G/SPS/W/326  
 
18 May 2020  
(20-3660) Page: 1/10 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
FIFTH REVIEW OF THE OPERAT ION AND IMPLEMENTATI ON OF THE AGREEMENT  
ON THE APPLICATION O F SANITARY  AND PHYTOSANITARY M EASURES  
COMMENTS SUBMITTED BY  THE UNITED STATES  ON THE REVISED  
DRAFT REPORT OF THE FIFTH REVIEW ( G/SPS/W/313/REV.2/AD D.1) 
This document includes the c omments sub mitted by the United States on  Part B of the revised draft 
Report of the Fifth Review (i.e. the factual section, G/SPS/W/313/Rev.2/Add.1 ). Please refer to 
document G/SPS/W/324  for additional comments from Members on  Part A of the revised draft Report 
of the Fifth Review (i.e. the section on proposals, G/SPS/W/313/Rev.2 ) and Part B of the revised 
draft Report of the Fifth Review ( G/SPS/W/313/Rev.2/Add.1 ). 
1  CONTROL, INSPECTION AND APPROVAL PROCEDU RES (ARTICLE 8 AND A NNEX C)  - 
SECTION 3 OF G/SPS/W/313/REV.2/AD D.1 
1.1.  Suggested edit s and comments in relation to  paragraph  3.1. 
"3.1 …  The workshop explored the main WTO rules provisions of , and related jurisprudence  
on dispute settlement reports regarding,  Article 8 and Annex C of the SPS Agreement, and 
explained the relationship between the TF and SPS  Agreements. Representatives from Codex, 
IPPC and OIE presented an over view of relevant work in the three sisters. Presentations by 
the World Bank, the STDF, and COMESA had depicted experiences on the ground, given 
estimates on SPS -related trade transaction costs, and identified win win  opportunities to 
facilitate safe trade,  such as interagency collaboration and increased transparency. The 
European Union, the United States, Canada, China, Turkey, Zambia and Belize presented their 
domestic experiences."  
a. The US institutional position is that dispute settlement reports are  not "jurisprudence ". 
Also, we are not sure what are the "rules on" Article 8.  
b. The double win is not identified.  
1.2.  Comment s on paragraph 3.5 in relation to the first and second sentences:  
"3.5 Several speakers shared experiences as importing and exporting Members in relation to 
approval procedures, followed by a discussion on costs and challenges related to asynchronous 
global  approval processes. An interesting insight into the linkages bet ween the WTO 
Trade  Facilitation Agreement and the disciplines on approval procedures was also provided. 
Some  key takeaways included the need for increased cooperation and capacity building for 
strengthening the implementation of cost -effective  approval pro cedures. Finally, a roundtable 
discussion concluded the thematic session by posing overarching questions to stimulate an 
exchange of ideas on possible ways to address some of the challenges identified, and explore 
possible future work."  
a. A more accurate for mulation would be "…a discussion on costs and challenges related 
to trade and innovation caused by asynchronous approval processes globally."  
b. What was the insight?  G/SPS/W/326  
 
