Only if the United States and Canada are able to obtain a geographical bovine spongiform encephalopathy (BSE) risk (GBR) classification of I or II under the EU’s new system do the two countries have any hope of reviving (or sustaining) tallow exports to the EU. Even then, the tallow will have to come from edible product production lines.
The key objective of the ABPR is to completely revamp veterinary legislation for animal by-products with the stated fundamental objec-tives being to ensure a high level of protection of public health throughout Europe. The EC has maintained that feed-borne food crisis such as BSE and dioxin all point to control deficiencies in the animal feed sector.
The new regulation builds on previous EU measures that required the exclusion of dead animals, speci-fied risk materials (SRMs), and other condemned materials from feed, and the pressure treatment of mammalian materials intended for use in feed. It also bans intra-species feeding of farmed animals. It classifies animal by-products into three categories based on their potential risk to animals, the public, or the environment, and sets out how each category must or may be disposed of.
Category 1 materials (i.e., animal by-products presenting highest risk, e.g., transmissible spongiform encephalopathies or scrapie; residues of prohibited substance, e.g., hormone used for growth promotion; or environmental contaminants, e.g., dioxins, PCBs) must be completely disposed of as waste by incineration or landfill after appropriate heat treatment.
Category 2 materials include animal by-products presenting a risk of contamination with other animal diseases, e.g., dead stock or animals killed in the context of disease control measures or where there is risk of residues of veterinary drugs. Products produced from these tissues may be recycled for uses other than food and feeds after appropriate treatment. Approved disposal includes biogas production, composting, and production of oleo-chemical products to be used in the technical industry.
Only Category 3 materials, tissues derived from healthy animals slaughtered for human consumption, may be used in the production of feeds following appropriate treatment in approved processing plants.
The ABPR requires reliable traceability and identification systems for marking certain materials intended for specific disposal options, like incineration of meat and bone meal, to avoid possible frauds or risk of diversion of unauthorized products into food and feed.
Meat and Bone Meal in Europe
The ABPR approval does not affect the current EU total ban on the feeding of animal protein meals to farmed animals, which is a separate issue and remains in force until at least June 2003. The EC wants to ensure that the meat and bone meal in storage (approximately 400,000/500,000 tons) at present, awaiting incineration, does not find its way into the feed chain. The EC is stating that they want tests to differentiate the different types of animal protein meals. However, the ABPR establishes clear safety rules for the production of meat and bone meal in case it is ever re-authorized for inclusion in feed for non-ruminant species. Concurrent with the feed ban has been a ban against the export of animal protein meals. The EU was once the world’s largest exporter, up to 700,000 tons per year.
Catering Waste and Yellow Greases
Feeding of catering waste has been credited by the EU with causing the epidemics of swine fever and foot and mouth disease. Similarly, the use of non-traceable cooking fats and oils is blamed for the dioxin feed contamination crisis in Belgium. Thus the ABPR has banned the use of catering waste in feed with up to a four-year derogation allowed for Germany and Austria. A yet to be approved derogation of two years for the United Kingdom and Ireland to use restaurant fats and oils under certain highly controlled conditions has still to be decided on.
Trade Implications
A) Trade With the EU
Tallow and Grease: The EU will not accept tallow unless it has been produced according to the regulations outlined above. In effect, this means that “packer type” tallow, if certified as coming from edible material, will be acceptable. There is a possibility that tallow produced from Category 2 raw material could be imported into the EU and used to produce technical fatty acids; however, it would be expected that there would be sufficient Category 2-derived tallow produced in Europe to satisfy the demand. Alternatively, the fatty acid manufacturers could decide to only use Category 3-derived tallow, as it gives them maximum flexibility in use of their finished products and poses no handling challenges.
The only possible export for yellow grease will be to Ireland and the United Kingdom if the two-year derogation is granted. Originally, the U.K. government was intending to apply for a four-year derogation, but there was a change of heart when the government was informed by the biodiesel equipment manufacturers that they could be organized within two years to utilize all of the restaurant grease produced in the United Kingdom for biodiesel.
Protein Meals: Raw material for pet food will have to be derived as per EU regulations and, similarly, any meals imported would have to be processed at pressure-cooking temperatures and conditions.
B) The Rest of the World
In general, to greater or lesser extent, other countries will be copying the EU regulations. For many countries, the replication will be because these countries will want to trade animal products to the EU, and to ensure they are acceptable, they will need to be produced under similar conditions. There is already a growing list of countries outside of those applying for EU membership that have said no to meat and bone meal imports, which include Japan, Lebanon, the Philippines, and Kenya.
GBR Classification
There has been no indication from the EC or its Scientific Steering Committee as to when North American countries are to be reclassified using the revised five-category BSE risk system. The system was initially produced by the EC and then fine-tuned by the Office International des Epizooties. The implications for trade are very severe, for if the United States and Canada were to be classified as a Category III country, then by definition, the two countries would have SRMs and thus need to be removed. Category I and II countries do not, by definition, have SRMs and therefore they would not need to be removed. In any case, tallow would need to be produced from tissues classified as being suitable for human consumption.
International Report - December 2002 Render