Decision tree helps defining feed products
Fefana (the EU Feed Additives and Premixtures
Association) has developed a user-friendly tool for supporting feed business
operators and 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.
Such a 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
· "Is my product an additive or an
· "Is my product a premixture or a
· "Is my product a
premixture or an additive preparation?"
These are questions frequently need
to be answered to be able to apply appropriate regulatory
Matter of interpretation
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
The European Regulatory Framework defines five main groups
- feed materials;
- compound feedingstuffs;
- feed additives;
- veterinary medicinal products.
regulatory requirements for each of these groups may differ
For 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.
In a worst case a
misinterpretation of the classification can lead to a withdrawal of the product
from the market through the Rapid Alert System.
To aid operators Fefana has created a Code of Practice for the
classification of products and substances in accordance with the European
This Code of Practice enables any business operator
and Authority to classify the product they aim to place on the market in a
consistent manner and in a predictable way.
This then helps the business
operators to take the proper decision to ensure that their products comply with
the European regulatory framework.
The questions used in the decision
tree are a combination of substance-related and use aspects. The flexibility
embedded in the approach, which could look at first sight as creating
uncertainty, is in fact creating much more transparency and stability than
trying once and for ever to put a given substance in a definition
The Code of Practice is available upon request by sending an email
to Fefana at firstname.lastname@example.org
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