Written by Anna Hardcastle, Nutritionist.
Animal feed is governed by EU legislation which specifies requirements on hygiene during production, and then requirements on marketing, use and labelling of different feeds and ingredients including genetically modified feeds. Other legislation lists maximum limits for coccidiostats, pesticides, mycotoxins, heavy metals and dioxins. Over the next 4 weeks I will be designing a new compound feed for broiler chickens and I’ll address a series of commonly asked questions to ensure the product is legally compliant:
Am I actually allowed to design, market and make this feed?
A very important question! Under Regulation 183/2005 laying down requirements for feed hygiene, articles 9 and 10 state that feed businesses must be either approved or registered with the appropriate competent authority. The categories for approval over registration are then listed in Annex IV and include manufacture and / or placing on the market nutritional additives e.g. vitamins, trace elements, amino acids, urea; zootechnical additives e.g. some coccidiostats; colourants, premixes containing vitamins A and D. Categories for registration include manufacture and / or placing on the market other additives not mentioned in Annex IV e.g. emulsifiers and anti-caking agents, complete and complementary feeding stuffs, feed materials, and storage and transport of feed and feed products. Article 19 states that establishments approved by the competent authority are recorded on a national list with a individual identifying number. In my factory, I must also comply with the requirements of Annex II of this regulation which covers good manufacturing practice – procedures and records for hygiene, pest control, training, calibration, maintenance, production, avoiding cross-contamination, water, waste, quality control and traceability. I must have all of these things in place before I even start to think about making my product.
Another thing to consider is that I want to use Narasin, a coccidiostat or specified feed additive (SFA), in my feed. SFAs fall under the Veterinary Medicine Regulations 2013. Guidance published on the gov.uk webite Manufacturing and supplying veterinary medicines for animal feed 01/07/2015 and schedule 5 of the regulations tells me that I am a category 5 site and my activity description is an establishment approved to manufacture feedingstuffs using premixtures containing SFAs when the feedingstuff are to be placed on the market. I need to request approval from the Veterinary Medicines Directorate (VMD) for this manufacturing these products. There is an exemption from this approval for distributors (not manufacturing the product themselves) who store or supply complete feedingstuffs containing SFAs.
Answer: As this is a complete compound feeding stuff, I need to be registered under category R4 with my competent authority for manufacture of compound feeds (but as this is not approval I might not receive a number from my competent authority). I must also be approved for category 5 with the Veterinary Medicines Directorate for manufacture of feedingstuffs containing SFAs which will be placed on the market.
