EFFPA members consider feed safety the top priority when it comes to the processing former foodstuffs. Upstream food chain partners and downstream feed chain partners need to be able to have confidence in the former foodstuff processing sector as a sector that will guarantee safety and traceability of its products. As former foodstuff processors produce a feed ingredient, they are legally considered feed business operators under EU law and therefore have to comply with several essential EU Regulations and Directives;
- Regulation (EC) No 183/2005 laying down Requirements for Feed Hygiene
This entire regulation is applicable to former foodstuff processors, given it applies to all feed business operators. This means inter alia that EFFPA members need to implement the principles of HACCP to achieve the highest level of feed safety possible.
- Regulation (EC) No 178/2002 laying down the General Principles and Requirements of Food Law
It is important to remember that the principles of food law apply just as much to feed business operators as they do to food business operators, given the fact feed eventually enters the food chain when given to food-producing animals. In Article 15 the feed safety requirements are stipulated, with specifically highlighted that feed must be safe and may not have any adverse effect on animal or human health. Article 18 stresses that feed needs to be traceable and identifiable throughout the supply chain and operators like former foodstuff processors need to be able to present this information to control authorities on demand. In Article 20 the responsibilities for feed business operators are described, which specifically call operators to maintain the integrity of feed and inform the authorities in case a non-compliance is found.
- Regulation (EC) No 767/2009 on placing on the Market and Use of Feed
When former foodstuffs are placed on the market as a feed ingredient, this regulation applies. Among other things, this regulation stipulates the labelling requirements for feed.
- Regulation (EC) No 1069/2009 laying down Health Rules as regards Animal By-Products and Derived Products not intended for Human Consumption
- Former foodstuffs that contain or are derived from animal by-products (milk, eggs, honey and gelatine) are identified as “category 3” animal by-products and more specifically described in Article 10(f) of this regulation. Depending on the Member State, registration according to Article 23 may be required. With Regulation (EC) No 294/2013, section 10 was amended to make clear that “ABP former foodstuffs” do not require further treatment when used in feed given they’ve already undergone treatment during the food processing. It is important to note that “ABP former foodstuffs” do not carry any elevated risks in comparison to former foodstuffs of vegetable origin, but because of the way EU legislation is formulated they need to be identifiable along the whole chain.
- Regulation (EC) No 882/2004 on Official Controls performed to ensure the Verification of Compliance with Feed and Food Law
This regulation lays down the rules for official feed controls, which former foodstuff processors as feed business operators are subject to.
- Regulation (EU) No 68/2013 on the Catalogue of Feed Materials
The Catalogue of Feed Materials is a voluntary, co-regulated guide to feed materials used in EU livestock farming. The use of common definitions for the many different feed materials allows for structured dialogues between feed supply chain partners and avoids confusion. In the Annex, Part A(3), the definition of former foodstuffs is provided.
- Directive 2002/32/EC on Undesirable Substances in Animal Feed
In the light of delivering safe feed to the market, former foodstuff processors need to comply with this entire legislation that dictates maximum limits for undesirable substances in animal feed.
- Directive 2008/98/EC on Waste
The legal status of former foodstuffs destined to animal feed has not been concretely defined in EU legislation to this day. To underline former foodstuffs are not a ‘waste’ in legal terms, former foodstuff processors use Article 5 of the Waste Framework Directive, where the criteria of by-products are listed.
EFFPA members take part in national and regional quality assurance schemes which ensure proper implementation of HACCP requirements as regards feed safety. It is part of EFFPA’s future commitments to develop a feed safety management guide for the former foodstuff processing sector in order to set the sector’s minimum requirements.