FEFAC: fighting to keep EU animal feed regulations in line

Between GMOs, dioxins and a feed ban of animal proteins, animal feed is still a hot spot for the European Commission and the European Parliament. For GMOs, what is at stake is to make the EU layman understand that the presence in imported feed materials (e.g. soybean meal or corn gluten feed) of GM products not yet authorized in the EU may be controlled and minimized but cannot be completely avoided.

Patrick Vanden Avenne, president of FEFAC, is hopeful for 2012 even though the European animal feed industry is facing many challenges.
Patrick Vanden Avenne, president of FEFAC, is hopeful for 2012 even though the European animal feed industry is facing many challenges.

Feed International: Genetically Modified Organisms, dioxins and a feed ban of animal proteins. Animal feed is still a hot spot for the European Commission and the European Parliament, isn’t it?

Patrick Vanden Avenne: GMOs, dioxins and the feed ban are indeed very topical these days, and all have in common one thing: how to properly handle risk communication.

For GMOs, what is at stake is to make the EU layman understand that the presence in imported feed materials (e.g. soybean meal or corn gluten feed) of GM products not yet authorized in the EU may be controlled and minimized but cannot be completely avoided. In the past four years there has been permanent and intensive mobilization of all EU and national feed and food chain partners as well as several periods of trade disruption because of this issue. Finally, in the spring of this year, the EU legislator acknowledged that there was a need to restore some common sense and pragmatism in the EU GM feed and food policy and to provide some legal security to operators. There must be a common understanding of what “zero” means in practice. We must pay tribute to [EU] Commissioner [John] Dalli for having proposed what we commonly call the “Technical Solution” (i.e. a 0.1% threshold for those products under evaluation by [the European Food Safety Authority] and with a method of analysis validated by [the European Commission's Joint Research Centre]).

FI: So you feel good with this decision?

PVA: Partly, as the glass is only half full. It must indeed be clear for everyone that the “Technical Solution” is not sustainable for the future. This solution indeed does work, but only in cases where products not approved in the EU are cultivated on very limited areas (e.g. for seed multiplication or on a very limited commercial scale). But the moment that a particular product is released for “full” commercial cultivation, then it can no longer work in practice. Such a scenario is not just theory: the non-EU authorized maize product Agrisure, cultivated in Brazil and the USA in 2010-2011, will likely prevent the EU from importing maize and/or maize co-products such as corn gluten feed or [Distiller's Dried Grains with Solubles] from the USA during the 2011-2012 cycle.

In addition, the technical solution applies to feed only, meaning that it will not be applicable to seeds imported into the EU for crushing. This could be a serious problem in the near future for the supply of soybean meal. In any case, considering the exponential pipeline of new GM traits scheduled for commercialization within the next 10 years, the technical solution is likely to become unsustainable in the very short term.

FI: If GMOs and dioxins are similar regarding the risk communication, the issue is really the same, isn’t it?

PVA: For dioxins, the issue for the legislator and operators is to explain to consumers and citizens that regularly we face, and will still be facing, contamination cases. However, the policy of reduction of dioxin occurrence, together with the new approach for feed and food safety involving [Hazard Analysis and Critical Control Points]-based risk management systems by operators, is delivering right. In fact, in the case of the German feed fats contamination at the end of last year, the problem was detected by a compound feed manufacturer as part of its auto control and the authorities were informed rapidly, and the contaminated goods were traced extremely rapidly. At the end of the day, with the exception of one farm, animal products were not excessively contaminated.

This could even have been a success story in the end, if again we would not have been facing a case where the root cause of the contamination was the negligence from a feed fats supplier and from the German control authorities. Now [the European Commission's Directorate General for Health and Consumers], DG SANCO, has proposed that Member States amend the existing EU legislation on feed hygiene with two key action points: an extension of the feed establishment approval procedure to oils and fats suppliers, and a mandatory monitoring program for dioxin in oils and fats based on a generic risk analysis of the different types of oils and fats.

