G/SPS/GEN/2046  
 
28 June 2022 
(22-5007) Page: 1/2 
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 24 June 2022, is the statement made by the United States of 
America at the 22-24 June 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.  In April, through G/SPS/N/EU/557 , the EU Comm ission notified the list of antimicrobials that will 
be reserved for human use. The United States acknowledges that the Commission followed the 
European Medicine Agency 's recommendations.  
2.  However, the United States continues to have concerns, and again ref ers to previous statements 
made at the SPS Committee and documented in the summary reports, regarding the implementation 
of Article 118 of EU Regulation 2019/6.  
3.  We would like to reiterate that animal species, specific pathogen -causing diseases, health 
mana gement practices, antimicrobial access, availability of alternative treatments, and antimicrobial 
susceptibility profiles vary by region, country, and even regions within particular countries. 
Any EU measure should allow flexibility to trading partners to use a mix of tools and techniques to 
meet the EU level of protection, in a manner that is appropriate to the needs of farmers and 
producers in the exporting countries ' own domestic context.  
4.  The United States remains concerned that the application of EU hea lth standards to imported 
agriculture and agri -food products from third countries will undermine the competency of national 
authorities of the EU trading partners to establish measures necessary for the protection of animal 
within their own territories.  
5.  Regardless of when measures are implemented, our concern remains that the legislation may 
unjustifiably limit access to the medicines needed in modern animal husbandry, particularly in 
developing countries where alternative treatments are not available.  
6.  The United States requests the scientific justification for the EU restrictions on the use of 
antimicrobial drugs for growth promotion that are not medically important for humans, as such 
provisions may negatively impact livelihoods of livestock producers in the European  Union  and 
beyond, and ultimately prevent countries from achieving food security and sustainable development 
goals.  
7.  Codex Alimentarius recently adopted valuable guidance on addressing AMR through the updated, 
"Code of Practice to Minimize an d Contain Foodborne Antimicrobial Resistance ", and we encourage 
the European  Union  to harmonize its approach with relevant international standards. 
Unilateral  approaches can undermine the multilateral system and create unnecessary uncertainty 
and disruptio ns for producers and consumers.  
8.  We would like to remind the Commission that in July 2021, DG SANTE offered to meet and 
provide updates to third countries. Members are ready to meet and await the EU setting a date for 
this meeting as soon as possible to sha re the outstanding details of the legislation, including its G/SPS/GEN/2046  
 
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  scientific justification, the relationship between the proposed measures and their risk assessments, 
and how the proposed measures will consider the competence of third country regulatory systems . 
9.  Also, the United States requests again that the EU Commission provide a new timeline, taking 
into consideration the lifespan of different animal species, for a pragmatic implementation process 
that considers the shelf and storage life of products already in the supply chain. In addition, 
the United States again urges the European  Union  to base its regulations on science and risk, and 
to be mindful of the impact of its SPS measures on global animal health, food security, international 
trade, and agr icultural sustainability.  
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