SecProbe.io

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Mail Stop 0308

	November 12, 2004

Thomas Lamb,
President
Europa Trade Agency, Ltd.
3715 West 14th Avenue
Vancouver, British Columbia V6R 2W8

	RE:	Europa Trade Agency, Ltd.
		Registration Statement on Form SB-2
		Commission File No. 333-118808
		Filed on September 3, 2004

Dear Mr. Lamb:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your disclosure.
After reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other aspect
of our review.  Feel free to call us at the telephone numbers listed
at the end of this letter.

Form SB-2
General
1. On the facing page, add a sentence indicating that securities are
being offered on a delayed or continuous basis pursuant to Rule 415.
See interpretation D.36 of the Manual of Publicly Available Telephone
Interpretations (July 1997) and Form S-1 to review the disclosure
that you should include.
2. We note the various websites you have identified throughout your
registration statement, including your own website, as identified on
page 34.  You are responsible for the accuracy of information on the
websites to which you refer in your registration statement.  Revise
the language that indicates that you are not responsible for the
content and that investors should not rely on the information on the
websites.
3. Please supplementally advise us why you have undertaken to
register the securities on behalf of the selling shareholders and
have agreed to pay the offering-related expenses.  We note that you
have not granted any registration rights to the selling shareholders
or to any other persons.

Prospectus Cover Page
4. Please disclose here your intention to apply for a listing of
common stock on the OTC Bulletin Board.
5. Describe the manner in which the securities will be sold.  See
Item 501(a)(9) of Regulation S-B.
6. Please tell us whether you intend to use the prospectus before the
effective date of the registration statement.  If so, you should
include the legends required by Item 501(a)(10) of Regulation S-B.
7. Please include disclosure on the cover page of the prospectus
stating that the selling shareholders will sell at a price or price
range per share until your shares are quoted on the OTC Bulletin
Board and thereafter at prevailing market prices or privately
negotiated prices.  You should specifically state the price or price
range.
8. Clarify here and in the offering section of the summary that you
are registering all of the 1,010,000 common shares on behalf of
selling shareholders, and disclose that you will not receive any
proceeds from the sale of the securities.

Summary, page 6
9. Avoid reliance on defined terms like those in parentheses and
quotation marks.  See Updated Staff Legal Bulletin No. 7 (June 7,
1999) sample comments 2, 3, 4, 5 and 39 available on our web site at
www.sec.gov under the heading "Staff Interpretations."
10. Please revise to clarify that you were "reincorporated" in Nevada
on May 26, 2004.
11. Please specify whether you are currently receiving revenue from
any of your relationships with the entities or products mentioned.
We note that revenues are solely derived from the sale of golf
nutrition bars.  Disclose that you have received only minimal revenue
to date and only from one of your products.

12. Provide us with support for your statements indicating that The
Kalamazoo Grill`s products have been featured in various
publications.  Supplementally provide us with the articles you have
referenced.
13. Please clarify what you mean when you say you "represent"
McKirdy`s RepalFly.  Clarify that you have negotiated the right to
market McKirdy`s products but have not as of yet signed a formal
agreement.  We note your disclosure on page 26 in the "Description of
the Business" section.
14. Please elaborate on the "exclusivity arrangement" you have with
Wal-Mart Canada.  What does this entail?
15. Disclose the company`s telephone number in the summary.  See Item
503(b) of Regulation S-B.

The Offering

Terms of the Offering, page 7
16. We note your disclosure that the selling shareholders will
determine when and how they will sell the common stock offered in
this prospectus.  Please revise to clarify that they will do so
subject to compliance with the applicable securities laws.

Risk Factors
17. It appears that your shares of common stock will be treated as
"penny stock" as defined by Rule 3a51-1 under the Exchange Act, and
thus the shares are subject to the penny stock rules.  Include a risk
factor that discloses that the shares are subject to the penny stock
rules, and note the risks involved in investing in penny stock.  In
this regard, consider discussing that: (i) Commission rules impose
additional sales practice requirements on broker-dealers who sell
such securities to persons other than established customers and
accredited investors, (ii) for transactions covered by the rule, the
broker-dealer must make a special suitability determination for the
purchaser and transaction prior to the sale, and (iii) the rule may
affect the ability of broker-dealers to sell the securities and also
may affect the ability of purchasers of the shares to sell the shares
in the secondary market.

