SUBMISSION BY THE UNITED STATES OF AMERICA

The following submission, received on 10 December 2025, is the statement made by the United States of America at the 5-7 November 2025 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 concerned that the EU's implementation of Article 118 will result in unnecessary negative trade impacts to US exports.

2.  The European Union still has not published a risk assessment to justify the restriction of certain products derived from animals treated with antimicrobials.

3.  Furthermore, the European Union has yet to provide an evidence-based rationale for restricting the use of non-medically important antimicrobials to promote growth.

4.  As such, Article 118 does not appear to address the issue of anti-microbial resistance (AMR) from a science- and risk-based standpoint, nor does it appear to be based on existing international guidance on combatting AMR issued by Codex.

5.  The United States again requests that the European Union take a risk-based approach in addressing concerns related to AMR and exempt low-risk animal products from Article 118 and all related delegated and implementing acts.

6.  We look forward to continuing engagement with the European Union in order to avoid any unnecessary trade disruptions resulting from the implementation of Article 118.

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