly with concerns about the online registration system;  
− Third, hold an informational session in Geneva for trading partners to learn more about 
GACC's implementation of the Decrees.  
 
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