We expect to incur operating losses for the foreseeable future, page
9
18. Please specify that you derive revenue from one product, the golf
nutrition bar, and quantify the revenue derived from the product as
of July 31, 2004.

If we are unable to effectively market our products . . ., page 10
19. Please specify that you have little or no market share for the
products you are currently marketing.

We heavily rely on third parties to supply and sell our products,
page 10
20. Please specify the types of services subdistributors will
provide.
21. Please specify whether you have any long-term agreements with the
third parties upon which you rely.

As our officers and directors do not devote 100% of their time to our
. . ., page 10
22. We note the individuals mentioned here.  Please identify the
position or positions that each person holds.  Disclose that you do
not have any employees other than your officers and directors.

Because Thomas Lamb and Craig Lamb, his father, will together . . .,
page 11
23. We note the beneficial ownership table on page 22 indicates that
Thomas and Craig Lamb together currently own 66% of the common shares
outstanding.  Please revise this risk factor to clarify, if true,
that Thomas and Craig Lamb currently have effective control of the
company and will continue to have control after the offering.

Determination of Offering Price, page 12
24. We note the disclosure on page 7 that indicates that the offering
price will be $0.09 per share.  Please disclose the manner in which
you determined the offering price.  See Item 505 of Regulation S-B.

Selling Security Holders, page 13
25. Provide the selling shareholder information as of the most recent
practicable date.
26. We note that you have included a qualifier indicating that "to
[your] knowledge" none of the selling shareholders has a material
relationship with you and none has ever been an officer or director
of Europa.  You are responsible for the disclosure in the
registration statement and this knowledge qualifier is inappropriate.
Please revise.

27. Tell us which selling stockholders, if any, are broker-dealers,
and identify them as underwriters.  Also, tell us which selling
stockholders are affiliates of broker-dealers.  For each selling
stockholder that is an affiliate of a broker-dealer, disclose if true
that:

* The selling stockholder purchased the shares in the ordinary course
of business, and
* At the time of the purchase of the securities to be resold, the
seller had no agreements or understandings, directly or indirectly,
with any person to distribute them.

Plan of Distribution, page 18
28. Please clarify what you mean when you indicate that your selling
shareholders may sell some of all of their common stock through the
writing of options on the common stock.

Directors, Executive Officers, Promoters and Control Persons, page 19
29. Provide this disclosure as of the most recent practicable date.
30. Please provide support for your statements regarding Daniel
Turner and Rebecca Turner`s successes and business experience.  For
instance, on what information do you base your statement that Mr.
Lamb specializes in taking sales operations that under-perform and
turns them into successful, efficient, money-making businesses?
Also, please provide support for your statement that Mr. Turner
developed and built workable internet marketing and sales systems
from scratch, managed multiple employees and salespeople, and turned
them into respective internet programs into successes.  In addition,
provide support for your statement that Ms. Miller was consistently a
leading salesperson by several measures.  If you are unable to
provide adequate support, please revise to eliminate these
statements.

Security ownership of certain beneficial owners and management, page
21
31. Provide the beneficial ownership information as of the most
recent practicable date.  See Item 403 of Regulation S-B.  Also,
delete the qualification that the information is provided for each
person "known to us."  You have a duty of reasonable inquiry to
determine any holders of more than 5% of your securities.  Delete the
limitation that you have included.

32. Please reconcile the 3,000,000 shares disclosed here to the
3,010,000 shares issued and outstanding that is disclosed on page 23
under common stock.
Disclosure of Commission Position of Indemnification For Securities
Act Liabilities, page 24
33. Please expand your disclosure to describe with more specificity
the indemnification provisions as provided by the Nevada Revised
Statutes and your other documents.