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  2  COOPERATION WITH THE  CODEX, IPPC AND OIE  - SECTION 4 OF 
G/SPS/W/313/REV.2/AD D.1 
2.1.  Suggested edits and c omment s on paragrap h 4.2 in relation to the first sentence:  
"4.2 In addition to the standard -setting information provided during the SPS Committee 
meetings by the three sister s, the IPPC urged Members  in 2018 to support Finland's proposal 
to declare 2020 as the International  Year of Plant Health  (IYPH) at the UN  General Assembly 
in September 2018 . …" 
a. There is n o need for the clause, which characterizes the nature of the info rmation  
presented.  
3  EQUIVALENCE (ARTICLE  4) - SECTION 6 OF G/SPS/W/313/REV.2/AD D.1 
3.1.  Suggested edit s and comments in relation to  paragraph 6.8:  
" 6.8. In October 201 8, the first part of the Thematic Session on Equivalence1 was held. The 
Secretariat developed a programme for the workshop based on the proposal by Canada and 
inputs from Members. This first part provided an opportunity to lay out the international 
framework for the application of the concept of equivalence. The In th is first part, the  
Secretariat provided an overview of the provisions of the SPS Agreement on equivalence 
(Article 4), the relevant guidelines  (GofG/SPS/19/Rev.2 ),, and of related jurisprudenc e; 
thedispute settlement reports. The  thematic session included a presentation from the 
Secretariat on equivalence from a TBT perspective. Secondly, the 
representatives Representatives  of Codex, IPPC and OIE explained how discussed  the concept 
of equivalence was applied  in their respective areas , and identified the relev ant international 
standards and guidelines., . Discussions covered the need to ensure the consistency of the 
work being undertaken by the standard -setting bodies with the WTO Agreements; the 
challenges of having a common definition of equivalence; the lack of consistency in wording 
across organizations; the situations in which a systems approach should be used; and the link 
between recognition of disease -free areas and equivalence determinations.  
a. In relation to the edit "In this first part , the Secretariat p rovided… ", more neutral 
wording avoids characterizing.  
b. In relation to the edit "Codex, IPPC and OIE explained how discussed  the concept of 
equivalence was applied  in their respective areas…",  the ISSBs do not “apply” 
standards. In the discussions, the ISSB representatives conveyed that they do not 
know how the concepts on equivalence contained in their standards, guidelines and 
recommendations are applied at the national level.  
c. In relation to the text "the lack of consistency in wording across organizations" , is 
it across and within ISSBs? Did Codex  not acknowledge inconsistency across its 
documents?  
d. In relation to the text "…the situations in which a systems approach should be used",  
a more accurate formulation would be: "… the factors which c ontribute to the 
relevance and effectiveness of the use of a systems approach ". 
e. In relation to the text "... and the link between recognition of disease -free areas 
and equivalence determinations",  a more accurate formulation would be:  "…and 
whether recognition of pest or disease -free areas constitutes a form of equivalence 
determination. " 
3.2.   Comment in relation to  the last sentence of paragraph 6.9:  
"6.9 Finally, speakers from COMESA, Imperial College London and Peru explored other 
approaches to equivalence. During the session, the principles of transparency, engagement 
 
1 The programme is available in document G/SPS/GEN/1640/Rev .1. Presentations from the thematic 
session are also available at: https://www.wto.org/english/tratop_e/sps_e/workshop301018_e.htm . G/SPS/W/326  
 
