European Protein Plan – Building in the Animal Nutrition Dimension

Untitled 2 - FEFAC ANNUAL REPORT 2017-2018*

In the development of a comprehensive European Protein Plan, the European is seen by DG AGRI as a crucial stakeholder as it represents the biggest user of protein in the EU. In the past year, FEFAC has highlighted the importance of including animal nutrition science as a key driver for the demand of high quality and digestible vegetable plant protein sources in order to increase the value potential of EU protein sources for the sector.

The European Protein Plan was announced by European Commissioner for Agriculture & Rural Development, Mr. Phil Hogan, at the XXVIII FEFAC Congress in Cordoba, Spain, in June 2017. FEFAC contributed to the DG AGRI public consultation held in March 2018 and was invited to provide industry experts for two out of the three expert workshops held so far. The European Commission expressed its gratitude to FEFAC for contributing to the ongoing drafting process at the 63rd FEFAC Public General Assembly in Lyon.

FEFAC has drawn attention to the concept of protein quality from an animal nutrition dimension, which determines the value and suitability of vegetable protein in feed. The amino acid profile of a protein source is a crucial parameter, as are digestibility, protein concentration, nutrient density and the need to reduce the presence of antinutrients. From a nutritional perspective, imported soybean meal remains a vital source of vegetable proteins, as it scores high on all protein quality parameters as well as competitiveness. From a feed material sourcing perspective there are, however, good opportunities to further boost the production of vegetable proteins in Europe, including oilseeds for biofuel production providing high-value protein meals, even though the EU will not be able to achieve self-sufficiency in the foreseeable future.

Animal nutrition science has a dynamic role in providing farm animals with essential amino acids. Improved efficiency rates have already allowed for more optimal use of available proteins, for example through improved processing techniques reducing nutrient leakage, reduced security margins as well as phase feeding linked to the age and growth cycle of the farm animals.

The increased use of synthetic amino acids has allowed to further increase efficiency of proteins, resulting in a substantial reduction of raw protein levels in compound feed for all animal species. FEFAC has called to be vigilant about potential tradeoffs on environmental impacts, for example phosphate emissions, when selecting different vegetable protein sources.

The outcome of the Commission market study in the context of the European Protein Plan will be presented at the high-level EU conference on 22-23 November 2018 in Vienna, Austria.

Renewable Energy Directive II –Guaranteed contribution of crop-based biofuels until 2030
In June 2018, a political compromise was reached on the Renewable Energy Directive II (2020-2030). For FEFAC, the outcome reflects an acceptable compromise, with some positive effects for the feed industry in the field of crop-based and advanced biofuels.

The contribution of crop-based biofuels to the renewable energy targets of the transport sector was one of the core issues during the political discussions and negotiations on the Renewable Energy Directive II. The protein concentrates that result from the crushing of oilseed crops such as rapeseed and sunflower for biodiesel and the distillation of cereals for bioethanol make an essential contribution to fulfil the protein requirements of the European livestock sector.

For FEFAC, the main achievement was reached when it became clear that none of the EU Institutions called for a complete phase-out of 1st generation biofuels. The final compromise of capping the contributions at Member State level of 2020 +1% will guarantee the sourcing of protein meals from crop-based biofuels until 2030. Within the context of the European Protein Plan, this contribution should be fully integrated into the long term strategy of the sustainable European protein supply, even if the main ambition of RED II is the greening of the EU energy policy.

The agreement equally reflects the potential competition between the production of advanced biofuels and the potential use of listed feedstock sources as feed materials. Any feedstock to be added to the list of advanced biofuels will have to pass a thorough assessment in which the policy makers will have to take into account the principles of the circular economy & the waste hierarchy, the sustainability criteria and the potential distortion of market for by-products. FEFAC, therefore, also welcomes the decision of the EU Institutions to delete molasses from the list of feedstocks that count towards renewable energy targets. Molasses is a highly valued energy-rich taste enhancer with pellet-binding qualities that increases the palatability and the homogeneity of feed. Molasses is also used to produce amino acids for animal nutrition as well as flavour-enhancing and protein balancing .

