G/SPS/GEN/2044  
 
28 June 2022 
(22-5005) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
CHINA 'S ADMINISTRATIVE MEASURES FOR REGISTRATION OF OVERSEAS 
MANUFACTURERS OF IMPORTED FOOD (26 NOVEMBER 2019)  
– SPECIFIC TRADE CONCERN 485  
SUBMISSION BY THE UNITED STATES  OF AMERICA  
The following submission , received on 24 June  2022, is the statement made by the United States  of 
Ameri ca 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.  The United States remains deeply concerned with China's lack of response to requests for 
scientific justification or an explanation of how Decrees 248 and 249 will address food safety and 
public health concerns, and requests any risk assessments that infor med the development of these 
decrees. The United States remains particularly interested in assessments that justify the 
identification of high -risk products and the application of these measures to low -risk products.  
2.  The United States notes that the lack o f guidance provided by China and inconsistencies in China's 
implementation and enforcement of the measures continues to cause considerable confusion for 
exporters and competent authorities.  
3.  The inconsistent and changing application of these administrative measures is directly leading to 
disruptions in trade. US agencies continue to face administrative burdens as they work to resolve 
issues with shipments held up at ports in China.  
4.  As we echo statements raised in every meeting of this Committee since June 20 20, any measure 
of this magnitude requires far more time for producers, exporters, and competent authorities to 
implement. Therefore, we again ask that China take the following steps to facilitate trade:  
− First, the General Administration of Customs of China (GACC) should continue to use existing 
government -to-government facility registration processes, as outlined in Article 11 of 
Decree  248, and not require facilities to enter information online, where such pre -established 
processes exist;  
− Second, allo w entry of all products from registered facilities until at least 1 July 2023 without 
requiring complete registration information or competent authority intervention. 
This additional time will allow facilities to accurately enter or update product informat ion in 
their online registration;  
− Third, provide a central point of contact at the GACC for facilities to contact directly with 
concerns about the online registration system. Facilities should be able to communicate with 
this point of contact in English fr om outside of China, and the point of contact should not 
refer general registration questions to satellite GACC offices at individual ports;  
− Fourth, hold an informational session in Geneva for trading partners to learn more about 
GACC's implementation of t he Decrees.  G/SPS/GEN/2044  
 
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  5.  We note that GACC's requests for additional detailed information from facilities and competent 
authorities, such as process -specific food safety plans and photographs on an establishment -by-
establishment basis, create additional administrative burdens for exporters and appear to be 
unnecessary and unjustified.  
6.  We look forward to China's response to these specific requests and comments.  
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