Challenges of EU organic poultry feed requirements

Under the current law, EU feed millers struggle to meet laying hen nutritional requirements, labeling legislation and the new nitrogen/phosphorus and greenhouse gas emission legislation.

The idealism in the pursuit of 100 percent organic diets for monogastrics is laudable, but impractical and not fully understood by the EU legislature. | Nikada, iStock.com
The idealism in the pursuit of 100 percent organic diets for monogastrics is laudable, but impractical and not fully understood by the EU legislature. | Nikada, iStock.com

In the early days of the European organic movement, it was realized that organic raw materials alone could not entirely satisfy the nutrient requirements of livestock, so a dozen officials sat in a room armed with lists of conventional raw materials, and they selected those conventional ingredients that could be used in organic feeds.

As there were no nutritionists in the room, the resulting “green” list did not include amino acids and enzymes. After the meeting, it was deemed that up to 20 percent of conventional raw materials could be used in organic feeds with the proviso that if the diet contained an organic raw material it could not at the same time contain the same material from conventional origin.

The EU legislators have as much understanding of nutrition as dentists understand outer space, but over the years, the lawyers have slowly reduced the allowable percentage of conventional raw materials.

Eu Conventional Raw Materials Organic Diets

Progression of the percentage of conventional raw materials allowed in organic diets. | Paul Poornan

Since 2011, the lawyers have been pushing to reduce the 5 percent allowance for conventional ingredients to zero percent but, as there are no organic supplies of amino acids, it is impossible to produce diets that meet the nutritional requirements of pigs and poultry. As a result, there is much frustration between the lawyers and the feed millers as the lawyers have tried to force the issue by implementing zero-percent conventional with effect from January each year but have had to back off each time.

There are also similar issues with vitamins, enzymes and carotenoids, which are almost under the radar. Many vitamins and enzymes have a GM-step in their production, and while the authorities understand that vitamins are essential, phytase is banned; consequently, organic diets contain much higher levels of added phosphate than comparable conventional formulations. The liberal use of phosphorus in organic diets sits uneasily against the ethos of the organic movement, particularly when global phosphate deposits are finite. Similarly, there is some small production of organic yolk pigments, but not enough to satisfy global organic production, so in the EU, conventional corn gluten 60 (prairie meal) is often used to supply the carotenoids needed to produce marketable eggs.

Illustration Organic Layer Diet

In this example, about 80 percent of the methionine comes from organic raw materials and 20 percent is supplemented by conventional raw materials from the 5 percent non-organic fraction. The hen loses about 0.2 grams of methionine with the production of each egg, which must be replaced by its diet.  | Paul Poornan

Organic regulations in practice

“Illustration of organic layer diet” graphics shows a typical organic layer’s diet. In this example, organic wheat contains 12 percent protein and 0.17 percent methionine. If the diet comprises 36.2 percent wheat, then wheat contributes 4.34 percent protein and 0.06 percent methionine to the finished feed. All the organic raw materials are very low in methionine so that the organic fraction of the diet only contributes 0.26 percent methionine.

High-methionine-containing conventional raw materials, such as corn gluten 60 and potato protein, are used to contribute another 0.07 percent methionine so that the complete feed will contain 0.33 percent methionine. About 80 percent of the methionine comes from organic raw materials, and the remaining 20 percent must be supplemented by conventional raw materials, from the 5 percent non-organic fraction.

Most laying hens require a minimum of 0.35 percent methionine in the diet, and most conventional diets supply 0.4 percent, but in the Europe, it is a struggle to reach this level in organic diets. This low level (0.35 percent) of methionine is still sub-optimal, but the hen will survive and produce eggs. As well as needing methionine for normal bodily functions, the hen loses about 0.2 grams of methionine in each egg, which must be replaced every day by the diet.

Most organic diets for poultry contain a much higher protein level than is required by the bird to meet the minimum methionine level, and the excess protein is useless to the bird and must be deaminated and excreted, which uses valuable energy, stresses the liver and increases nitrogen excretion.

In some systems, the high levels of ammonia in the litter can damage the birds. The bottom line is that methionine as a raw material is essential to organic hens and the take-home message for any legally orientated readers is that that lysine and methionine are essential for pigs and poultry if 100 percent organic diets are to be achieved.

Thus, the law needs to be changed to allow the use of amino acids in organic monogastric diets, which will also have the added benefit of reducing the protein levels in organic diets, reducing greenhouse gas emissions and helping comply with the new EU legislation, which limits the nitrogen and phosphorus emissions in excreta and sets maximum ammonia levels.

Methionine troubles in organic diets

The table also shows that minerals are excluded from the organic percentage calculation; as all feed millers will understand, layer diets contain about 10 percent limestone to provide the calcium needed to make the egg shell.

The EU lawyers did not know this, so the labeling laws state that 90 percent of the dry matter of the diet must be organic before it can be labeled organic feed. As there is no organic limestone (because it is a mineral) in the EU, there are no organic layer diets, only diets suitable for feeding organic hens.

There is a danger that frustrated officials will impose 100 percent organic diets in January 2019, so that as nutritionists we will have to produce diets with seriously sub-optimal methionine levels. After conducting in-house (unpublished) trials on adult birds fed 100 percent organic diets, we found impaired production, reduced feather cover, aggressive and stressed birds, with high incidence of feather pecking and increased levels of mortality. Feeding organic pullets with nutritionally deficient diets will produce smaller birds, many of which fail to thrive due to underdeveloped organs. The only solution is for the EU to change the rules, but the lawyers are reluctant to do so.

If we were able to use methionine in the diet, then:

  • We would need less than 0.1 percent pure methionine in the feed
  • The bird would receive the correct amount of methionine
  • We would no longer be over-feeding protein
  • The nutritionally induced welfare issues would disappear
  • The birds would be fitter and healthier and more able to fight off disease
  • We would need to import significantly less proteins
  • We would not need the entire 5 percent non-organic fraction. About 2 to 3 percent of corn gluten 60 or grass meal would be needed for egg yolk color. If methionine and conventional egg yolk pigments were permitted, then the 5 percent non-organic fraction could be reduced to zero.

2019 outcomes

EU feed millers could face three choices in January 2019: produce 100 percent organic diets that seriously damage the welfare of the birds and the organic brand; find some way to circumvent the legislation (not advised); or decline to manufacture organic feed and endanger the livelihood of our organic livestock customers. Not a good outcome, with honorable feed millers probably opting to cease organic feed production as the least-worst choice.

Thus, the EU feed milling industry is endeavoring to educate the legislators with a view to changing the rules, and at the same time, still looking for the magic amino acid bullet in case we fail to do so.

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