positive list system for pesticides veterinary drugs and feed additives mrls in march 2005 china reported that the issue of japans ministry of health labour and welfare amendment to the maximum residue limits mrls for pesticides veterinary drugs and feed additives had been discussed in a bilateral meeting. although the measure had not yet been notified to the sps committee japan had sought the opinion of the relevant departments and business communities of china on the proposed amendment in 2004. china was concerned that the proposed adoption of a single standard limit of 0.1ppm for the close to 700 types of pesticides veterinary drugs and feed additives for which no specific residue limit had been established would jeopardize chinese exports of vegetables to japan. although china respected the right of japan to protect public health it expected that in doing so japan would as specified in the sps agreement assess the possible impact of such an amendment on exports to japan provide opportunities to discuss the results of this assessment and consider solutions to minimize its impact. china also expected that japan would provide the science-based risk assessment that had led to the amendment of the mrls. should there be any notification in the future on this issue japan should provide a comment period of at least 60 days as of the date of distribution and extend this upon request. the representative of china further requested that when specifying the time for the formal implementation of the proposed amendment japan provide an adequate adaptation period in accordance with the decision at the doha ministerial meeting. finally the representative of china sought clarifications on the japanese detection method for residues. the philippines supported chinas concerns on this issue and requested relevant information from japan in order to assess the possible implications of this proposed amendment on the philippines exports to japan. japan clarified that the japans new positive list system based on the revised food sanitation law was aimed at regulating the distribution of foods that contained agricultural chemicals veterinary drugs and feed additives for which no mrls had yet been established. before the positive list system would enter into force the ministry of health labour and welfare would review the compliance of its provisional mrls with the codex alimentarius standards. chinas concerns on comment and implementation periods would be reported to the relevant japanese authorities. in october 2005 the united states reported that in june 2005 japans ministry of health labor and welfare mhlw had notified its final draft of thousands of new provisional maximum residue limits mrls for over 700 pesticides veterinary drugs and feed additives covering all basic commodity groups.. the united states was grateful of having been consulted throughout the elaboration of this final draft and the development of implementation plans for japans new food sanitation law. in november 2005 the provision of a six-month transition period before official enforcement of the provisional mrls had been notified by mhlw. without any reference to the final draft of june 2005 or in any subsequent notification the ministry of agriculture forestry and fisheries of japan maff had announced in december 2005 the implementation and enforcement of the provisional mrls on rice wheat barley and possibly other commodities. the united states was concerned about the effect of these new mrls on agricultural exports to japan and requested japan to clarify its plans regarding the enforcement of these mrls. china requested japan to provide a transitional period before implementing this positive list system and noted that china had also put this item on the agenda. the representative of australia expressed appreciation for japans collaborative attitude when developing this comprehensive new positive list and noted that japans private sector was also confused about the exact nature of the testi