Delegated act to extend derogation for non-organic protein feed

As the Action Alliance Bioschweine Deutschland, we have been defending the interests of German and European organic pig farmers for many years. Together with other stakeholders, we believe that it is not possible to supply piglets up to 35 kg exclusively with organic feed without endangering animal health.

Filed in German · English published by the European Commission

The extension of the 5 % conventional percentages for young animals is necessary in order to feed the animals according to their needs. Most of these are potato protein and maize gluten components, which are residues from the food industry. There are some good approaches to alternative feed, many are not yet mature enough or disproportionately expensive.

Filed in German · English published by the European Commission

At the level of the College of Producers, its members are very much in favour of extending the derogation for 5 % of non-organic protein materials and extending it also to young poultry. The reasons are the lack of availability of these raw materials in Bio and the fact that synthetic amino acids cannot be used in Bio, which makes it difficult to balance poultry rations.

Filed in French · English published by the European Commission

EUROFAC, representing the French animal nutrition industry, supports the postponement of the current derogation for piglets and young poultry to 2036. EUROFAC agrees with the European Commission’s finding on the sufficiency of organic protein supply (methionine, lysine). This deficit concerns all poultry, including laying hens, and not only young animals.

Filed in French · English published by the European Commission

ODNV is a French cooperative comprising egg packing centres which pack and pack eggs from hens born and reared in France, including organic eggs collected from almost 200 breeders. The most recent European legislation, which came into force in 2022, has had a disproportionate negative impact on the production of organic laying hens and eggs due to a large number of constraints.

Filed in French · English published by the European Commission

Copa and Cogeca welcome the Commission's initiative to address the continuation of the authorisation for the use of a limited proportion of non-organic protein feed in organic pig and poultry production beyond 31 December 2026. The insufficient availability of suitable organic protein feed remains a significant challenge for organic livestock producers across the EU.

The Eggs section of the UGPVB, which represents egg producer organisations in the Grand Ouest of France, France’s largest production region, supports maintaining the possibility of using, under the conditions laid down in the draft delegated regulation, a limited proportion of non-organic protein raw materials in the labelling of organic poultry.

Filed in French · English published by the European Commission

BFA Contribution to the public consultation on the proposed Delegated Regulation providing for authorisation to use up to 5 % of non-organic protein feed in the nutrition of piglets and young poultry The Belgian Feed Association (BFA), understands that the proposal in the current draft of the Delegated Act of the European Commission supports an extension for ten years (until the 31st of December 2036) of the current…

Filed in French · English published by the European Commission

Requirement ® is an organic label in Sweden that is recognised by 99 % of Swedish consumers. We have developed rules and offered certification for organic production since 1985. In several areas, particularly in animal welfare, biodiversity, social responsibility and climate, rules go beyond the EU organic regulation.

Filed in Swedish · English published by the European Commission

I fully support this proposal to extend the use of 5 % non-organic protein until the end of 2036, which is responsible for the sale of eggs by the cooperative Le Gouessant. There are various reasons for this belief, Tension on the availability of organic MP. Defending the price to the consumer. Defending the producer’s remuneration with better technical performance.

Filed in French · English published by the European Commission

It is necessary to prolong the derogation allowing the use of up to 5 % non-organic protein feed for young monogastric animals, so that feed with the correct amino acid composition can continue to be produced to young organic pigs and poultry. If this possibility disappears within four months, much of the organic production of pigs, eggs and chickens is cut off.

Filed in Swedish · English published by the European Commission

Positionspapier zur Konsultation betreffend die Verwendung von nicht ökologischem Eiweißfutter in der biologischen Produktion Die Wirtschaftskammer Österreich unterstützt den Vorschlag der Europäischen Kommission, die derzeit in Anhang II, Teil II, Punkt 1.9.3.1(c) und Punkt 1.9.4.2(c), Verordnung (EU) 2018/848 vorgesehene Ausnahmeregelung für Ferkel und Junggeflügel um 10 Jahre bis zum 31.12.2036 zu verlängern.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ERPA is the European association representing rural poultry producers in Europe, including producers of organic eggs and organic poultry for meat. ERPA supports the European Commission's proposal to extend the derogation allowing up to 5% of non-organic protein feed for young poultry until 31 December 2026.

FEFAC representing the EU manufacturers of feed for food producing animals, including under organic farming conditions, notes that the measure at stake consists in postponing until 31 December 2036 the date of expiration of the current derogation under the same conditions as today, i.e. for young poultry and piglets.

Need to extend the 5 % derogation in organic piglet feeding: The possibility of using a limited proportion of up to 5 % of conventional protein feed in organic pig feeding needs to be extended beyond the current end of the derogation. As an organic farm with its own pig farm, we are directly affected by this rule and experience the associated challenges in pig feeding on a daily basis.

Filed in German · English published by the European Commission

I am strongly in favour of receiving this up to 5 % conventional feed when rearing organic piglets. The supply of amino acids from easily digestible feed components is a major challenge in organic pig farming. As the EU does not seem to be able to persuade itself to consider/enable a gap supply via crystalline amino acids in the same way as for vitamins.

