FEED & ADDITIVE MAGAZINE April 2024 5 The following items - not an exhaustive list - can be found in the Executive Summary of the evaluation report as topics for the up-coming revision of the feed additive regulation: simpler procedure for changes in the holder of an authorization, extending the duration of the authorization period, at least for certain types of additives, reform the system of non-holder specific authorizations, introduce modern alternatives to physical labels and harmonize rules, including for feed additives that are imported or exported, improve a number of provisions in terms of clarity and coherence, better coherence with other legislative provisions, such as the Regulation on classification, labelling and packaging of substances and mixtures (CLP Regulation). FEFANA and its feed chain partners had provided inputs on all of these items during the evaluation process as well as during the consultations, interviews and workshop of the following impact assessment that the European Commission had undertaken between 2020 and 2022 as a further step of the process. FEFANA has emphasized in particular that the current disproportionate time and resource intensive EU authorization procedure poses an obstacle for bringing innovative products to the market. Another particular problem that has come to light more prominently in the most recent past is the arbitrary limitation of EU authorization period of feed additives to 10 years. The renewal requirement is inconsistent with other areas of the EU food law and bears a risk related to continued EU market availability of some generic feed additives that are perfectly safe and that contribute to a safe and sustainable feed and food chain. The problem is linked to the fact that there is no protection of investment for those companies investing considerable resources in the authorization and/or renewal of non-holder (generic) feed additives. Another major issue that FEFANA has pointed out for several years is related to current product labelling requirements which are not aligned with today’s possibilities of modern communication tools and the EU Commission’s own high-level objective of digitalization. FEFANA calls also for the inclusion of adequate provisions in the regulation with regard to the use of certain feed additives in water for drinking and to resolve the current non-harmonized approach with regard to the production and movement of safe feed additives for export to third countries, where the authorization conditions differ from EU (use levels, animal species, registration status). FEFANA is working together with its EU feed chain partners, the EU institutions and EU Member States to outline solutions and to advocate for a future modernized regulation to further unlock the potential of feed additives to improve the sustainability of feed, pet food and food production while fostering EU competitiveness in the global market.
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