European Issues Deemed Complicated

By Tina Caparella


They do things differently in Europe…and it can get quite complicated.

So was the opinion of those attending and presenting at the European Fat Processors and Renderers Association (EFPRA) Congress in early June. Renderers from around the globe traveled to the Irish city of Dublin to hear how the industry is addressing the complex matters being faced.

Martin Alm, EFPRA’s technical director, opened the congress by insisting the European rendering industry have a code of practice. On that note, Peter Brattinga, European Feed Ingredients Safety Certification (EFISC), followed with a glimpse into the voluntary European code to good practice for the industrial manufacturing of safe food materials. He said feed and food safety is important but producers must be able to facilitate trade. For the past five to six years, EFISC has been developing a European Feed Ingredients Platform certification that utilizes third-party audits to demonstrate that companies are in compliance with the relevant European Union (EU) feed hygiene regulation. Three community guides have been developed by industry members, assessed by the European Commission (EC), recognized by the Global Feed Safety Initiative, and are available in all 27 EU languages.

EFISC is working hard on promoting the scheme to competent authorities, European and national sector organizations, the compound industry, and others downstream of the feed ingredient process. At the moment, 47 sites have registered for review and certification. Brattinga highlighted the following valuable points of EFISC:
• uniformed, harmonized feed material safety certification in the EU-27 countries;
• implementing EFISC code assures compliance with EU legislation;
• removal of trade barriers caused by different standards;
• appreciated by official control authorities; and
• increased transparency and customer confidence.

Coen Blomsma, FEDIOL – the federation representing the European vegetable oil and protein meal industry, reviewed one of the myriad of EU regulations, guides, and catalogues. Regulation (EC) No. 767/2009 amends a rule from 2003 and repeals various commission directives as they pertain to placing on the market and use of feed. A new voluntary feed materials catalogue was included in the regulation, and FEDIOL is suggesting the EU rename fatty acids in the regulation as a measure in the aftermath of the dioxin incident in Germany (see “Germany Finds Dioxin Contamination in Feed,” February 2011 Render). EFPRA was able to provide input prior to the finalization of the regulation, of which processed animal proteins only comprises nearly two pages out of 80 pages.

The carbon footprint of animal by-products was addressed by Hans Blonk, Blonk Environmental Consultants. The carbon footprint aims to systematically study the greenhouse gas impact of a system, product, or service. He provided the complex formulation being used that includes raw materials, transportation, product processing, and product uses. Based on studies presented, the carbon footprint of animal fats used as fuel is quite favorable, and protein meals used as fuel is comparable to wood pellets. In preliminary comparisons with vegetable oils as feed, animals fats and protein meals from category 3 material score better. Blonk’s conclusion: the carbon footprint of animal fats and proteins are often, in most cases, favorable to their vegetable alternatives.

The most anticipated speaker was Matjaz Klemencic, the EC’s directorate general for Health and Consumer Affairs, or DG Sanco, who spoke on the new animal by-products regulation (ABPR) approved last year that recently went into effect. Commission Regulation (EU) No. 142/2011 implements Regulation (EC) No. 1069/2009 of the European Parliament (EP) and of the council laying down health rules as regards to animal by-products not intended for human consumption. While Klemencic presented quite a bit of information, many questions still remain as the EC tries to sort out the details and find answers brought about by the new regulation.

Animal by-products categorization is similar to the previous ABPR regulation (No. 1774/2002) except blood of ruminants fit for human consumption following ante-mortem inspection now fall under category 3 as does adipose tissue of animals fit for human consumption following ante-mortem inspection. Klemencic advised renderers to pay particular attention to article 7 of Regulation No. 1069/2009 as it addresses this new categorization.

Article 19 of the new regulation spells out new disposal options, which allows burning or burial on-site in remote areas or in cases of natural disaster, outbreak of a notifiable disease, or widespread outbreak of a zoonotic disease.

The new regulation also spells out requirements for operators until the “end point,” a new concept introduced in this regulation. Among the obligations are traceability, registration or approval, and hazard analysis and critical control point-type checks. Operators are also required to mark certain derived products except in the case of immediate incineration or co-incineration and immediate use of alternative methods for category 1 and 2 materials.

