Feed additives - revision of EU rules

AnimalhealthEurope welcomes the opportunity to comment on this combined roadmap and inception impact assessment. In general we are in agreement with the document, particularly the intention to tackle the Non-authorised Feed Additives issue and the creation of new functional groups.

IMAA, the International Methionine Analogue Association welcomes the European Commission initiative for the revision of the Regulation 1831/2003 on the use of feed additives in animal nutrition. The feed additive industry innovates on new products, processes and applications of their products and needs the appropriate framework, to ensure these innovations are readily available for the feed chain.

Ajinomoto Animal Nutrition Europe (AANE) produces feed amino acid through fermentation process. AANE welcomes the Inception Impact Assessment on the revision of Regulation 1831/2003 and the opportunity to comment on it. The contribution of AANE to this consultation is provided in the attached document.

However, in combination with other functional components, feed additives have a very important role to play, in particular in terms of nutrient efficiency, minimisation of the environmental impact of feed use and reduction of antimicrobial treatment.

Filed in Hungarian · English published by the European Commission

Dibevo welcomes the opportunity to respond to this change. We can agree to simplify and streamline the system of registration and recognition, but would certainly like to highlight the problems faced by small markets; At this point in time, we note that the high costs of registering additives can hinder innovation in the sector.

Filed in Dutch · English published by the European Commission

The working group for active substances in animal nutrition (AWT e.V.) is the German industry association for producers, processors and traders of feed additives, premixtures and special feed additives. We would like to thank the European Commission for the opportunity to provide feedback on the EC Roadmap with initial impact assessment Ares (2020) 7546840 — on the revision of Regulation (EC) No 1831/2003 on feed…

Filed in German · English published by the European Commission

Based on extensive user experience of Regulation (EC) No 1831/2003 DSM Nutritional Products Ltd supports the initiative to modernise the legislative framework in order to address new developments and needs that have emerged over the past 20 years.

The Landwirtschaftskammer Nordrhein-Westfalen appreciates the opportunity to give feedback on the proposal on the Revision of the Feed Additives Regulation (EC) No 1831/2003 and likes to thank the European Commission for this opportunity. Some points of the proposal can lead to a more efficient use of feed additives and resources.

I am giving this feedback on behalf of Pen & Tec Consulting SLU, an SME based in Sapin, serving EU & international clients & supporting registration of feed additives, novel foods, food enzymes & food additives as well as biocides & natural crop enhancers.

FEDIAF, the European Pet Food Industry Federation, thanks to the European Commission for the opportunity to express our views on the EC Inception Impact Assessment - Ares(2020)7546840 – on the Revision of the Feed Additives Regulation (EC) No 1831/2003. FEDIAF full feedback as shared via position paper in the attachment.

MSD Animal Health welcomes this opportunity given by the Commission to provide feedback on the Roadmap for animal nutrition and the aim of modernising EU rules on feed additives. MSD AH would like to encourage the Commission to also pay attention to the benefits provided by other disease prevention tools such as vaccines, in particular for addressing diseases such as coccidiosis in poultry farms.

I am making this contribution on behalf of the Association of Veterinary Consultants (AVC), a not-for-profit organisation registered in France. The AVC are independent veterinarians, working in the areas of animal & human health/nutrition, & frequently involved in advising regulators, governments and the human/animal health industries.

Copa and Cogeca generally welcome the policy proposals and would like to comment on the following aspects: - We welcome the streamlining of the process to create new categories/functional groups that can reflect the new benefits of feed additives and provide suitable efficacy criteria. - If the definition of feed additives is reviewed, it should not be to the detriment of feed materials.

The European Feed Manufacturers’ Association (FEFAC) welcomes the possibility to comment on the Combined Evaluation Roadmap / Inception Impact Assessment for the revision of the feed additives regulation (EC) No 1831/2003.

Nevedi (the Dutch association of feed Industry) welcoming the initiative of the European Commission to revise the feed additives legislation. Animal nutrition in general but feed additives especially can be of great value in offering solutions for a number of challanges the livestock sector is faces with.

Filed in Dutch · English published by the European Commission

Nevedi (the Dutch association of feed Industry) welcomes the initiative of the European Commission to revise the feed additives legislation. Animal nutrition in general but feed additives especially can be of great value in offering solutions for a number of challanges the livestock sector is faces with.

The Dutch Dairy Association (Nederlandse Zuivel Organisatie, NZO) is an association of the Dutch dairy industry, representing the interests of thirteen dairy companies. They process milk into a wide range of dairy products: from beverages, infant formula and children’s food, cheese and desserts, to ingredients for the broader food industry and the pharmaceutical sector.

AFCA-CIAL is the French association representing the suppliers of additives and manufacturers of premixtures and complementary feedingstuffs for productive animals. AFCA-CIAL members are particularly concerned and involved in the application of Regulation 1831/2003.

Filed in French · English published by the European Commission

SERRPA welcomes the Inception Impact Assessment on the revision of Regulation 1831/2003 and the opportunity to comment on it. This document is obviously based on a throughout and well-structured reflection, resulting in a very good analysis of various strengths and weaknesses of the current legislation, and providing sensible policy orientations towards the necessary evolution of this framework.

The European dairy industry welcomes the Commission's effort to review the Feed Additives Regulation (Regulation (EC) No 1831/2003), with the aim of modernising the legislation to adapt it to the goals of sustainable farming and improve its effectiveness and efficiency without compromising health and food safety.

VDDN the Association of Animal Feed Specialities and Animal Health Products in the Netherlands appreciates the possibility of Feedback and wishes to share our views on the document “EC Inception impact assessment — Ares (2020) 7546840 — on the Revision of the Feed Additives Regulation (EC) No 1831/2003”.

Filed in Dutch · English published by the European Commission

New regulations probably needed about highly-nutritional Alternative Animal Feeds, mass-produced in a sealed, germless & 100% Sterile Tropical Environment, as for example the Fast-Growing (9,000 times in 2 weeks) BSF / Hermetia Illucens Larvae (43% Protein), reared on Shelves, in a fully-automated Vertical Multifloor Farm, and fed with Sterile & Superfast-Growing (1m/day, Everyday-Harvest) Bamboo Biomass, also grown…

Please find our comments in the attached position paper. As entrepreneurs who develop, produce and distribute highly specialized compound feed and feed for particular nutritional purposes we essentially rely on the availability of a broad portfolio of feed additives.

FEFANA, the EU Association of Specialty Feed Ingredients and their Mixtures, would like to share its views on the EC Inception impact assessment - Ares(2020)7546840 – on the Revision of the Feed Additives Regulation(EC) No 1831/2003. Please refer to the document in the Annex for the full FEFANA feedback.

SUMMARY More efficient use of resources will be key in the EUs Circular Economy Action Plan. Animal feed and feed additive have an important role to play and have great potential in being part of the transition to a circular economy. EasyMining fully supports strong safety requirements to prevent risks of pathogens and contaminations in animal feed and feed additives.

ESPP regrets that the proposed Roadmap does not address the obstacles posed to the Circular Economy by the animal feed and feed additives regulations. Reference is twice made in the proposed Roadmap to better or more efficient “use of resources”, but no reference is made to the EU Circular Economy Action Plan, nor in any way to the circular economy or recycling It is our understanding that any feed additive which is…

Our opinion is focused on suppling evidences over the suitability of certain food colourings because of the effects of these compounds on human health. For this reason, in the present opinion, the biological effects of six worldwide used food colorings (Riboflavin, Tartrazine, Carminic Acid, Erythrosine, Indigotine, and Brilliant Blue FCF) were analyzed.