* Health sector particularly hard hit, Syria's UN envoy says
* He says UN report on children in conflict "fraudulent"
* U.S., EU, Arab League have imposed sanctions on Syria
By Michelle Nichols
UNITED NATIONS, Oct 22 (Reuters) - Sanctions imposed on Syria by the European Union, the United States and others over its 19-month conflict are "immoral and illegal" and harming Syrian children, the government wrote in a letter to U.N. Secretary-General Ban Ki-moon released on Monday.
The letter from the Syrian government was in response to a recent report by Leila Zerrougui, Ban's special representative for children and armed conflict, who accused both sides in Syria of targeting children with bomb attacks, sexual violence and torture.
The Syrian government said the claims against it were "unsubstantiated and fraudulent" and relied on allegations by the media and opposition groups rather than facts. The government said sanctions were hurting the children.
"It is the children who are primarily adversely affected by those sanctions and the challenges they post to the various sectors and, in particular, the health sector," Syrian U.N. Ambassador Bashar Ja'afari wrote in the Oct. 4 letter.
"The difficulty of exchanging money that has ensued from the embargo placed on national banks has impacted the import of children's vaccines and the availability of medications, raised the cost of medical equipment and made supplies thereof unreliable," Ja'afari said.
He said his government called "for the immoral and illegal nature of the unilateral sanctions that have been imposed on Syria to be exposed."
The World Health Organization has said Syria produced 90 percent of its medicines and drugs before the conflict began. But production has been hit by the fighting, lack of raw materials, impact of sanctions and higher fuel costs, it said.
The United States, European Union and Arab League have imposed various sanctions on Syrian President Bashar al-Assad's government in a bid to bring peace to the country where 30,000 people have been killed in the fighting.
"It is the armed terrorist groups that are violating the rights of the child in Syria and obstructing the evacuation of the injured and sick, children and disabled persons from certain quarters where they are held hostage," Ja'afari wrote.
The issue of children and armed conflict sparked a split in the Security Council last month with China, Russia, Pakistan and Azerbaijan abstained from a U.N. Security Council vote to renew Zerrougui's mandate over concerns the U.N. envoy can investigate any conflict, not just those before the council.
Russia and China have vetoed three U.N. Security Council resolutions condemning Assad's government and calling for an end to the conflict. They have also rejected the idea of imposing sanctions on Syria.
A report by Ban to the Security Council on children and armed conflict, based on the work of his envoy, covers conflicts in 23 countries. Of these, 16 are on the council agenda and seven are not - Colombia, India, Pakistan, the Philippines, Sri Lanka and the southern border provinces of Thailand and Yemen.