The major provisions of the ABPR are: a categorization of raw material with only edible material being acceptable as a raw material where the resultant products are to be used in food, feed, fertilizer, and cosmetics; dead stock is excluded from the raw material base; and within the EU there is to be no species-to-species feeding of protein meals. Accompanying the above restrictions is the classification of manufacturing plants according to the raw material they handle with different categories being processed in separate plants.
The delay in implementation for third countries is to give the European Commission (EC) time to alter some of the health certificates, inform the World Trade Organization, and to allow for a further period of consultation with third countries. In practical terms, the delay means that North American renderers can continue to provide Europe with tallow for production of cosmetics, since Regulation No. 999/2001, pertaining to specified risk material (SRM) and geographical bovine spongiform encephalopathy (BSE) risk (GBR), states that its provisions do not apply to the use of rendered products in the manufacture of cosmetics as long as acceptable methods of manufacturing are used as laid down in previous cosmetic regulations.
New Opinion on Tallow Derivatives
At the last meeting of the EU Scientific Steering Committee (SSC), a revised opinion on tallow derivatives was presented that could have far reaching effects on countries that are categorized II on the GBR assessment.
The SSC was asked whether tallow derivatives manufactured from raw tallow sourced from cattle of a GBR II country would be safe if: the raw material was obtained from ruminants that were fit for human consumption (thus no dead stock); and it was processed according to the Cosmetics Directive.
The findings of the SSC were that they classified tallow as being in the lowest category with respect to BSE risk but did not classify it as non-infectious and that fallen stock must be removed from GBR I countries.
For GBR II countries, tallow derivatives would be safe if fallen stock is excluded, animals fit for human consumption were used, and the tallow was filtered to contain a maximum of 0.15 percent insoluble impurities. For GBR III and IV countries, in addition to the above, SRM’s should be removed.
If these findings are put into law by the EC, it would mean that the United States and Canada, with a GBR II classification, would not need to remove SRM’s from the raw material (under the ABPR each country would), but dead stock would have to be removed.
This constitutes a significant change in thinking within the EC and its scientific committees.
Peroxide Values in Egypt
In March 2003, the Egyptian Ministry of Agriculture tested a shipment of U.S. origin meat and bone meal (MBM) for peroxide values (PV) and found a range of PV up to 150 milli-equivalents per kilogram (meq/kg) of fat. As the Egyptian regulations specify that MBM shall be free of rancidity, the authorities considered that an appropriate test for rancidity would be the PV test.
However, as there is no accredited method for extraction of the fat from the MBM before the PV determination, such variables as type of solvent used and temperatures used in removing the solvent can all have an effect upon the PV obtained.
The Egyptian authorities were insisting that the PV should be zero; however, the PV specification for edible tallow is one meq/kg and for lard is four meq/kg, which suggested that the Egyptians did not fully understand the implications of PVand how to use it in a practical situation.
The National Renderers Association (NRA) prepared and submitted to the Egyptian authorities data from feeding trials that clearly demonstrated that when the PV of fat was as high as 180 meq/kg, there was no deleterious effect upon animal performance. Only when the PV has been at five meq/kg of total feed has a negative effect been shown. That value in finished feed is the equivalent of 800 meq/kg of fat in the MBM, a level far in excess of what could be obtained under normal conditions.
The final outcome on the acceptable levels has still to be worked out with the Egyptian authorities; however, NRA and member companies are working hard to provide the Egyptian authorities with information upon which they can make informed decisions.
Feathers in MBM Blends
Following the incident with peroxides in MBM, the Egyptian authorities examined a number of containers of 60 percent protein MBM and found the presence of feathers. To some in the trade this was not a surprise as the Egyptians had been purchasing 60 percent MBM from Europe for 20 years, knowing that to achieve such protein levels feather meal (FM) had to be added. Owing to the quirky nature of the Egyptian market, where a protein concentrate is sold to consumers to mix with grain at an inclusion level of 25 percent, 60 percent protein MBM was needed at the cheapest unit protein cost.
The Egyptian authorities on this occasion took the view that MBM does not contain FM and stopped the movement of the material from the port. The Egyptian feed industry has made representations to the Egyptian authorities and at the time of this writing, it appeared that the material already in the port and on the water would be allowed in with the proviso that the labels for the material be clearly marked that it is a blend and what is in the blend.
The Egyptian authorities have indicated that they will allow the import of FM to be used as a raw material. There appears to be some confusion over whether straight FM was previously allowed largely due to the misconception that FM has a very low digestibility. Commercial use of FM in U.S. broiler farms indicates that up to three percent FM can be included in broiler rations with a beneficial effect on the economics of broiler growth.
It would appear that in the future, Egypt will not allow MBM blends in with an elevated FM content. Clarification is still required of the allowable FM presence due to some feathers appearing in the finished product as a result of some whole birds being included at low levels in the raw material collected.
International Report - June 2003 Render