Setting and reviewing maximum levels for certain undesirable substances in feed

Als Vertreter eines kleinen Handelsunternehmen in Deutschland vertrete ich die Ansicht, das die von den EU-Mitgliedsstaaten vorgeschlagene Anpassung der THC Grenzwerte fuer Futtermittel aus EU Sorten von Nutzhanf / Industriehanf weder zielfuehrend sind noch gerechtfertigt. 1. Die regionale und nationale Futtermittelproduktion kann einen wesentlichen Beitrag auf dem Weg zur regenerativen Landwirtschaft leisten.

The trade association Cannabiswirtschaft e.V. and the useful hemp network represent the interests of the German hemp industry, German farmers and companies that cultivate and further process EU-certified industrial hemp.

Filed in German · English published by the European Commission

We have reviewed a recent opinion by the EU Commission regarding acceptable levels of Δ9-tetrahydrocannabinol (THC) in hemp feed and hemp-derived feed materials. The suggested limits are unnecessarily low. Is the objective here to create negative consequences for the European hemp industry, which has provided safe hemp products to the Community for the last 30 years?

We have reviewed a recent opinion by the EU Commission regarding acceptable levels of Δ9-tetrahydrocannabinol (THC) in hemp feed and hemp-derived feed materials. The suggested limits are unnecessarily low. Is the objective here to create negative consequences for the European hemp industry, which has provided safe hemp products to the Community for the last 30 years?

We have been an importer/producer of bird feed since 1960. Hemp seed has been an important part of many feed mixtures for decades, as renowned ornithologues confirm the importance of hemp seed for birds. If there is now a THC limit of 3 mg/kg for hemp seeds, we fear that farmers will no longer grow this article, they will risk having to destroy the product at the end.

Filed in German · English published by the European Commission

Dear sirs/madams, I am writing you on behalf of COCERAL, the European association representing the trade in cereals, oilseeds, rice, feedstuffs, olive oil, oils and fats and agrosupply. COCERAL welcomes the intention of the EU Commission to ensure a higher level of animal health protection, by reviewing the Annexes I and II to Directive 2002/32/EC of the European Parliament and of the Council as regards maximum…

The unnecessarily restrictive proposed limits for THC – 3 mg/kg for seeds and expellant, 7.5 mg/kg for hemp oil, flour and fibre, and 0.5 mg/kg for complete feed – are considered neither relevant nor scientifically justified by professionals, especially farmers, in our industry.

Filed in French · English published by the European Commission

European Fishmeal and Fish Oil Producers (EFFOP) represents European fishmeal and fish oil producers, an important processing industry key to fisheries, aquaculture, and agriculture. Our members produce high quality products with a low carbon footprint based on a sustainable supply of raw materials: fresh fish as well as by-products from the fish processing industry.

EUROMALT, the trade association representing the malting industry in the European Union, welcomes the intention of the EU Commission to ensure a higher level of animal health protection, by reviewing the Annexes I and II to Directive 2002/32/EC of the European Parliament and of the Council as regards maximum levels and action thresholds for arsenic, cadmium, lead, nickel, rye ergot, delta-9-tetrahydrocannabinol…

FEDIAF, the European Pet Food Association has noted with interest the proposed amendments to the Directive 2002/32 and associated annexes. We support the ongoing updates to this Directive as need and additional science develops to drive such changes. However, we urge those responsible for such updates to be led by a balance of informed risk assessment and emerging, peer reviewed science to direct updates.

The German Pet Food Industry Association (IVH) (www.ivh-online.de) represents the interests of the German pet food industry. We welcome amendments to the Directive that serve to protect animal health and - as far as possible - take account of the practical circumstances of pet food production, such as in particular the adjustment of the maximum lead content for wild materials for the production of pet food.

I am a farmer in Germany and have been growing winter hemp for several years as a catch crop and sell the stems to a company that produces elementary textile fibres. Over the years, through the management and experience I have learned about the environmental benefits of cultivation of farm hemp. I now plan to grow summer hemp on part of my land.

Filed in German · English published by the European Commission

Page 13 indicates a maximum content of p-phenetidine of 125 ppt in feed materials, feed additives, premixtures and compound feed. Considering that the motivation of including p-phenetidine in this directive is the presence of this substance in ethoxyquin; that this residue is not an environmental pollutant; and that ethoxyquin is not currently allowed for use as a feed additive in the European Union, we consider…

The introduction of the current draft law on maximum THC levels for hemp feed threatens to put an end to the Steadily growing market for hemp-containing feed in the EU, as compliance with good manufacturing practice and the application of the ALARA principle to achieve the limit values from the food sector in the feed sector are not possible for cost reasons.

