FEFANA promotes a Code of Practice for Feed Additives and Premixtures Classification

FEFANA, the EU Feed Additives and Premixtures Association,has developed a user-friendly tool, in order to support feed business operators and the authorities in classifying feed products and mixtures according to the regulatory framework in the European Union. Based on very simple questions and a decision tree system, this tool allows the allocation to the proper regulatory classification status of any single component or feed mixture.

The tool will prove helpful for operators to ensure compliance of their products with regulatory frameworks. Undoubtedly it will also be used by the authorities to assure a consistent regulatory management of such products on the market.

Feed business operators are faced on a daily basis with questions related to the regulatory requirements of products they plan to or are placing on the market in the European Union. Depending on which category a product will be placed into, it will be subjected to very different regulatory requirements. “Is my product an additive or an ingredient?”, “Is my product a premixture or a complementary feedingstuff?”, “Is my product a premixture or an additive preparation?”, these are questions that frequently need to be answered in order to apply appropriate regulatory options. Although the current set of definitions in the European feed regulatory framework is clear and comprehensive, the interpretation borderlines between different categories are sometimes ambiguous and lead to uncertainties for both the operators and authorities.

The European Regulatory Framework defines five main groups of products:

- feed materials;

- compound feedingstuffs;

- premixtures;

- feed additives;

- veterinary medicinal products.

The regulatory requirements for each of these groups may differ substantially. As an example, if a product is classified as a feed material, it can be placed on the market without a prior assessment from the authorities. If the same product is classified as a feed additive, it would need to obtain a pre-marketing authorisation, leading to a delay of at least 2 years before it can be placed on the market.

Recent discussions in the EU Standing Committee on the Food Chain and Animal Health Section Animal Nutrition (e.g. status of chondroitin sulphate) and questions FEFANA receives from its members show that, in some instances, the feed business operators and the authorities are confused or inconsistent on the classification of certain products. Furthermore, diverging classifications amongst business operators may lead to unfair competition and potential crisis in the feed chain. At worst - and this has already happened - this can lead to the withdrawal from the market of a product through the Rapid Alert System, on the basis that its classification by the operator was not in line with the latest interpretation by a specific implementing authority. These uncertainties are detrimental to the sustainability of the EU industry and to the transparency and credibility of the EU legislative framework.

In order to get more clarity on the market place, FEFANA carried out an extensive review of the situation on the market and the different kinds of products that are currently available. Through inputs from its members and a close scrutiny of the reality of the market, this work came to the conclusion that the classification of all products (single products and mixtures) relevant to the overall feed business could be based on a limited series of simple questions; even the difficult