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  and mutual trust were highlighted as prerequisites for the effective implementation of 
equivalence. " 
a. Actually, during the session it became clear that some (many?) Members did not 
notify their equivalence arrangements nor make the terms of such arrangements 
publicly available. Nor did these Members indicate a willingness to do so. Apparen tly, 
transparency is not a prerequisite.  
3.3.  Suggested edit s in relation to  paragraph 6.12:  
"6.12 Also in 2019, a joint proposal submitted by Brazil, Kenya, Paraguay and the United 
States2 on enabling access to tools and technologies towards safer and more sus tainable 
agriculture through regulatory collaboration, included equivalence as one of the possible 
concepts subject to for further Committee discussion in connection with fall armyworm 
(FAW).3" 
4  MONITORING THE USE O F INTERNATIONAL STAN DARDS (ARTICLES 3.5 AND 12.4)  - 
SECTION 10 OF G/SPS/W/313/REV.2/AD D.1 
4.1.  Comment in rela tion to  number (iv) of paragraph 10.5:  
"10.5 In 2016, several previously raised issues were discussed:  (i) Argentina's concerns 
regarding measures on bovine semen and reproductive material more restrictive than the OIE 
Standard; (i i) Senegal's concerns regarding the application of ISPM 13 on notifications of non -
compliance; ( iii) US concerns regarding BSE restr ictions not consistent with the OIE 
International Standard; (i v) US concerns regarding IPPC phytosanitary certificate 
requirements for processed food products; (v) US concerns regarding the use of the Codex 
international standard on glyphosate; and (vi) US  concerns regarding HPAI restrictions not 
consistent with the OIE International Standard."  
a. A more accurate formulation would be: "(iv) US concerns regarding the non -
application of IPPC international standards for phytosanitary certificates for processed  
food products. " 
4.2.  Comment in relation to  the second sentence in  paragraph 10.7:  
"10.7 In 2017, the Committee agreed to circulate the convening airgram one week earlier 
than the previous practice. This meant that the original deadline for raising agenda 
items under the procedure to monitor the use of international standards, which was 10 days 
before the meeting, no longer coincided with the deadline for raising issues under other 
agenda items. …"  
a. The original deadline is the deadline contained in G/SPS/11/ Rev.1?  
“This meant that the deadline of 10 days before the meeting contained in the 
Committee’s monitoring procedures established in 2004, no longer coincided…”  
4.3.  Comment in relation to  number (i) in the first part of paragraph 10.8:  
"10.8 In 2018, several n ew issues were raised: (i) US concerns regarding unnecessary delays 
in adoption of Codex Food Additive Standards; (ii) US concerns regarding  non-science factors 
in Codex standards; (iii) EU concerns on ASF restrictions not consistent with the OIE 
internati onal standard ; (iv) Indonesia's and US concerns regarding risk management related 
to the global movement in plant seeds (ISPM 38); and (v) India's concerns regarding the use 
of the Codex definitions for milk and milk products. " 
 
2 G/SPS/W/317 . 
3 G/SPS/W/305 , G/SPS/W/309 , G/SPS/W/309/Corr.1  and G/SPS/W/317 . See the section on fall 
armyworm in Part A of the Report of the Fifth Review  (i.e. document G/SPS/W/313/Rev.2 ), which provides 
additiona l details on the substance of submitted  proposal s and the subsequent discussions.  G/SPS/W/326  
 
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  a. Language here is ambiguous on whether  the complaint is delays by Codex in adopting 
new standards or delays by Members in adopting Codex standards.  A more accurate 
formulation would be: "US concerns regarding unnecessary d elays in the adoption of 
Food Addi tive Standards by the Codex Committee on Food Additives."  
 
4.4.  Comment in relation to  number (iii) in the second part of paragraph 10.8:  
"10.8 Some previously raised issues were also discussed: (i) EU and US  concerns regarding 
HPAI restrictions not consistent with the OIE international standard; (ii) US concerns regarding 
the relation of the World Health Organization and the Food and Agriculture Organization to 
Codex Alimentarius; (iii) US concerns regarding the non -use of Codex Guidelines and 
Principles on Off icial Import and Export Certificates; (iv) US concerns regarding 
BSE restrictions not consistent with the OIE international standard; and (v) US concerns 
regarding the use of the Codex international standard on glyphosate. " 
a. In relation to the text " … Codex  Guidelines and Principles on Official Import and 
Export Certificates ", is this the right name?  
5  OBSERVER STATUS  
5.1.  Comment in relation to  the last sentence of paragraph 11.2:  
"11.2 In September 2019, the Committee received a new request for ad hoc observer st atus 
from the United Nations Industrial Development Organization (UNIDO).4 In the November 
2019 Committee meeting, some delegations requested more time to consider this request, 
and the Committee agreed to return to it at its March 2020 Committee meeting. "  
 a. At its next meeting?  
6  OTHER SUBSTANTIVE DI SCUSSIONS  - SECTION 12 OF G/SPS/W/313/REV.2/AD D.1 
6.1  Maximum residue limits (MRLs) for plant  protection products  – Section 12.1  
6.1.  Suggested  edits and  comments in relation to  paragraph 12.3:  
"12.3 The Secretariat organized a Thematic Workshop on Pesticide Maximum Residue Levels5 
in October 2016 , which brought together officials for an in -depth sessi on focusing on the 
relevant provisions of the SPS Agreement and related jurisprudence, as well as the Codex 
approach to establishing MRLs. The workshop also benefitted from presentations on various 
regional and international initiatives focused on harmoniz ing MRLs and establishing MRLs for 
minor -use crops. In  addition, various WTO Members shared their national experiences on 
establishing MRLs and provided insights into : the challenges of implementing and complying 
with Codex MRLs, as well as  the impact of d efault MRLs and MRL expiration on international 
trade , and the challenges to producers of complying with Codex MRLs . Speakers from the 
private sector also contributed to the workshop, highlighting the various ways for the private 
sector to be involved  in establishing MRLs, such as by providing the relevant technical data. 
Several follow -up actions were proposed during the workshop, with a view to addressing 
various concerns related to pesticide MRLs. " 
a. In relation to "jurisprudence", replace with "d ispute se ttlement reports ". 
b. In relation to the edits in the text, these are p roposed changes for clarity.  
6.2.  Comment in relation to  number (iv) of paragraph 12.4:  
 