Key Agreements and Developments, page 25
34. Please specify the interest rate on the loan offered by Thomas
Lamb.
35. Please discuss the material terms of the material agreements you
have identified.  For instance, specify any material termination
provisions related to the agreement with The Kalamazoo Grill Company
and Bug Master.  Also, discuss Rebecca Miller`s compensation under
her agreement.
36. We note your disclosure of several agreements executed by you in
2004 to distribute products for other companies.  Supplementally
please tell us and disclose in MD&A if any of these agreements
require you to make any financial commitments.  Please revise your
disclosures here to include the date you expect to commence
distributing products under each agreement.

Description of the Business, page 25
37. Please specify that although you are involved in the sale of
three main product types, you do not receive significant revenue from
them.  Further, quantify the revenue derived from the sales of
gourmet grills, insect repellants and snack bars.

Description of the Products, page 26

The Kalamazoo Grill, pages 26-27
38. Please provide support for your statement that in the
marketplace, Kalamazoo grills are recognized as high-quality,
American-made products and that Kalamazoo was chosen by Harley-
Davidson Motorcycles to be the exclusive manufacturer of the Harley-
Davidson Grill.

Market for the Product, pages 27-28
39. We note the statistics cited in the second paragraph of this
section.  It is unclear where the supporting information is located
on the website you cite.  Please provide supporting information or
revise.  Also, provide support for all of the statistics you have
cited throughout the registration statement, including claims
regarding the market for nutritional and meal replacement bars.
40. We note your reference to The Shopper Report.  Please provide
background information regarding this publication.  Also, it is
unclear why you are confident that the Canadian market has
experienced an increase in barbecue occasions comparable to the
increase in the United States market.  Please provide information
supporting this statement or revise.  Also, tell us whether you have
received consents from this publication and others to provide these
statistics in the registration statement.
41. We note the last paragraph in this section.  Please specify that
you are citing information from the Health, Patio & Barbeque
Association and briefly provide background information regarding this
association.

Current and Future Revenue Streams, page 31
42. Please quantify the revenue derived from the sale of golf
nutrition bars and clarify that you have had no sales of your other
products.
43. We note your disclosure regarding a planned 2004 meeting with
Wal-Mart Canada Corp. buyers.  Please update the disclosure regarding
this meeting.  Do you still plan to have this meeting and plan to
complete a formal agreement by Fall 2004?

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 35

Results of Operations, page 35
44. It is not clear from your disclosures if the $3,385 include sales
of products other than the golf nutrition bar.  It appears that your
sales may only be from the golf nutrition bar.  Please revise your
disclosures to clarify if you sold any other product during the
fiscal year ended July 31, 2004.
45. Please expand your disclosure to specify the services that were
provided in exchange for the professional fees.

Internal and External Sources of Liquidity, page 36
46. Specify the amount drawn down from the credit facility, if any,
and the interest rate on the amount borrowed and outstanding.

Certain Relationships and Related Transactions, page 38
47. Please include a discussion of the $75,000 loan Thomas Lamb
agreed to give the company, including the interest rate that would be
associated with the loan.
48. Disclose whether the terms of Rebecca Miller`s independent
contractor agreement are as beneficial to the company as could be
obtained from unaffiliated third parties.

Recent Sales of Unregistered Securities, page 51
49. We note the issuance of $2 million shares of your common stock
pursuant to Section 4(2) of the Securities Act of 1933.  Please
identify the persons or class of persons to whom you sold the
securities.  See Item 701(b) of Regulation S-B.

Financial Statements

Balance Sheets, page F-2
50. Please disclose separately trade accounts payable for each period
presented.

Statement of Operations, Page F-3
51. You disclose on page 21 in Executive Compensation that your
officers have not received any compensation for services rendered
since inception.  You also disclose on page 37 that your President
provides office and warehouse space at no cost.  We believe that your
financial statements should reflect all of the costs of doing
business.  Supplementally, please tell us the estimated fair value of
the services rendered by your officers and the amount of any other
services not currently included in your financial statements.  Please
revise your financial statements to reflect the fair value of the
services provided by the officers at no cost as a capital
contribution with a charge to the appropriate expense accounts.
Refer to SAB Topics 1:B and 5:T.

Notes to Financial Statements

Note 2.   Significant Accounting Policies

(f)  Revenue Recognition, page 47
52. You disclose that revenue recognition occurs upon delivery