chinas aqsiq official certification requirements for food imports g tbt n chn 1209 previously raised as lack of transparency for certain sps measures in march 2004 the united states expressed concerns over chinas failure to notify nearly 60 regulations covering food forestry and fishery products issued since 2002. burdensome certification requirements for fresh chilled and frozen aquatic products were imposed by aqsiq decree 31 which entered into force on 1 july 2003 but were not notified to the wto. despite holding bilateral consultations with china no progress had been made on this issue. the united states urged china to comply with its sps obligations and to notify new regulations so that members had an opportunity to comment on them. china stressed that it had notified 213 sps measures since its accession and was committed in fulfilling its transparency obligations. the comment period was calculated from the day the secretariat circulated the notification. there was no obligation to notify aqsiq decree 31 as it was an operational rule of a corresponding regulation that had already been notified to the wto and imposed no new technical requirements. however in the interest of enhanced transparency decree 31 had been notified in august 2003 g sps n chn 22 . in june 2016 the united states reiterated its concern first raised in march 2004 with chinas lack of transparency for certain sps measures. the united states recognized that china had been actively notifying the sps measures of many of its agencies and expressed appreciation for these efforts. however recently many measures issued by some of chinas principal regulatory agencies in relation to the implementation of chinas 2015 food safety law had not been notified. the united states indicated as an example a recent chinese measure implementing the new official certificate requirement for imported foods of which the united states had become acquainted through a letter sent by the chinese general administration of quality supervision inspection and quarantine aqsiq to the united states embassy in beijing on 9 may 2016. the united states urged china to notify this measure as well as all sps measures that could impact international trade in order to allow its trading partners to comment on them and to take these comments into account upon finalizing the measures. the united states again expressed appreciation to china for the substantive bilateral dialogue on transparency and looked forward to further cooperation with china to improve food safety. australia reminded all members that they should notify in accordance with their wto obligations. while appreciating that it was sometimes difficult to determine whether a measure required notification or not australia encouraged members when in doubt to notify. the european union supported the points made by the united states and australia and underlined its particular concern about the new chinese certification regime. the european union feared that this specific measure would not be justified by any risk assessment as the products concerned pasta confectionary or baked products were inherently safe and would impose a disproportionate and unnecessary burden on the importing countries. the european union looked forward to seeing the chinese notification for this measure and to work with china on this issue. new zealand shared the concerns of australia the european union and the united states regarding chinas lack of transparency and especially highlighted australias more generic reminder to encourage all members to notify their sps measures. new zealand insisted on the values of the notification system in allowing members to comment and clarify measures as well as exchange experiences. new zealand wondered whether a lack of transparency in notifying sps measures could be associated with a lack of experience with the notification system and recalled the value of the mentoring system put in place some years ago wherein developed members helped developing members to manoeuvre the notification system. china responded that from