4 G/SPS/GEN/121/Add.18 . 
5 The summary report of the Pesticide MRLs Workshop was circulated as G/SPS/R/85 . The programme 
(G/SPS/GEN/1 514/Rev.1) and presentations from the workshop are available via the following link: 
https://www.wto.org/english/tratop_e/sps_e/wkshop_oct16_e/wkshop_oct16_e.htm . G/SPS/W/326  
 
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  "12.4 Following the workshop, the United States made suggestions for future work by the 
SPS Committee in four topic areas: (i) enhancement of the Codex MRL system; (ii) 
transparency and predictability in Members' regulatory approaches; (iii) regular updates on 
harmonization efforts being undertaken by APEC, NAFTA, OECD and EAC, with the aim of 
inspiring similar harmonization initiatives at the regional level; and (iv) greater access of 
developing countries to newer, alternative pesticides that can replace older pesticides. …" 
a. In relation to the text " newer, alternative pesticides that can replace older 
pesticides ", instead refer to "lower-risk pesticides" . 
6.3.  Suggested edits and comment  in relation to paragraph 12.17:  
"12.17 In 2019, Australia drew attention to the  “APEC import  Import  MRL guideline  Guideline  
for Pesticides pesticides : A guideline  Guideline  on possible approaches  Possible  Approaches  to 
Achieve  achieve alignment  Alignment  of international  International  MRLs".6 …" 
a. In relation to the suggested edits, t his is a title . 
6.4.  Suggested edit in relation to last sentence of paragraph 12 .19: 
"12.19 … Burkina Faso requested that JMPR include sesame in its studies, and as well as  Côte 
d'Ivoire and Nigeria, pointed to the need for technical assistance in this area ." 
6.5.  Comment  in relation to last sentence of paragraph 12.20:  
"12.20 … Representa tives of nearly 20 countries had attended the event and had explored 
practical examples o f the application of the SPS  Agreement for the proper definition of 
pesticide MRLs."  
a. What does this mean?  
6.2  Fall armyworm (FAW)  – Section 12.2  
6.6.  Suggested edits and comment in relation to first sentence of paragraph 12.27:  
"12.27 First, the Secretariat provided an overview of the provisions of the  certain  SPS 
Agreement provisions  and jurisprudence  dispute settlement reports that could be  relevant to 
regulatory approac hes that enable d access to safe tools and technologies. …"  
a. Some edits for clarity.  
6.7.  Suggested edit in the first sentence of paragraph 12.28:  
"12.28 At the end of the thematic session, the Chairperson invited Members to comment on 
the first open -ended meeting of the Working Group of on FAW, which had been held after the 
informal meeting.  …" 
6.8.  Suggested edit and comment in relation to paragraph 12.29:  
"12.29 … The African Union reiterated its efforts to support the management of FAW 
outbreaks  in Africa with other developing partners.  ECOWAS  drew attention to the training it 
had provided to s trengthen the monitoring, prevalence and impact of FAW on food 
production , with the financial and tec hnical support of FAO; which had led to additional 
targeted funding. … "  
a. Added “on food production” to clarify that ECOWAS does not really want to strengthen 
the impact of FAW.  
 