[The European Feed Manufacturers' Federation], FEFAC, was among those calling for the first measure and we therefore welcome it. But the second measure is a pure heresy: DG SANCO’s proposal to require all operators to apply the same monitoring program goes against the principle of risk management and control designed by individual feed business operators based on their individual risk profile. This was a principle that was at the origin of the complete recasting of the EU general feed and food law in 2002. We really take this proposed measure as an undue collective sanction for failure of a single operator.

What will happen next? We are still hopeful that we can convince the EU Commission to step back, with the support of a number of national authorities, or at least make this monitoring plan more proportionate and limited in time.

FI: The potential return of processed animal proteins – that’s another hot spot with very different positions throughout the EU, isn’t it?

PVA: The lifting of the feed ban will certainly be a real challenge in terms of communication to the public. There is today more or less consensus between authorities, operators of the livestock chain and consumers that the time has come to consider the re-authorization of non-ruminant processed animal proteins in non-ruminant feed. A key argument often raised by people, including [Members of the European Parliament], is the soya savings that using PAPs would trigger. It is important at this stage to warn people, whether authorities, farmers or livestock chain partners, that they should not expect too much of such a lifting for several reasons:


  • because the amount of PAPs at stake is relatively low (a bit more than 1 million metric tons); 
  • because the conditions for re-use are expected to be so strict that only a limited number of feed companies specialized in production of feed for a single species may be able to use them; 
  • because there will be a resistance from the marketplace to the reuse of such animal proteins, especially in countries having been the most affected by the [Bovine spongiform encephalopathy] crises, i.e. UK, France or Germany. 

The only sector where we can see a potential for utilization of poultry and pig proteins is aquaculture. But, still, this will require a consensus along the chain, including retailers and consumers.

In practice, DG SANCO foresees a political agreement on the re-authorization of non-ruminant PAPs in non-ruminant feed in the first quarter of 2012. This would take effect in the second half of 2012. But of course, this is what is on paper at this stage. To be completely frank, our concern at FEFAC is that at the end of the day, as soon as their possible reuse in feed is decided in the EU, the non-ruminant PAPs will be exported outside the EU to feed Brazilian chicken that will come back to the EU. Prudence and vigilance are therefore the FEFAC motto on this issue.

FI: Regarding health, we hear a lot about medicated feed and a potential link with antibioresistance on animals and humans: is this file up on the Commission “to do” list?

PVA: The question of antimicrobial resistance has become a key priority for the EU authorities and really needs to be addressed seriously. The EU livestock industry is being singled out as favoring the development of antibioresistance due to the excessive use of antibiotics on farms. The EU livestock sector has fully acknowledged that the amount of antimicrobials used by food-producing animals can and should be dramatically reduced. The answer is prevention through better hygienic measures and a more targeted use of such substances, when essential, to preserve animal health and welfare. This is the key message that the EU Platform for Responsible Use of Medicines in Animals is delivering through its guidelines for prudent use of antimicrobials.

In the Netherlands, the issue has become highly political with the establishment by the Dutch authorities of a reduction target of 50% by 2013 compared to 2009. Other countries such as Denmark have also taken measures to encourage the reduction of the use of antibiotics on the farms. There is no doubt that the link between livestock and antimicrobial resistance will be a key topic of the November 2011 seminar in Brussels organized by the Polish Presidency of the EU together with the EU Commission.

In addition, the issue has taken on a new dimension. There is now a suspicion, prompted by a Dutch study, of the possible contribution to antimicrobial resistance by the carry-over of veterinary drugs from medicated into non-medicated feed. Although the protocol and the conclusions of this study are challenged by a number of people, it remains nevertheless a very hot issue.

We can expect a tough debate on this, especially since DG SANCO planned to completely recast the present EU legislation on medicated feed with a legal proposal. This will likely take place in the first half of 2012, which will undergo co-decision. From a FEFAC perspective, it is clear that manufacturing medicated feed is a service to farmers and, if the legislator considers that such a service should be maintained, it should give the feed industry the means to produce in a workable legislative framework.

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