proposal on animal by-products the united states stated that ec regulation 1774 2002 would severely restrict or prohibit a range of animal by-products intended for use in feed industrial or other non-food purposes. due to the lack of transparency of this regulation the lack of sufficient time and information for exporters to comply and the ec failure to adequately address the concerns of third countries the united states requested a delay in the implementation of the regulation. the united states was also concerned about derogations for certain ec member states that were not available to third countries the lack of scientific justification for the regulation and the lack of a risk assessment for the proposed inter-species feed ban. brazil shared the concerns raised by the united states. china requested the european communities to delay the regulations implementation until 1 may 2005. australia stated that without clarifications and equivalence determinations it would have difficulty in complying by 1 may 2003 and might seek a delay in the full implementation of the regulation. canada stated that it did not see how practical implementation of this regulation would be possible by 1 may 2003 and was of the view that a delay in implementation was warranted and required. the european communities stated that the objectives of the draft regulation were to ban the recycling of dead animals offer alternatives to denaturation take account of environmental requirements control traceability of sub-products and simplify the patchwork of existing legislation. information meetings on 13 november 2002 and 28 march 2003 were organized and an explanatory document had been produced. the measures were based on solid science even though no formal risk assessment had been conducted for each chapter of the text and the european communities were willing to make all relevant information available to trading partners. certain ec member states and third countries had expressed concern over the date of entry into force of the regulation. as a result the european commission was studying transitional arrangements which would enable temporary flexibility on certain provisions. any temporary flexibility or new measures on certification of third country products would be decided on and notified to wto members with a new deadline for comment. in june 2003 china reported that it had submitted comments on the ec regulation on animal by-products but had not received any reply. china would need a transitional period of two years to adjust. the united states stated that concerns raised at the last sps committee meeting were still valid. the european communities confirmed that comments made by china would be carefully examined and that china would receive a response. the european communities would take a flexible view on transitional measures for third countries. in october 2003 the united states reported that despite bilateral technical discussions and the lack of scientific risk assessments disruption of us exports of pet food was likely. canada welcomed the decision to postpone implementation of the regulation for third parties beyond 1 may 2003. ec member states benefited from 16 transitional measures to allow them to adjust to the new regulations and canada asked to also benefit from such transitional measures. china requested a transitional review of the regulation and continued bilateral discussions. the european communities explained that transitional measures had been adopted for ec members states and additional time for compliance for all third parties allowed until 31 december 2003 ec 1812 2003 . certification of imports had been reviewed and notified. the european communities had decided to offer targeted transitional measures to third countries on a case-by-case basis. a technical agreement based on comments received from australia canada china and the united states would be notified shortly. the european communities were awaiting the conc