In response to uncertainties about the regulation, the EC has issued a document titled, “Question and Answers on Animal By-products,” which begins by defining animal by-products as “the parts of a slaughtered animal that are not directly consumed by humans, including dead on farm animals and catering waste (i.e., waste food originating from restaurants, catering facilities, and kitchens) that contains or has been in contact with meat products, whether cooked or uncooked. Some of these products are used in animal proteins like meat and bone meal, fats, gelatin, collagen, pet food, and other technical products, such as glue, leathers, soaps, fertilizers, etc. The alternative is their destruction, most often by incineration.”
Information in the question and answer document is presented, in part, below. For more information on the animal by-products regulation, log onto www.europa.eu.int/comm/food/food/biosafety/animalbyproducts/index_en.htm. The complete questions and answers document is posted at www.europa.eu.int/rapid/start/cgi/guesten.ksh?p_action.gettxt=gt&doc=MEMO/04/107|0|RAPID&lg=EN.
More than 10 million tons of meat not destined for direct human consumption derived from healthy animals are produced in the EU, which is then transformed into a variety of products used in human food, animal feed, cosmetic, pharmaceutical, and other technical uses. According to the document, the new regulation aims to integrate the animal by-products sector into the farm-to-table approach for food safety as set out in the White Paper on Food Safety adopted in January 2000 by introducing stringent conditions throughout the food and feed chains.
The regulation classifies animal by-products into three categories based on their potential risk to animals, the public, or to the environment, and sets out how each category must or may be disposed of.
Category 1 materials are animal by-products presenting the highest risk, such as transmissible spongiform encephalopathies or scrapie, residues of prohibited substance (e.g., hormone used for growth promotion), or environmental contaminants, such as dioxins or PCBs. In the EU, these materials 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., animals which die on farm or are killed in the context of disease control measures on farm or at risk of residues of veterinary drugs), and may be recycled for uses other than feeds after appropriate treatment (e.g., biogas, composting, oleochemical products, etc.).
Only Category 3 materials, by-products derived from healthy animals slaughtered for human consumption, may be used in the production of feeds following appropriate treatment in approved processing plants.
The regulation also requires reliable traceability and identification systems of marking for certain materials intended for specific disposal options to avoid possible frauds or risk of diversion of unauthorized products into food and feed.
The regulation extends the current ruminant intra-species recycling ban to other species. Porcine animal by-products cannot be fed to pigs and poultry animal by-products cannot be fed to poultry. However, derogation is provided for in the case of fish and fur animals subject to strict controls by the competent authority.
While the use of catering waste in feed for pigs and poultry is not the focus of the regulation, it is of concern to nearly all EU member states, which led to the states agreeing last year on a total ban on such feeding practices (“swill feeding to pigs, i.e., liquid feed”) in the revised Council Directive on Swine Fever. Because catering waste fed to pigs may contain porcine material, catering waste feeding will be inconsistent with the ban on intra-species recycling. It is also not possible to establish clear traceability for catering waste.
The adopted regulation is flexible, permitting a temporary relaxation of the ban on the use of Category 3 catering waste in feed. This relaxation will last for a period of not more than four years for Austria and Germany.
The regulation does not affect the current EU ban on the feeding of meat and bone meal to farmed animals, which is a separate issue and remains in force without any termination date. However, the regulation establishes clear safety rules for the production of meat and bone meal in case it is ever reauthorized for inclusion in feed for certain non-ruminant species.
In order to guarantee that animal by-products derived from animals unfit for human consumption do not enter the human food or animal feed chain, the following requirements have been introduced:
• Complete separation during collection, transport, storage, handling, and processing of animal waste not intended for animal feed or human food;
• Complete separation of plants dedicated to feed production from plants processing other animal waste destined to destruction;
• Stricter rules for traceability of animal by-products, including the control of movements of bovine spongiform encephalopathy (BSE) specified risk material by a record keeping system and accompanying documents or health certificates, and visual markers for animal proteins and fats intended for destruction.
In practice, food and feed products cannot be derived from BSE suspect animals, specified risk materials (SRMs), or animals slaughtered over 30 months of age not submitted to a BSE rapid test. All potentially infected material in these categories is destroyed in the EU, eliminating any prospect of it entering the food or feed chain.
The regulation introduces a set of controls, which are as strict as the controls established for the food industry. Furthermore, the use of markers for the identification of material unfit for human or animal consumption and the availability of new tests for the detection of prohibited ingredients in animal feed will provide practical instruments for an effective control.
The EC has prepared a series of transitional and permanent implementing measures in order to prepare for and facilitate a swift application of the regulation, including a derogation for the import of photographic gelatin produced from specified risk vertebrae materials from the United States and Japan intended for the production of photo films in France, the Netherlands, and the United Kingdom, and a derogation until October 31, 2005, for the continued import into the EU of certain products not meeting the requirements of the regulation concerning the total separation of Categories 1, 2, and 3 processing plants from Australia, Canada, China, and the United States.
Derogation has also been granted for the import, transit, trade, and export of Categories 1 and 2 risk materials (hides and skins, rendered fats, intestines, and bones) intended exclusively for technical/industrial uses. However, hides must come from animals that have anti-mortem and post-mortem inspection, which will have an impact on hides processed at rendering plants.
International Report - June 2004 Render