G/SPS/GEN/1637  
 
26 July 2018  
(18-4753) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
CONCERNS WITH PRIVAT E AND COMMERCIAL STA NDARDS  
FORMAL MEETING OF THE WTO SPS COMMI TTEE – 12 JULY 2018  
Communication from Belize  
The following communication, received on 24 July 2018, is being circu lated at the request of the 
Delegation of Belize . 
 
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1. Belize, with the kind support of the Food and Agriculture Organization of the United Nations, 
was able to have representation at the government to government and government to business 
meetings held in Japan in the month of March 2018.  
2. We also thank the governments of Canada and Japan for the invitation and the Global Food 
Safety Initiative (GFSI) for waiving the registration fee for the Global Food Safety Conference.  
3. At the margins of the Food Safety Conference, a few Members of the GFSI Board gave us 
the opportunity to register our concerns on matters related to private and commercial standards, 
and their negative impact on the exporting companies in Belize.   
4. Belize informs Members that since concerns with private and commercial standard s were 
first raised in the SPS Committee (2005) to now (2018), the private sector has noted the 
following:  
 Audits to maintain certification continue to be conducted annually by the certification 
bodies;  
 Audits by the buyers are now at an average of two per  annum (in addition to audits by 
competent authorities and the private certification bodies);  
 Financial costs associated with the audits continue to be the sole responsibility of the 
exporting company (except where it is conducted by a competent authority of the 
importing country);  
 The scientific basis for some requirements continues to be lacking; and  
 MRLs and limits for microbial contaminants are still not aligned with those of Codex.  
 
5. In addition to the Committee Decision on "Actions Regarding SPS -Related Private 
Standards ", as contained in document G/SPS/55, we encourage Members to:  
 Continue the dialogue with the certification programme owners and buyers to continue for 
them to understand the impact of their requirements, especially on exporters from 
developing and least developing countries;  
 Advise certification programme owners and buyers of the importance of ensuring that 
sanitary and phytosanitary requirements are based on science and applied only to the 
extent necessary;  G/SPS/GEN/163 7  
 
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   Encourage participation in  the Codex standard -setting process to assist  certification 
programme owners and buyers to align their requirements with those of the international 
standard setting body; and  
 Ensure that the technical support that is available to some countries in which th ese 
standards are being applied, is also made available, especially to those developing 
countries where the exporters are most negatively affected.  
6. Finally, without prejudice to the views of Members on whether this agenda item should 
continue to be discuss ed in this Committee or whether it falls within the scope of the Application of 
the Agreement on Sanitary and Phytosanitary Measures, we would like to remind Members of the 
legal obligations contained in Article 13 of the SPS Agreement. In particular, we d raw Members 
attention to the second and third sentences in that provision:  
"Members shall formulate and implement positive measures and mechanisms in support of 
the observance of the provisions of this Agreement by other than central government 
bodies [emp hasis added] ." 
 "Members shall take such reasonable measures as may be available to them to ensure 
that non-governmental entities [emphasis added] within their territories, as well as 
regional bodies in which relevant entities within their territories are members, comply with 
the relevant provisions of this Agreement ." 
7. We believe that the development of guidelines for the implementation of Article 13 are far 
overdue, and as such strongly recommend that the Committee make an effort to initiate work in 
that r egard.   
8. Our hope is that the work currently being undertaken in the Codex Committee on Food 
Import and Export Inspection and Certification Systems (CCFICS) on "Guidance for Competent 
Authorities to assess Third Party Assurance and its Potential to Inform National Food Control 
System Planning " serves as a catalyst to advance the work on this agenda item and influences the 
development of guidelines for the implementation of Article 13 . 
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