Feed Safety – Interaction between public and private controls
Cooperation between operators and control authorities is one of the main focus areas of the FEFAC Vision on Feed Safety Management. An overview report by the HfAA (the EU Health and Food Audits & Analysis Team) has identified the benefits and challenges of establishing closer interaction between the system of official feed controls and private assurance schemes.

The feed industry has for long invested in feed safety assurance and monitoring schemes to allow for an optimised management of the risks along the chain and to increase confidence among partners. The existing EU Official Controls Regulation (EC) No 882/2004 foresees that Member States should take into account the result of auto-controls performed by operators when designing their risk-based national control programmes. This will be further reinforced with the future EU Official Controls Regulation (EC) No 2017/625 that clearly points out that the implementation of third party certified safety assurance schemes is an additional element for consideration by authorities.

The feed sector was taken as a test case by the HfAA Directorate of DG SANTE to analyse the different types of auto-control systems and their integration in the design of official control plans. An HfAA Overview Report, published in December 2017, showed that in four EU Member States the competent authorities have already a well-developed system of interaction with the feed safety assurance schemes they consider robust enough. This interaction has resulted in a more targeted, risk-based approach to official controls for the affiliated feed business operators. Results from private plans have shown to help with the design of the official feed plan, while compliance records from private assurance schemes help with the risk profiling and prioritisation of official controls on feed business operators.

FEFAC welcomes that five more Member States have declared their intention to take concrete steps to establish such interaction. Currently, most Member States see the integration of private assurance schemes in their planning as challenging. There are often questions about to what extent they ensure compliance with legal EU requirements, whether audits carried out by private entities are comparable to official controls and whether the commercial aspects of private assurance schemes do not present a conflict of interest.

In a meeting with HfAA in January 2018, FEFAC expressed its interest to pursue its initiative in providing a general framework for discussions on emerging feed safety management challenges and best practice experience regarding interaction between public and private sector controls in a “peacetime setting”. FEFAC is willing to contribute in facilitating the independent evaluation of the performance of feed safety management systems via its project of developing a benchmarking tool in cooperation with the International Trade Centre to characterise the different feed safety management systems and tools developed in many EU countries.

Animal Nutrition – Revised maximum permitted levels for copper
In April 2018, the Standing Committee on Plants, Animals, Food and Feed (SCoPAFF) unanimously voted for the revised maximum permitted levels of copper in piglet feed, deviating from the EFSA opinion. FEFAC played a crucial role in convening a balanced political decision, taking into account the role of animal nutrition in farm animal health management as a leading argument.

Dietetic copper is an essential trace element in compound and adequate levels thereof in piglet feed will maintain good performance and can reduce the occurrence of post-weaning diarrhoea. In the light of reducing copper emissions into the environment, EFSA recommended lowering the maximum levels for copper in piglet feed to 25 mg/kg, but the political agreement allows for levels of 150 mg/kg up to four weeks after weaning and 100 mg/kg up to eight weeks after weaning.

FEFAC’s advocacy activities identified the clear risk for the health management of the pig farming sector in an early legislative stage and submitted its own impact assessment, in addition to the valuable study performed by Bikker et al. (2015) on reduced copper levels in piglet feed. FEFAC demonstrated to the authorities that lowering the copper levels in piglet feed in the most sensitive period of their life would have a critical impact on their health and performance, which would most likely lead to an increased need for treatment with antibiotics and run contrary to the ambition to reduce AMR. Given the modest amount of feed consumed by piglets, the environmental gains from reducing the maximum copper levels to 25 mg/kg would be marginal. At the same time, it must be noted that most of the copper released into the environment comes from agriculture, including organic farming.

FEFAC calls on competent authorities to extrapolate the balanced approach for copper inclusion rates in piglet feed to nutritional additives in general, acknowledging that their role goes beyond just meeting the levels required to avoid deficiencies, underlining the fact that animal nutrition science delivers more value to farm animals than just increasing performance and productivity.

Circular Economy – Feed manufacturing finally takes legal distance from waste management
The General Food Law from 2002 made clear that producing safe feed for food-producing animals needs to be seen as an integral part of producing safe food. With the most recent revision of the Waste Framework Directive, concluded in the 1st half of 2018, the legal separation between feed production and waste management has finally taken shape, thus improving the feed chain’s risk management capabilities.

