Up-coming modernization of the EU Feed Additive Regulation to stimulate innovation for a more sustainable feed chain and to foster EU competitiveness in the global market
Secretary General of FEFANA
FEFANA is the EU association of manufacturers, traders and premixers of feed additives and other functional ingredients with currently 96 member companies across Europe. As the united voice of the industry, we work at EU level for the appropriate political and legal framework to ensure the safety of our products in the market and fair competition. Feed additives and other functional ingredients are key to optimizing animal feed formulations. They enable more efficient and sustainable animal production through reduced consumption of natural resources, less waste and emissions from animal husbandry, reduced use of antibiotics and high-quality products of animal origin. In addition, the products of our industry make a significant contribution to animal health and welfare of farm animals and pets.
FEFANA promotes the view that the legal requirements for feed additives and their mixtures in the European Union should be based on the following principles: promoting faster introduction of innovative products into the EU market, responding to future challenges in the feed chain and to societal developments, including those related to sustainable food production and here first and foremost reducing emissions from animal production and avoiding or limiting the need for antibiotic treatments, promoting fair competition in the EU market and competitiveness outside the EU, and, last but not least, reflecting a holistic approach and modern understanding of animal nutrition in the way feed additives are evaluated and approved prior to placing them on the EU market.
The modernization of Regulation (EC) No 1831/2003 on additives for use in animal nutrition had started with a fit-for-purpose evaluation which was completed in 2020. The report of this process was released only now, in February 2024, in the format of a Commission Staff Working Document Evaluation which is available from the European Commission DG SANTE public website.
The evaluation shows that the Regulation has generally functioned well, particularly with regard to ensuring a high level of protection of human health, animal health and the environment along the EU feed and food chain. At the same time, it is acknowledged that there are areas for improvement, notably related to encouraging innovation in feed additives to improve sustainability of livestock farming, including animal welfare, and to reduce administrative and regulatory burden of the authorization process. The findings of the evaluation report align with the statement in the EU Farm to Fork strategy and its connected action plan of 2020 related to the required revision of the EU feed additive regulation to reduce the environmental impact of livestock farming and to facilitate the placing on the market of sustainable and innovative feed additives.
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.
