Wouldn't it be handy to base the classification of all feed products (compund feed and feed additives) on a limited series of simple questions? Fefana agrees and therefore developed a simple electronic tool - ID Feed - for feed companies to find the regulatory definition of feed products. It is not a substitute for current legislation but a tool for better streamlining and transparency.
By Emmy Koeleman
On a daily basis, the feed industry is confronted with questions regarding the classification of the substances and products which are placed on the market by the operators. Regulation No 1831/2003 distinguishes different products and substances (such as feed additive, compound feeding stuff, veterinary product or mineral feeding
stuff). According to these definitions, the classification of a substance or product leads to different regulatory requirements, e.g. if a product is classified as a feed additive, it needs to be authorized after a pre-marketing evaluation, while if it is considered to be a feed material it can be sold without an authorization procedure. Furthermore, the labeling requirements are different. It is therefore an absolute necessity to support the operators and the authorities with clear criteria to define what a product is. A transparent, consistent and robust system needs to be provided to all the stakeholders in the feed chain.
Serie of simple questions
Although the current set of definitions in the European feed regulatory framework is clear and comprehensive,
the interpretation of different categories is sometimes ambiguous and can lead to uncertainties for operators as well as authorities. The European regulatory framework defines five main groups of products: feed materials, compound feedingstuffs, premixtures, feed additives and veterinary medicinal products. In order to get more clarity, Fefana (the EU Feed Additives and Premixtures Association) has carried out an extensive review of the situation on the market and the different kinds of products that are available.
Through inputs from its members and 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 distinction between premixtures and complementary feed can be managed through this tool. The selected set of questions takes the following aspects into account: the needs for simple wording and questions, the predictability of the choice (i.e. the same result is obtained by different operators for the same product) and the possibility to justify the choice made by the business operators in front of the control authorities.
Code of Practice for classification
On the basis of what has been done, Fefana has therefore created a Code of Practice for the classification of products and substances in accordance with the European regulatory framework. This document was discussed with authorities at European and Member State levels as well as with other Industry Associations, and their feedback was taken into account. The classification of a feed product is determined according to the nature of both the product and its use. For instance, a given substance can be classified as a feed additive or ingredient, depending on the way and the purpose for which it is used. The same apply to mixtures. The questions used are a combination of substancerelated and use aspects. The flexibility embedded in the approach creates much more transparency and stability, rather than trying once and for all to put a given substance in a particular box.
User friendly tool
The above mentioned review and discussions from Fefana has led to the development of a user-friendly tool in order to support feed business operators and authorities in classifying feed products and mixtures. Based on very simple questions, the web tool, called ID-feed, allows any single component or feed mixture to be allocated the proper regulatory classification status. Such a tool will prove helpful not only for operators to ensure compliance of their products with regulatory frameworks but hopefully also for the authorities to ensure a consistent regulatory management of such products on the market. ID-feed, the electronic tool recently developed on the basis of the Code of Practice should offer support to any business operator and authority for the classification of the product they aim to place on the market. This then aims at helping the business operators to take the proper decision and ensure that their products comply with the European regulatory framework. It is freely available for feed business operators and authorities via the Fefana website (www.fefana.org/ID-feed/Start.htm
Before using the tool, it is suggested to prepare or have a complete description of the product: composition, general manufacturing information, how it is used and for what purpose it is used.
The ID-feed tool is a help that does not substitute to regulations in force but is expected to bring streamlining and transparency. Several Member States are also taking initiative to translate ID-feed and make it available for national operators. More information on the translated versions will be released in due time.
Source: feed Tech magazine Volume 13. No. 2