Use of technical fats not permitted under the GMP+ Regulation
The use of fats with a technical destination as feed material is not permitted under the GMP+ Regulation. Technical fats are not included in the Feed Materials Risk Assessment Database.
Under German national legislation it is forbidden to export animal fats as feed material. These fats may, however, be exported if their destination is technical. The use of fats with a technical purpose as feed material is not permitted under the GMP+ Regulation.
Until 2005 there was a specific prohibition in the Dutch legislation against the use of fats of German origin as feed material. This mirror legislation was, however, rescinded in the EU’s efforts to minimise legislation and rules.
It is possible that fats which were exported from Germany with a technical destination will be offered as feed material in the Netherlands.
The use of these fats as feed material is however in contravention of the GMP+ regulation because technical fats are not included in the Feed Materials Risk Assessment Database.
In addition, the specific HACCP assessment which has to be carried out by the manufacturer under the GMP+ regulation is focused on use as feed fat. A risk assessment which is only aimed at a technical destination is not sufficient.
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