G/SPS/GEN/2145  
 
18 July 2023 
(23-4854) Page: 1/1 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
  
EUROPEAN UNION  REVIEW OF LEGISLATION ON VETERINARY MEDIC INAL PRODUCTS  
– SPECIFIC TRADE CONCERN 446  
SUBMISSION BY THE UNITED STATES  OF AMERICA  
The following submission, received on 14 July  2023, is the statement made by the United States of 
America at the 12-14 July 2023 WTO SPS Committee, and is being  circulated at the request of the 
Delegation of the United States  of America . 
 
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1.  This is the twelfth time the United States has raised its concerns in this Committee on the 
implementation of Article 118 of EU Regulation 2019/6.  
2.  The United States continues to be concerned that the EU regulation will unnecessarily limit access 
to animal production practices that are necessary and appropriate for farmers and producers within 
their own countries and pose no food safety risks.  
3.  The EU regulation does not allow for alternative regulatory approaches by third country systems 
that achieve the sam e level of protection. Members require flexibility in how they use veterinary 
medicines because animal species, specific pathogen -causing diseases, health management 
practices, antimicrobial access, availability of alternative treatments, and antimicrobial  susceptibility 
profiles continue to vary by region, country, and even regions within countries.  
4.  The European Union has yet to provide scientific evidence that demonstrates that its measures 
are justified, will significantly and effectively reduce the occu rrence of foodborne antimicrobial 
resistance, and are the least restrictive to achieve the EU member States ' appropriate level of 
protection.  
5.  As such, the United States remains concerned that the unilateral restriction by the 
European  Union on the use of specific production practices in other countries unnecessarily hinders 
the ability of producers in those countries to raise animals in the most  efficient and sustainable 
manner for their local conditions. Growth promoters safely and efficiently increase yield; through 
their use, feed and other inputs may be optimized for animals to reach market weight more quickly, 
which can result in production systems that are more environmentally and economically sustainable 
than other approaches.  
6.  Further, the United States understands that the European Union is contemplating a 24 -month 
transition period, which is impractical for the implementation of these mea sures, as this time period 
does not accurately consider the lifespan of different animal species and the shelf and storage life 
of products already in the supply chain.  
7.  We appreciate the European Union for recently hosting a second virtual meeting to keep third 
countries informed on the draft Implementing Regulations. However, given the extent that these 
measures will uniquely impact trading partners, we expect the European Union to meaningfully 
engage with Members through bilateral consultations in order t o mitigate any potential trade 
disruptions.  
8.  As such, the United States remains available for bilateral engagement to further discuss 
implementation of Article 118.  
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