“Substances that are destined for use as feed materials (…) and that do not consist of or contain animal by-products” are excluded from the scope of the revised Waste Framework Directive 2018/851 published in June 2018, thus closing an important loophole in EU food safety legislation, bearing in mind that animal by- products were already excluded. This grants a long-standing request from the European feed industry to avoid the unnecessary duplication of waste and feed legislation for materials destined for feed production, undermining the integrity of the feed chain and the functioning of the single market for feedstuffs. Particularly for former foodstuff processors, the legal clarification confirms that their business practice is not a form of (food) waste recycling, meaning that all relevant EU feed hygiene and safety management rules apply while environmental authorities can no longer challenge their feed-related activities based on interpretation of the by-products criteria from the Waste Framework Directive. At local level, this would also end unjustified legal requirements for compound feed manufacturers to acquire environmental permits in the light of their alleged handling of waste.
The revised Waste Framework Directive also unfolds the plans for food waste measurement in the EU for the coming years. Before March 2019, the European Commission will launch the official measurement methodology to be used by Member States to deliver their annual food waste numbers. The animal feed outlet is recognised as a means to prevent food waste as well as a contribution to the circular economy, meaning it should be recognised as “part of the solution” in national food waste prevention strategies. This was further confirmed by the publication of the Commission Guidelines for the feed use of food no longer intended for human consumption in April 2018, which aims to clarify and facilitate the transition of food into a feed material.

In November 2017, European Commissioner for Health & Food Safety, Mr. Vytenis Andriukaitis, visited a former foodstuff processing facility in the Netherlands, to experience firsthand what he considered “circular economy in action”. FEFAC explored, together with EFFPA (the European Former Foodstuff Processors Association), the possibilities with the DG SANTE representatives for a legislative framework that enables the safe sourcing from the food manufacturing and retail sector by former foodstuff processors.

Medicated Feed – Much needed recasting
finally agreed
In June 2018, the EU Institutions reached a political agreement on the Commission proposal for a Regulation on the production of Medicated Feed. FEFAC welcomes the result, which above all illustrates that the competent authorities acknowledge medicated feed as a safe and well-controlled route of administration of medicines to sick farm animals subject to veterinary prescription.

The agreement was reached shortly after the compromise on the proposal for a new Veterinary Medicinal Products Regulation, which was part of a package with the Medicated Feed proposal due to direct cross-references between both draft regulations, in particular as regards legal definitions and measures against AMR. The agreement sets risk-proportionate technical requirements for the manufacturing of medicated feed in multipurpose feed mills, which was a key concern for FEFAC. The restrictions on prophylactic and metaphylactic use with a view to bringing down the occurrence of AMR are consistent with the political decisions made in the context of the new Veterinary Medicinal Products Regulation. Carry-over limits of active medicinal substances into non-target feed will be defined by the European Commission one year after the EU Regulation becomes applicable, in consultation with EFSA.
During the political negotiations, FEFAC has always reminded that the production of medicated feed is a service provided by compound feed manufacturers to livestock farmers, based on the examination, diagnosis and prescription by the veterinarian. The EU Institutions have recognized that medicated feed is one of the safe and well-controlled channels of administrating a veterinary medicinal product to a sick farm animal, with its intrinsic advantages as regards dosage accuracy and product homogeneity. The administration at farm level of oral powders via “top dressing” (feed route) or drinking water will come under increased scrutiny subject to tailor-made guidelines for producers and users.

The Regulation on Medicated Feed replaces the Directive 90/167/EEC from 1990 which after 28 years resulted in different legal interpretations at national level, creating an uneven playing field. The harmonisation and clarification of requirements in the internal market are expected to increase legal certainty. It is important to highlight that providing safe and nutritional feed solutions to keep animals healthy is the core business of compound feed manufacturers, which also makes a significant contribution to help reduce the need for antibiotics at farm level in the treatment of sick animals.

*This document is compiled from the Annual Report 2017-2018 of FEFAC and is published upon the written permission of the institution given exclusively to Feed Planet magazine.

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