Filed in German · English published by the European Commission

At our fishmeal factory in Cuxhaven, we produce oils and feeds from fish and shrimp by-products since over 100 years. With regard to the most recent draft (PLAN/2021/12796 ANNEX dated 5.1.2024) to modify Directive 2002/32/EC, the limit for dioxins (Sum PCDD/PCDF) has been lowered from 1,75 ng/kg to 1,5 ng/kg, the action threshold is reduced from 1,25 ng/kg to 1,00 ng/kg.

A downward revision of the maximum levels for dioxins/furans and dioxin-type PCBs in certain feed materials or components is appropriate taking into account the evidence provided. Furthermore, it should be noted that these new lower maximum levels are compatible with the performance of the current methodologies for the analysis of these compounds, in particular with the limits of quantification that can be achieved…

Filed in Spanish · English published by the European Commission

FEFAC representing European manufacturers of compound feed and premixtures for food producing animals welcomes in general the proposed amendments to the Annex of the EU Directive on undesirables substances, although with some reservations as regards the relevance and proportionality of the setting of maximum limits for p-phenetidine and the feasibility to reach the new limit proposed for rye ergot by 2026.

We are a company that since 1996 has been involved in the breeding, cultivation and further processing of EU-certified industrial hemp into a wide range of products. This includes in particular the production of food and feed derived from hemp. Please find below our comments on the maximum THC levels in feed proposed by the European Commission.

Filed in German · English published by the European Commission

Please find below our comments on the maximum THC levels in feed proposed by the European Commission. In general, we can follow the position paper submitted by the European Industrial Hemp Association (EIHA) and the opinion of Dr Bernhard Beitzke (Consultancy in Chemistry). In the following, however, we would also like to briefly address the most important arguments for us.

Filed in German · English published by the European Commission

The maximum levels for THC in feed proposed by EU Member States do not take into account the realities of the EU feed market, nor are they derived from recent scientific evidence on the carry-over rate of THC from feed to animal food, and they are certainly impracticable for the farmed hemp industry and the feed industry if they are as restrictively low as the maximum levels for hemp seed products in food.Analogous…

Filed in German · English published by the European Commission

We at FoodFarm Ltd have reviewed the recent draft bill proposed by the EU Commission regarding the THC level in hemp feed. While we appreciate and support the Commission's commitment to ensuring a high level of human health protection, we believe that the proposed limit values for Δ9-tetrahydrocannabinol (Δ9-THC) in hemp-derived feed materials are unnecessarily low and could have severe unintended negative…

We at Trans Farm Oy have reviewed the recent draft bill proposed by the EU Commission regarding the THC level in hemp feed. While we appreciate and support the Commission's commitment to ensuring a high level of human health protection, we believe that the proposed limit values for Δ9-tetrahydrocannabinol (Δ9-THC) in hemp-derived feed materials are unnecessarily low and could have severe unintended negative…

The proposed, unnecessarily strict limits for THC - 3 mg/kg for seeds and expeller, 7.5 mg/kg for hemp seed oil, flour, and fibre, and 0.5 mg/kg for complete feed - are deemed neither practical nor scientifically substantiated. The proposed introduction of identical maximum THC levels for animal feed and food is fundamentally flawed and inconsistent with existing regulations governing animal feed.

The new set limits of maximum content of rye ergots in compound feed with cereals and with rye is going to be in force in July 2026. It is too short time make new varietes with stronger resistence to rye ergot within 2026. On behalf of the industry we prefare a maximum limit in the mixed compound instead of the component in the feed mix. E.g. rye is newer used alone as feed.

The proposed, unnecessarily strict limits for THC - 3 mg/kg for seeds and expeller, 7.5 mg/kg for hemp seed oil, flour, and fibre, and 0.5 mg/kg for complete feed - are deemed neither practical nor scientifically substantiated. The proposed introduction of identical maximum THC levels for animal feed and food is fundamentally flawed and inconsistent with existing regulations governing animal feed.

Dear European Commission Officials, I, Aleksander Lacaj - Executive Director of the National Albanian Hemp Industry Association, officially support EIHA position on THC maximum levels in the feed material as below: The proposed, unnecessarily strict limits for THC - 3 mg/kg for seeds and expeller, 7.5 mg/kg for hemp seed oil, flour, and fibre, and 0.5 mg/kg for complete feed - are deemed neither practical nor…

If the same limits are applied to animal feed as are applied to human food, then this is a deadly decision for the hemp sector in Europe. The circular and green economy aims to use as many by-products as efficiently and sustainably as possible. But if by-products can no longer be used for animal feed, then hemp industries in Europe will no longer be competitive.

Enclosed is the EIHA's position paper on the proposed maximum levels of THC in feed. This document provides a comprehensive analysis and recommendations, emphasizing the need for scientifically-based and economically viable THC limits in animal feed. We believe these insights will contribute significantly to the ongoing discussions and decision-making process.