Klemencic clarified that traders should also register for tracing purposes, even though they don’t take physical control of the material. He went on to explain that the key principals of the new regulation are to maintain the general principals of 1774/2002, clarification of the scope and responsibility, and the reduction of administrative burdens due to a more risk-based approach. Klemencic clarified that the new 250-page regulation combines 1774/2002 with eight other regulations and three EC decisions.

Business Matters
EFPRA took time to hold its business meeting where President Niels Nielson thanked the Federation of Irish Renderers for hosting the congress and reported that his first EU renderers meeting was in 1977 in Dublin, Ireland, so he has come “full circle.”

Alm then reported that he will continue discussions with DG Sanco on the animal by-products regulation over the next few months and that a stakeholders meeting on the dioxin issue in Germany was recently held. He said the EC is under pressure to do something and they will, perhaps insisting on random tests on fat at a cost of 500 euros per test. EFPRA has submitted the industry’s concerns and recommendations to the commission, such as fats from category 3 materials, which are deemed fit for human consumption, are already considered safe so should be exempt from testing.

“The outcome was very clear that they [EC] seemed to understand what we wanted,” Alm commented. EFPRA is also suggesting the monitoring only be done for a maximum of five years and is requesting copies of the testing reports to collect data. Alm believes a regulation on dioxin won’t come into effect until this fall.

On a positive note, the association recently received version two of the proposed regulation to lift the feed ban. To the pleasant surprise of EFPRA, the commission is recommending allowing porcine and poultry processed animal proteins be fed to the opposite species and to fish. The EC must now discuss the proposal with EU member states and issued the following timetable: a vote possible in the second half of 2011 followed by a three-month review by the EP, which is in favor of a relaxation of the feed ban. The commission sees perhaps a regulation going into force in mid-2012. Nielsen said member states are the key to getting the legislation passed so EFPRA members need to lobby their respective governments.

“This proposal is a very, very crucial role in our industry,” said Nielsen. “We will fight further on with this very important issue.” Some member states are concerned going forward with this proposal because of control issues, with some suggesting introducing proteins in fish feed only.

The Irish Way
Nielsen opened day two of the congress with the unveiling of EFPRA’s new logo and identity, “Driving food chain security and sustainability in Europe.” He also announced the processed animal proteins informational Web site at www.papinfo.eu is now live and an educational video has been posted on YouTube (search for “EFPRA – Big Fish”).

Tom Moran, secretary general of the Department of Agriculture, Fisheries, and Food in Ireland, began by noting that very seldom does a feed ingredient become a costly disposal problem overnight (Moran worked with renderers when the feed ban was first put in place in the EU).

He quickly switched gears and began discussing food production, which he said is going to have to increase by 70 percent by 2050 to feed the world’s population that will primarily live in cities. In Ireland, 29 percent of greenhouse gas emissions come from agriculture; the average in Europe is nine percent. The country’s agriculture sector produces about 150,000 jobs with an annual output of over 24 billion euros; exports account for eight billion euros. There are around 128,000 farms in Ireland, primarily family farms, with 60 percent of livestock produced in the country being beef and dairy. According to Moran, Ireland is the fourth largest beef exporter in the world, with 90 percent of the beef produced exported, primarily to the EU; 80 percent of dairy produced is exported worldwide.

Moran said food safety is absolutely key and regards bovine spongiform encephalopathy (BSE) as a historical issue with only single digit cases currently discovered annually in Europe. He added that the only way Ireland dealt with BSE was by being transparent. Irish beef was never banned from any market in the EU because of the country’s traceability.

“It was a horrific assault on a biosector,” Moran stated. “We need to be clear and transparent and deal with a problem head on.” The Irish government invested a lot of money in reassuring the public the country’s beef was safe.

Moran briefly highlighted Ireland’s Food Harvest 2020, an industry-driven strategy put under government control. The three structural challenges the industry has vowed to meet to ensure its sustainability are “smart, green, and growth.” Moran concluded by saying Ireland is open to debate regarding the reintroduction of processed animal proteins based on the context of sustainability.

