G/SPS/GEN/1866  
 
18 November  2020 
(20-8299) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
INDIA'S NEW REQUIREMENTS FOR ANIMAL FEED IN THE FOOD SAFETY  
AND STANDARDS ACT, 2006 (DATED 27 JANUARY 2020) –  
SPECIFIC TRADE CONCERN 479  
SUBMISSION  BY THE UNITED STATES  OF AMERICA  
The following document , received on 13 November  2020, is being circulated at the request of the 
Delegation of the United Sta tes of America . 
 
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1.1.  The United States remains concerned with India 's new directive on animal feed, issued on 
27 January 2020. We anticipate that the directive will have a significant impact on trade in feed 
ingredients, and possibly on meat and dairy products from livestock fed in other countries and 
imported by India.  
1.2.  The directive contains two parts. Part one of the directive make s mandatory the form erly 
voluntary guidance for animal feed, to implement the Bureau of Indian Standards (BIS) 
specifications for Compounded Feeds for Cattle (IS 2052:2009). Part one has not been notified to 
the WTO SPS Committee and, to date, WTO Members have not had an oppo rtunity to comment on 
this regulation. Part two of the directive was notified to the SPS Committee as G/SPS/N/IND/249  on 
26 February 2020.  
1.3.  The United States appreciates that India provided a six -month implementation period for 
Members to comply with the directive. However, given th e current COVID -19 pandemic and 
its impact on the preparedness of all stakeholders, in addition to the fact that India has not yet 
notified part one of the directive to the SPS Committee, we ask that India suspend implementation 
until India notifies these mandatory requirements and responds to questions and concerns raised by 
Members including those of the United States.  
1.4.  As we noted during the June 2020 SPS Committee Meeting, part one of the directive appears 
to make mandatory a guidance document from 2009 titled, "Indian Standard, Compounded Feeds 
for Cattle – Specification". According to this document, India only allows import of those feed types 
listed in the document.  
1.5.  This list omits several feed ingredients commonly used around the world, such as distillers ' 
dried grains with solubles (DDGS), alfalfa, timothy hay, and several types of vitamin and mineral 
feed supplements.  
1.6.  It appears that this list has not been updated since 2009 to include new or different feed types. 
We again request that India pl ease clarify the criteria used to compile the list and the process by 
which other types of feed can be added to the list.  
1.7.  Part two of the directive also includes language that amends requirements for meat and meat 
products as detailed in the 2011 FSSAI Foo d Product Standards and Food Additives Regulations. 
This text appears to link feed and the acceptability of meat and meat products from cattle fed with 
certain types of feed. The text states that milk - and meat -producing animals, except poultry and 
fish, s hall not be fed with feed containing bovine - or swine -origin materials except for milk/milk 
products.  G/SPS/GEN/1866  
 
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  1.8.  The United States raised concerns with these regulations during previous SPS and 
TBT Committee meetings, and we have not received a response or further ex planation on this issue 
from India. We again request that India please provide further information to the United States on 
these important matters.  
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