Use of feed additive in pet food

 By: Philippe Becquet, Member of the FEFANA2 Operational Team

In October 2003, the Regulation No 1831/2003 on additives in animal nutrition has been published. This Regulation will become applicable from the 18 th October 2004. in the meantime, feed additive manufacturers, traders and importers have to notify their products to the Commission and the European Food Safety Authority (EFSA). Based on this notification, feed additives will remain on the market for their current use, including use ip pet food. Notified feed additives will be re-evaluated by the Commission and the EFSA within the nest 7 years in order to enter for a ten-year period in a specific register. Furthermore, the European Parliament and the Council are currently discussing a regulation on Feed Hygiene proposed by the Commission, the Feed Hygiene regulation will implement new rules for the approval of establishments producing feed additives, as well as establishments using them.

Although the marketing of the petfood is in close relation with the food industry, the regulatory framework for these products is the one related to animal feed. The feed is defined in the regulation No 178/200 on the Food Law, as any substance or product intended to be used for oral feeding to animals, which includes all pet animals (e.g. dogs, cats, ornamental birds or fish….) therefore, all regulations recently published or under discussions regarding the feed encompass the pet food business.

Positive List of Feed Additives

Feed Additives in animal nutrition are regulated since 1970 based on Council Directive 70/524/EEC. In order to consolidate the different amendments and to better answer to the safety requirements for the consumers, as well as the need for fair trade in the European Union, the new regulation No 1831/2003 on feed additives introduces new rules for the evaluation and the authorization of feed additives, including the ones used in pet food. As the former Directive, the principle of the 'positive list' (now called register) or feed additives is maintained. This means that a feed additive can only be placed on the market for a certain animal category after its evaluation by the EFSA. The evaluation focuses on the product's identity, safety but also efficacy. The level of information to be given with the application's dossier depends on the animal category and on the type of additive used. For petfood, specific provisions are considered appropriate and will be set up in adapted guidelines. The Commission will establish these after consultation of the European Food Safety Authority (EFSA). A transition period is installed between the repeal of the current positive list and the final register, to be established after the re-evaluation of all feed additives within the nest seven years.

First placing on the Market

Regulation No 1831/2003 introduces a new very interesting definition. 'the first placing on the market'. This notion does not refer to the introduction date of an additive but on the status of the feed business in the food chain. The first companies in the chain who introduce the feed additive on the EU market are responsible for this product. It can be EU manufacturers; one or more of their distributors or the importers of a product manufactured outside the EU.

Notification

The notification of feed additives is part of  the transition period. In order to keep its feed additive on the EU market; each company first placing on the market shall notify this fact to the Commission and to EFSA. By notifying this fact, the feed additive business operator shows its responsibility on the product.

The notification is a rather easy documentation that aims to show interest from the company on a specific feed additives. Although the requirements are limited, it needs some consistency within the Industry and FEFANA, in connection with FEFAC, IMA EMFEMA and FEDIAF is elaborating a website, where any first placing on the market, whatever size and additives type can share the notification's work.

Approval of establishment

The current Council Directive 95/69 establishes a system of approval/registration of establishment producing feed additives. A proposal for a regulation on Feed Hygiene, which will replace the current Directive, is currently under discussion at the European Parliament and Council level. According to the last discussions, the new regulation will implement a system of approval for all establishments first placing on the market feed additives. This new approval system in connection with the re-evaluation of all feed additives, will become an excellent tool to ensure that all feed additive business operators will take their responsibility in marketing products, evaluated as being safe and manufactured in appropriate conditions to ensure safety along the chain.

(Footnotes)

1 DSM Nutritional Products Europe CH-4002 Basel

2 Federation Europeenne des Fabricants d'Adjuvants pour la Nutrition Animale (European Feed Additives Manufacturer Association), Avenue E.Van Nieuwenhuyse, 4 – b-1160 Brussels

PETS International Magazine ISSUE 4,2004