Mairead McGuinness, Irish member of the 692 member EP and member of the EP Committee on Agriculture and Rural Development, reaffirmed Moran’s statement that currently, politically, food safety is a high priority, especially after the E. coli outbreak in Europe in May and early June that killed at least 31 people, mostly in Germany. She declared that food security issues shouldn’t be “nationalized” but should be a solidarity EU problem with EU solutions, and that the EU has stringent microbial rules in place for meat but the rules are not as strict for vegetables.

“We need scientifically backed information available to politicians so we can make informed decisions,” declared McGuinness, who is a member of the committee on reintroducing processed animal proteins in feed. One reason the EC is examining this possibility is Europe is too heavily reliant on protein imports. She insisted that the public needs to understand the logic behind processed animal proteins and advised the industry to begin the debate now with the public before it becomes a hot topic in the media.

“We have come a long way from the horrible dark days when BSE grabbed us,” McGuinness stated. “But it shows when people sit down and come up with a plan, no matter how costly, we can recover. People are eating beef again.” She also encouraged the industry to have discussions with parliament now while things are calm.

“Find champions amongst your own politicians and give them the necessary information so they can rally on your behalf,” McGuinness concluded.

Dr. Michael Scannell, director of the EC’s Food and Veterinary Office, discussed the experience gained by the organization on compliance with the animal by-products regulations in the EU. He said measures put in place after BSE were first and foremost for public safety, not for the sake of the industry. Scannell declared that those measures worked, restoring confidence albeit at a very high cost, then acknowledged that flaws and mistakes were made in the original animal by-products regulations (1774/2002), but that the government didn’t have the “luxury of time” and had to respond quickly and decisively. He pointed out that in the wake of that early regulation, the industry is now seeing better practices and processors and credits 1774/2002 for squeezing out the bad operators.

As for the future of the Food and Veterinary Office, which became operational in 2000 because of the BSE and dioxin issues, regulators will continue to look at compliance within organic fertilizer and examine new issues of concern such as gelatin and collagen and the raw materials used in this industry, particularly those materials imported.

Rounding out the array of presenters was Patrick Coelenbier, president of SIFCO, EFPRA’s French member association, who gave a statistical overview of Europe’s animal fats and proteins industry. Twenty-one countries reported in 2010, providing better data each year. There is a huge degree of uncertainty in the meat market due to the economic outlook; however, white meat consumption is on the rise with the EU becoming a net importer of poultry meat. Beef and veal meat consumption has been dropping since 2007 along with production, with sheep and goat meat production declining further. Overall, meat production is recovering, but exports are deteriorating, said Coelenbier.

There wasn’t much change in the total amount of animal by-products processed from 2009 to 2010, with 16.7 million metric tons processed in Europe last year. The top 10 producing countries were Germany, France, the United Kingdom, Spain, Italy, the Netherlands, Belgium, Ireland, Denmark, and Austria. Since 2000, the total tonnage of processed animal proteins has only increased 1.4 percent.

On the fats side, energy use dropped to 19 percent of total production in 2010 from 24 percent in 2009, but use in biodiesel grew from eight percent in 2009 to 15 percent in 2010, with 410,000 metric tons of animal fats going into biodiesel. Combined, energy accounted for 34 percent (2.2 million metric tons) of the animal fats and proteins (6.7 million metric tons) outlets in 19 EU countries in 2010, followed by pet food at 27 percent (1.8 million metric tons), fertilizers at 13 percent (898,000 metric tons), feed at 12 percent (792,000 metric tons), and the oleochemical and soap industries at nine percent (604,000 metric tons).

Not all Business
The Europeans mixed in plenty of socializing with the business meetings, including an Irish celebration one evening at the Old Jameson Distillery complete with Irish music and dancers. The last night of the meeting was reserved for a black tie gala dinner at the stately Royal Hospital Kilmainham, which was established and built between 1680 and 1684 as a retirement home for soldiers. Delegates who remained after the congress were also treated to a tour of the stunning Dublin coastline and famous Irish National Stud where one fetching stallion was worth an estimated 60 million euros.

EFPRA will hold its next congress June 6-9, 2012, in Dubrovnik, Croatia.


August 2011 RENDER | back