6 G/SPS/GEN/1746 . G/SPS/W/326  
 
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  6.3  Gene editing and biotechnology  – Section 12.4 
6.9.  Comment in relation to the tit le of section 12.4  "Gene editing and biotechnology":  
a. A more accurate formulation would be: "Gene editing and other forms of biotechnology ". 
6.10.   Comment in relation to paragraph 12.43:  
"12.43 …  Australia, Brazil, Canada, Colombia, the Dominican Republic, Gua temala, Honduras, 
Jordan, Paraguay, the United States, Uruguay and Viet  Nam supported the International 
Statement. ECOWAS also expressed support for the proposal, while highlighting some 
challenges for developing countries in responding to this advanced te chnology.  
a. Please use full title  of the statement, i.e . “International Statement on Agricultural 
Applications of Precision Biotechnol ogy”. 
6.11.   Comment in relation to paragraph 12.46 : 
"12.46 In 2019, the United States brought Members' attention to its Executive Order 13874, 
entitled Modernizing the Regulatory Framework for Agricultural Biotechnology Products. The 
United States also drew attention to its Sustainable, Ecological, Consistent, Uni form, 
Responsible, Efficient (SECURE) proposed rule. The rule sought to modernize USDA's plant 
biotechnology regulations, to protect plant health while allowing agricultural innovation to 
thrive.  The framework would provide a clear, predictable, and effici ent regulatory pathway for 
innovators, while facilitating the development of new and novel GE plants that would be 
unlikely to pose a plant pest risk. "  
a. Unclear if “the framework” is meant to refer to the E xecutive Order (which has 
“framework” in title) , the rule, or both. Instead suggest “The framework, and the 
proposed rule, sought to provide a clear, predictable, and efficient pathway for 
innovators. The proposed rule sought to facilitate the development of new and novel GE 
plants that would be unlike ly to pose a plant pest risk.”  
7  REGIONALIZATION (ART ICLE 6)  - SECTION 14 OF G/SPS/W/313/REV.2/AD D.1 
7.1.  Suggested edits and comments in relation to the last part of paragraph 14.13:  
"14.13 … The Secretariat provided an overview of the provisions of the  SPS Agreement on 
pest-free areas  Article 6 and the relevant guidelines  (G/SPS/48), as well as relevant 
jurisprudence from recent disputes. On behalf of the IPPC, a Member presented on the IPPC 
standards on pest -free areas; factors  to consider when establishing pest -free areas; 
implementation challenges; and information on the IPPC's Pest -Free Area Project."  
a. In relation to the suggested edits "The Secretariat provided an overview of the 
provisions of the  SPS Agreement on pest -free areas ", not all of Art icle 6 is about 
pest-free areas and we assume the presentation was about more than the specific 
parts of Art icle 6 on pest-free area . 
b. In relatio n to the edit "  relevant guidelines ", use the actual title instead of statement 
about relevance: "Guidelines to Further the Practical Implementation of Article 6 of 
the Agreement on the Application of Sanitary and Phytosanitary Measures".  
c. In relation to "jurisprudence", replace with "dispute settlement reports".  
7.2.  Suggested edit and comment in relation  to the first sentence of paragraph 14.14:  
"14.14 Discussions were also held on the role of dispute settlement panels in assessing the 
evidence provided by Members in relation to the determination of pest -free areas and on the broad 
nature of IPPC standard s, among other s. …" G/SPS/W/326  
 