Filed in German · English published by the European Commission

Ladies and gentlemen, I am a BIO pigmaster and have been renouncing the use of feed from conventional agriculture since 2015. The piglets I have been buying since then have also been fed 100 % feed from organic farming. It works! For a transitional period, I was able to accept the use of protein feed from conventive agriculture, but the transitional period has long since expired!

Filed in German · English published by the European Commission

Vereninging Biologische Varkenhouders, organisation for the Dutch organic pig farm, supports the proposed extension of this derogation to 5 % non-organic protein feed necessary for the growth and welfare of piglets and young poultry.

Filed in Dutch · English published by the European Commission

Please find enclosed our detailed opinion. The Commission is proposing a delegated act (ARES(2026)7580042) extending the derogation of 5 % of conventional protein for piglets and young poultry until 2036 due to the persistent lack of adequate quality organic protein feed.

Filed in German · English published by the European Commission

The VOLINEO group of poultry farmers brings together some 30 Bio laying hen farmers in western France. We support the proposed extension of the derogation allowing the use of 5 % non-organic protein feed for young poultry. We do not have enough organic protein feed rich in the necessary amino acids, without which we cannot raise our poultry properly and in good health.

Filed in French · English published by the European Commission

Synalaf represents in France producers and organised sectors producing organic poultry and eggs or Label Rouge (in poultry, Label Rouge is a method of lifting close to organic production). Synalaf thus accounts for approximately 95 % of French production of organic poultry for meat production and 75 % of French production of organic eggs, and therefore represents significant volumes of organic poultry and eggs…

Filed in French · English published by the European Commission

The Coopérative Agricole des Fermiers de Loué is very much in favour of the European Commission’s proposal to extend until 31 December 2036 the derogation allowing the use of 5 % non-organic protein feed for young organic poultry. This possibility remains necessary in view of the insufficient availability at European level of organic protein foods sufficiently rich in essential amino acids.

Filed in French · English published by the European Commission

The extension until 31/12/2026 of the derogation allowing the use of non-organic protein feed up to 5 % for young poultry is necessary because there is not enough BIO protein feed rich in amino acids in Europe. This decision is also beneficial from a technical point of view and for the health of the animal. It could be extended to all poultry.

Filed in French · English published by the European Commission

Accompanying the development of organic farming in southern France for 30 years, I support the proposal to postpone until 31/12/2036 the requirement for 100 % organic feed for young monogastric animals (pigs, poultry) because the lack of certain organic amino acids actually penalises their growth and increases the cost of production for the farmer, which is very difficult to pass on to the final market (consumers).

Filed in French · English published by the European Commission

It is a very good initiative of the Committee to propose the extension of this derogation of 5 % of non-organic protein feed. In a tense global context in terms of the availability of raw materials and where food autonomy will be the major challenge for Europe in the coming years, enabling organic production to remain competitive and attractive for both farmers and consumers is a good decision.

Filed in French · English published by the European Commission

Bionext, the representative organisation for the Dutch organic sector, supports the proposed extension of this derogation to use 5% non-organic protein feed necessary for the growth and welfare of piglets and young poultry.

AVEC, ELPHA and EPB strongly support the proposed extension until 31 December 2036. The continued structural shortage of suitable organic protein feed is well documented by Member States. Young poultry have specific requirements for essential amino acids during their early growth stages. Failure to meet these requirements can negatively affect animal health, development and welfare.

We support the renewal of the derogation allowing the use of up to 5% non-organic protein feed in organic animal production, as well as its extension to all poultry and pigs. From a nutritional and animal welfare perspective, it remains challenging to formulate fully balanced diets for poultry and pigs using only the organic feed materials currently available on the market, particularly with regard to the supply of…

We support the proposal to extend the derogation allowing the use of up to 5% non-organic protein feed for young monogastric animals. In our experience, an appropriate amino acid composition is particularly important for the health, welfare, and development of piglets and young Gallus gallus poultry. At present, the supply of suitable organic protein sources is insufficient to meet these nutritional requirements.

As an animal nutritionist specialising in organic farming, I fully support this proposal to extend the derogation of 5 % protein feed in the diet of monogastric animals until 2036. This extension is justified at many levels, first and foremost animal welfare, the balanced diet of an animal goes hand in hand with its welfare and its healthy development.

Filed in French · English published by the European Commission

Supply chain Italy, the association that supports and enhances the 100 % Italian agri-food chain, welcomes the European Commission’s initiative to gather views on authorisations for the use of non-organic protein feed in organic farming. See position paper in annex.

Filed in Italian · English published by the European Commission

Coldiretti, the largest farmers’ representative organisation in Italy and Europe, with 1.6 million members, welcomes the European Commission’s initiative to gather views on authorising the use of non-organic protein feed in organic farming. See position paper in annex.

Filed in Italian · English published by the European Commission

I think it's important to respond to this consultation to keep the 5% of non-organic protein feed for young monogastrics (pigs under 35 kg and poultry under 18 weeks) in order to: Ensure relevant growth and production. This 5% of non-organic feed helps balance rations with essential amino acids needed for animal growth, especially with today's genetics. Limit pollution.

The British Poultry Council supports an extension of the current 5% non-organic feed derogation until 2036 and thereafter until sufficient quantities of suitably assured organic protein feed materials are available year-round at a commercial scale. Failure to extend the derogation would have significant environmental, nutritional, welfare and financial implications for organic poultry production.