G/SPS/GEN/1899  
 
1 April  2021 
(21-2748) Page: 1/1 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
 
CHINA'S ADMINISTRATIVE MEASURES FOR REGISTRATION OF OVERSEAS PRODUCERS 
OF IMPORTED FOODS AND ADMINISTRATIVE MEASURES ON IMPORT  
AND EXPORT FOOD SAFETY – SPECIFIC TRADE CONCERN 48 5 
SUBMISSION BY THE UNITED STATES  
The following submission , received on 30 March 2021, is being circulated at the request of the 
Delegation of the United States . 
 
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1.1.  The United States thanks China for notifying to the TBT Committee its draft  Administrative 
Measures for Registration of Overseas Producers of Imported Foods  (Administrative Registration 
Measures) ( G/TBT/N/CHN/1522 ), and to the SPS Committee its draft Administrative Measures on 
Import and Export Food Safety (Administrative Import Measures) ( G/SPS/ N/CHN/1191 ). We 
continue to have concerns with these draft measures and urge China to carefully consider their 
enaction of such restrictive reg ulations without a clear food safety and public health benefit.  
1.2.  The proposed measures seem to be related, as both measures describe food facility registration 
requirements that are very similar and even appear to overlap in some cases. Thus, we are 
address ing both G/TBT/N/CHN/1522  and G/SPS/ N/CHN/1191  together in this intervention.  
1.3.  G/SPS/ N/CHN/1191  appears to be the over -arching regulation for imported and exported food 
products, and G/TBT/N/CHN/1522  the implementing measure for food facility registration. We ask 
that China please confirm this understanding of the relationship  between the two regulations.  
1.4.  The proposed measures also appear to affect all food products, regardless of risk or whether 
foods are already subject to additional import certification requirements. Low -risk foods, including 
the low -risk products listed in Article 6 (i.e., dried fruits, nuts and seeds, coffee beans, cocoa beans, 
etc.), should be removed from the product scope for the proposed measures.  
1.5.  We are also concerned that China' s proposed measures would mandate additional certification, 
audit, and inspection documents and procedures beyond what is already in place for higher -risk 
products. China has not provided any specification of what food safety risks these new requirements 
would mitigate that are not already addressed by China' s prior legislation. Can China specify what 
new food safety risks are being addressed?  
1.6.  We anticipate that these draft measures, if implemented, would likely create major trade 
disruptions for every coun try that exports food and agricultural products to China, and especially for 
developing countries whose competent authorities may have limited capacity to meet China' s 
proposed requirements. Similar difficulties would also be encountered by small - and medi um-sized 
enterprises globally.  
1.7.  The United States urges China to take a risk -based systems approach to determine which 
procedures may be required for individual trading partners and product groups to meet China' s 
appropriate level of consumer protection, and identify which food safety ri sks such procedures would 
mitigate that are not already addressed by China' s prior legislation.  
1.8.  Finally, we ask that China please provide an update regarding its comment review process and 
timeline for next steps for both of these measures.  
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