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   a. In relation to the text "among others", replace with "among o ther issues "? 
7.3.  Comment in relation to the footnote 85 of paragraph 14.16:  
"Footnote 85 The WTO Secretariat participated in this symposium via video conference and 
delivered  a presentation on pest -free areas and the SPS Agreement, including relevant SPS 
Committee Guidelines."  
a. In relation to "relevant SPS Committee Guidelines", u se actual title instead of 
statement about relevance: "Guidelines to Further the Practical Imple mentation of 
Article 6 of the Agreement on the Application of Sanitary and Phytosanitary Measures".  
8  RISK  ANALYSIS: RISK ASSE SSMENT (ART. 5), RIS K MANAGEMENT AND 
COMMUNICATION  - SECTION 15 OF G/SPS/W/313/REV.2/AD D.1 
8.1.  Comment in relation to the last sentence of paragraph 15.10:  
"15.10 …  Codex informed on the decision of the Chairperson of the Codex Committee on 
Residues of Veterinary Drugs in Food (CCRVDF) not to move the MRLs for Zilpaterol to step 5 
for intermediate adoption, despite t he completed JECFA risk assessment and Members' 
consensus on the science, and also on the adoption of the Risk Management Recommendation 
for Gentian violet. " 
a. In relation to the text "…on the adoption of the Risk Management Recommendation 
for…", u nclear whether  this connects to  Members’ consensus or the Chairperson’s 
report.  
8.2.  Comment in relation to paragraph 15.11:  
"15.11 In 2019, the Russian Federation informed the Committee  of the International 
Conference on Food Safety  Risk Analysis and Antimicrobial Resistance, to be held in Moscow 
on 17 -18 December  2019. The aim of the conference, jointly organized with FAO, was to 
enhance multinational cooperation on food safety, gatheri ng representatives in animal health, 
public health and food safety sectors to facilitate exchange in experiences and best practices 
relating to reduction of AMR, assess multifaceted food safety risks, enhance multilateral 
dialogue and promote partnerships between different stakeholders. In addition, t he Dominican 
Republic highlighted the Risk Analysis Consortium created with the support of IICA  (including 
its SPS Leadership Course)  and OIRSA. " 
a. This paragraph  is mentioned twice in the report, here and under AMR.  
9  SPS-RELATED PRIVATE STANDARDS  - SECTION 17 OF G/SPS/W/31 3/REV.2/ADD.1  
9.1  Other activities in relation to private standards  – Section 17.5  
9.1.  Suggested edits and comment in relation to paragraph 17.27:  
"17.27 In July 2018, Belize informed the SPS Committee of its participation in government to 
government, and governme nt to business meetings held in Japan in March 2018, with the 
support of FAO. On the margins of the Food Safety Conference, Belize expressed its concerns 
on issues related to private and co mmercial standards, and their negative impact on exporting 
companie s in Belize. Belize observed stated  that since concerns with private and commercial 
standards had first been raised in the SPS Committee in 2005,  the following points had been 
noted by the Belize’s  private sector exporters had reported that : …" 
a. In relation to the edit " Belize’s  private sector exporters had reported that ", we 
presume this is not the view of the private sector users of the schemes, but rather of 
Belize’s exporters.  
9.2.  Suggested edit and comment in relation to the word "referencing" in th e first sentence of 
paragraph 17.28:  G/SPS/W/326  
 
