. /.   WORLD TRADE  
ORGANIZATION  G/SPS/W/254 
21 December 2010 
 
 (10-6859) 
Committee on Sanitary a nd Phytosanitary Measures Original:   Spanish 
  
 
ON-SITE AUDIT PROCEDURES 
 
Proposal by Argentina
 
  
 The following communication, received on 20 December 2010, is being circulated at the 
request of the delegation of Argentina
. 
 
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I. INTRODUCTION 
1. Control, inspection and approval procedures ar e important tools for verifying and ensuring 
compliance with sanitary and phytosanitary measures.  The relevant rights and obligations of Members are set out in Article 8 and Annex C of the Agreement on the Application of Sanitary and 
Phytosanitary Measures (SPS Agreement).  Comp liance helps to achieve a balance between 
Members' right to adopt the sanitary measures they  consider relevant and the obligation to prevent 
such measures from being applied in such a way as to constitute either arbitrary or unjustifiable 
discrimination among Members in which the same situ ation exists or a disguised restriction on 
international trade. 
2. Nevertheless, the ambiguity or lack of precisi on characterizing certain provisions in Annex C, 
as well as the lack of guidelines clarifying their cont ent and scope, have led to significant differences 
between Members with regard to the design and im plementation of their national control systems.  
These disparities have resulted in major trading difficulties which seriously affect exporters, 
especially as far as developing countries are concerned. 
3. Argentina wishes to express particular concer n regarding inspection procedures that take 
place in the territory of the exporting Member.  Paragraph 3 of Annex C to the SPS Agreement 
provides that "Nothing in this Agreement sha ll prevent Members from carrying out reasonable 
inspection within their own territories".  The absen ce of additional guidelines gives greater rise to 
situations that both hamper international trade and make it more costly, for example, visits, 
inspections or audits which are disproportionately frequent or lengthy without justifiable reason and 
the cost of which has to be borne, in the majo rity of cases, by the exporting Member.  Attention 
should be drawn to the fact that, in many instanc es, there are also considerable differences in the 
methodology used for the visits, inspections and a udits carried out by importing Members and, in 
some cases, by different institutions within the same importing Member. 
4. Argentina would like to emphasize that the international reference organizations (Codex, 
IPPC and OIE) have carried out important work  as regards harmonizing control, inspection and 
approval systems.  Nevertheless, certain asp ects which are pending harmonization go beyond the 
technical and scientific scope of the "Three Sisters" and relate to trade issues, which, by their very 
nature, should be addressed by the SPS Committee. G/SPS/W/254 
Page 2  
 
  5. As was the case with regard to the regionali zation work carried out by the SPS Committee, it 
is not our intention to duplicate efforts or create overl apping activities.  On the contrary, we feel that it 
is important to complement the technical work of the "Three Sisters" with procedural provisions which enable multilateral obligations to be implemented coherently  and consistently. 
II. PROPOSAL 
6. Although Argentina remains concerned about the discrepancies in criteria in relation to the 
implementation of certain paragraphs of Annex C
1, it suggests that work should commence with the 
issue of audits. 
7. In particular, we propose the following: 
 (a) Members should be urged to excha nge information on their experiences and 
difficulties with implementing paragraph 3 of Annex C to the SPS Agreement in the 
light of the international reference standard. 
  (b) The Committee should submit responses to the international reference organization 
responsible in this area, so that the problems identified can be analysed and 
consideration given to whether new standa rds need to be created or existing ones 
amended. 
  (c) In the event of the competent organization reporting that an appropriate, valid 
international standard does exist, the Comm ittee should be able to discuss the issues 
arising from the implementation of this st andard under a new specific agenda item. 
 
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1 G/SPS/W/244.