PolicyBrief
S. 1104
119th CongressMar 25th 2025
WATCH Act
IN COMMITTEE

The WATCH Act mandates quarterly inspections and certification for foreign laboratories receiving U.S. federal funding for animal research to ensure compliance with animal welfare standards.

Eric Schmitt
R

Eric Schmitt

Senator

MO

LEGISLATION

WATCH Act Demands Quarterly Inspections for Foreign Labs Using U.S. Research Dollars, Starting in 6 Months

The Worldwide Animal Testing Compliance and Harmonization Act of 2025 (WATCH Act) is throwing down a new set of rules for international labs that take U.S. federal money—specifically grants or contracts from the National Institutes of Health (NIH)—to do research involving animals. Six months after the Act becomes law, any foreign facility receiving these funds must submit to mandatory, quarterly (every three months) inspections to prove they are meeting U.S. standards for animal care and oversight (Sec. 2).

The New Compliance Checklist

Think of this as mandatory quality control for research funded by your tax dollars, no matter where it lands. The inspections aren't just a formality; they specifically check whether the foreign lab has the proper animal care committees in place, if those committees are actually reviewing and managing animal welfare correctly, and if the lab is keeping accurate records and reporting everything properly. If a lab passes the quarterly inspection, they get a public compliance certificate from the Office of Laboratory Animal Welfare (OLAW). This ramps up transparency, making it easy to see which foreign partners are following the rules.

What Happens When the Grade is Low

Here’s where the teeth of the bill come in. If a foreign lab fails an inspection, they get a chance to fix the problems the inspectors found. But if they don’t correct the deficiencies after that “reasonable chance,” the Secretary has the power to suspend or completely revoke the NIH grant or contract. This is a massive new enforcement tool. For U.S. researchers who rely on international collaborations—say, a team working on a rare disease that requires specialized foreign facilities—this introduces a new layer of risk and administrative burden. If their foreign partners can’t keep up with the quarterly inspections, the entire project's funding could dry up.

The International Red Tape Challenge

Implementing this isn't just about sending an inspector with a clipboard. The Secretary and the NIH Director are required to work with foreign governments and regulators to make these inspections happen smoothly, all while “respecting the laws and sovereignty of those foreign countries.” This is the biggest potential sticking point. While the goal is great—better animal welfare and accountability abroad—the reality is that if a foreign government pushes back or has laws that restrict access, the effectiveness of these quarterly checks could be severely limited. The bill essentially creates a high standard for compliance but then ties the hands of the enforcers by mandating respect for local laws, which might create a loophole where enforcement is most needed.