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  "17.28 In addition to referencing  the Committee Decision on "Actions Regarding SPS -Related 
Private Standards", as contained in G/SPS/55 , Belize encouraged Members to: …"  
a. Without this word here, the sentence reads – incorrectly – as if G/SPS/55 also 
encoura ges Members to do the 4 things suggested by Belize  in paragraph 17.27 . 
9.3.  Suggested edits and comments in relation to paragraph 17.29:  
"17.29 Finally, Belize reminded Members of the  legal obligations contained in  provisions of  
Article 13 of the SPS  Agreement, and in particular drew Members' attention to the second and 
third sentences of Article 13. Belize further  underscored the  expressed that it sees a  need for 
the development of guidelines for the implementation of Article 13 , especially given the 
increased role of the private sector, and urged the Committee to make an effort to initiate 
work in that regard. Belize also noted the work being undertaken in the Codex Committee on 
Food Import and Export Inspection and Certificatio n Systems (CCFICS) on "Guidance for 
Authorities to Assess Third Party Assurance and its Potential to Inform National Food Control 
System Planning", indicating its hope that this would serve as a catalyst  to advance the  
Committee's work and influence  for Co mmittee discussions and promp t the development of 
guidelines for the implementation of Article 13."  
a. This report consistently (and correctly) refers to the “provisions of” SPS  Agreement  
Articles and does not elsewhere use the phrasing “legal obligations. ” The specific 
phrasing here, moreover, is not explicitly attributed to Belize as opposed to the Members 
who will endorse this report. Accordingly, Art icle 13’s contents should be described using 
the “provisions of” phrasing used elsewhere.  
b. The word “underscored” suggests the need was already apparent.  
c. In relation to the edits " to advance the  Committee's work and influence  for Committee 
discussions and promp t…", the c urrent phrasing incorrectly suggests existence or 
contemplation of current work on gu idelines.  
9.4.  Suggested edits and comments in relation to the last sentence of paragraph 17.30:  
"17.30 … Ecuador recalled that the Committee' discussions on private standards had continued 
for some time and that document G/SPS/55 , which had been adopted by the Committee in 
March 2011, continued to apply. Ecuador further noted that the application of standards and 
measures by private entiti es could have a disproportionate effect on trade for goods produced 
and exported by developing countries. Ecuador indicate d its stated that it had  continued 
interest in discussing this topic in the Committee , in order to reach an agreement on the best 
way to regulate these types of standards and to ensure compliance with Article 13 of the SPS 
Agreement."  
a. Phrase so as to ensure all thoughts in the  sentence, including their relationship and 
precise framing, are clearly attributed to Ecuador only.  
b. In relation to the edit " in the Committee ,", delete comma to help ensure that all 
thoughts in the sentence, and their relationship, are clearly attribu ted to Ecuador only 
and not to Members endorsing the report.  
9.5.  Suggested edits and comment in relation to paragraph 17.31:  
"17.31 In 2018 and 2019, the Committe e discussed proposals submitted by Belize  on: for the 
development of guidelines for implementatio n of Article 13,7 and on voluntary third -party 
assurance schemes.8"  
 
7 G/SPS/W/306 . 
8 G/SPS/W/316  and G/SPS/W/320 . See the section on voluntary third -party assurance schemes  in 
Part A of the Report of the Fifth Review  (i.e. document G/SPS/W/313/Rev.2 ), which provides additional details 
on the substance of th e submitted  proposal s and the subsequent discussions . G/SPS/W/326  
 
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  a. The word “on” suggests  a currently ongoing development process.  
10  TECHNICAL ASSISTANCE  AND TRAINING ACTIVI TIES (ARTICLE 9)  - SECTION 18 OF 
G/SPS/W/313/REV.2/AD D.1 
10.1  The Standards and Trade Development Faci lity (STDF)  – Section 18.3  
10.1.   Comment in relation to the first sentence of paragraph 18.21:  
"18.21 The STDF is a g lobal partnership that helps developing countries improve their food 
safety, and animal and plant health capacity to meet SPS requirements  for trade, based on 
international standards . …" 
a. In relation to the text "based on international standards", i s this supposed to modify 
“SPS requirements” or how the partnership helps? Need to clarify . Is it “... requirements 
for trade that are  based on  intern ational standards ”? 
10.2.   Suggested edits and comments in relation to the first sentence of paragraph 18.26:  
"18.26 In 2018, t he STDF initiated work on creating a guidance document and practical 
checklist on the use of Good Regulatory Practice  (GRP) .9 This work aims to provide guidance 
for developing countries to ensure that SPS measures are "fit for purpose" and that they avoid 
the creation of non -tariff barriers. It will seek to identify good practices and recommendations 
to enhance the development a nd implementation of SPS measures in order . It will aim  
specifically  to: (i) strengthen the effectiveness of regulatory interventions; (ii) improve 
compliance with increase use of  international standards and  implementation of  the 
SPS Agreement ; and (iii) e nsure health protection while facilitating trade. A peer review group 
of STDF members and relevant organizations (including OECD) is supporting this work. The 
Secretariat aims to present this work on the margins of a Committee meeting in 2021."  
 a. In rela tion to the edit " in order ", this connector does  not make sense.  
 b. In relation to the text "increase use of  international standards ", there is n o 
requirement to “comply” with int ernationa l standards.  
11  TRANSPARENCY (ARTICL E 7 AND ANNEX B)  - SECTION 19 OF 
G/SPS/W/313/REV.2/AD D.1 
11.1.   Comment on "Chart 6 - Development status of notifying Members between January 2014 and 
31 December 2019 ": 
 
 
 
9 http://www.standardsfacility.org/good -regulatory -practice . 
G/SPS/W/326  
 
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  a. This pie chart need s further labelling. Unclear what it is showing.  
11.1  Proposals on transparency  – Section 19.5  
11.2.   Suggested edit and comment in relation to paragraph 19.34:  
"19.34 The Secretariat provided an overview of the key SPS and TBT transparency provisions 
and reviewed the objectives and coverage of the SPS and TBT Agreements, related discussions 
in the respective Committees and examples of measures notified under both  Agreements. 
Brazil, Japan, Chinese Taipei, Canada and Uganda presented  on their experience in 
implementing the transparency provisions with SPS/TBT notifications. The Secretariat, 
UNCTAD and ITC introduced several tools and sources of SPS/TBT information.  Uganda, 
Australia, China and New Zealand shared their experience on transparency -related 
coordination. Representatives from the WTO Secretariat, STDF, UNCTAD and Belize took part 
in a round table on Guidelines and available tools for domestic coordination . Canada, Peru, 
Kenya, the United States and Senegal shared domestic coordination experiences. And finally, 
the African Union, ECOWAS, IICA, Chile and APEC presented on regional/international 
initiatives to support domestic coordination."  
a. Use of "Guidelines" here, with capitalization is odd. If part of a title , then we presume 
other words need to be capitalized. Should this be “guidance” (no capitalization)?  
11.3.   Suggested edits and comment in relation to paragraph 19.35:  
"19.35 In 2019, the United Sta tes noted that  several Members ha d national policies to align 
their SPS standards and regulations to those of the European Union, but did not regularly 
notify proposed changes to the SPS Committee. The United States pointed to the low 
notification rate of the European Free Trade Association (EFTA) and invited Members with 
national policies aligned with EU SPS measures to review their notification practices to ensure 
that other WTO Members had the opportunity to comment on changes to their SPS 
measures regula tions. Colombia appreciated the inclusion of this item on the agenda and 
Paraguay and Uruguay expressed their concern."  
 a. Annex B concerns regulations.  
12  APPENDIX  
12.1.   Comment in relation to the Appendix:  
" APPENDIX A : Secretariat  background documents and other  meeting documents, 2014 -2019 
A. Transparency  
B. Monitoring International Standards  
C. Technical Assistance  
D. Implementation of the Agreement – Specific Trade Concerns /Ad Hoc Consultations  
E. Private Standards  
F. Regionalization  
G. Review of the SPS Agreement  
H. Equivalence  
I. Other"  
a. We are n ot sure what the point of including this table of contents is when the list 
itself w ill not  be part of this doc ument . It looks very odd and it w ill not  be clear that this 
is a table of contents (as opposed to a listing of docu ments).  
 
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