Editor’s Note – The following is a speech, in part, given by N.C. Leth Nielsen, Daka Denmark A/S, at the European Fat Processors and Renderers Association 2013 Congress in June in Prague, Czech Republic.
In our industry, we never can relax. There is always some new legislation or rules in the pipeline that may have influence on the rendering industry and how we run our business. From time to time, the issues are extremely important as the outcome could determine whether renderers continue to be successful in business or not.
Martin Alm, technical director for the European Fat Processors and Renderers Association (EFPRA), recently looked over regulations relevant to EFPRA members and discovered more than 30 different pieces of legislation in the areas of food, food safety, animal by-products, transmissible spongiform encephalopathy, waste, feed, fertilizer, renewable energy, fuel quality, greenhouse gas emissions, industrial emissions, chemical substances, wastewater, transportation of dangerous goods, animal diseases, and the European Union’s (EU’s) Rapid Alert System for Food and Feed. This means that EFPRA, as an organization, and most of all its staff, secretary general, and technical director, must be alert all the time and react with due diligence, supported first of the presidency of EFPRA and, of course, its board and members.
One of the major issues is always the animal by-products regulation (ABPR), which is the European rendering industry’s “constitution,” if I may use that word. The ABPR is that piece of legislation that dictates how to collect animal by-products, how to treat them, and how the finished products can be used. It sounds quite simple, but as we all know, the ABPR is a comprehensive and very complex legislation very few people understand in detail.
The previous ABPR 1774/2002 had quite a few loopholes and missing points, which EFPRA staff and members thought would be resolved in the new ABPR 1069/2009. Much has improved in the new regulation, but there are still some issues that need to be clarified, which Alm, who is one of the few people who knows and understands the ABPR, is working on with the European Commission’s Health and Consumer Directorate-General, or DG SANCO, to resolve in a fair and constructive way.
I will not mention all the issues EFPRA is still discussing with DG SANCO, but here are a few.
There is still no clear definition of used cooking oil. In other words, should used cooking oil be regulated under the ABPR or the waste directive? EFPRA believes it should fall under the ABPR to ensure good control.
There is ongoing discussion regarding the importation of tallow from third countries to the EU for use in biodiesel production. These fats are, by definition, category 1 material in the EU and subsequently need to have been treated under method 1, pressure sterilization. DG SANCO intends to allow imports of tallow produced with method 7, but not meat and bone meal. EFPRA has told DG SANCO that the EU rendering industry fears this could cause hygienic problems thus it is important that DG SANCO ensure the rules for method 7 are actually fulfilled. Sometimes method 7 is believed to be an easy and soft production method, but it is not. It is actually quite difficult to pass the needed 30-day test.
During talks on imports of tallow produced using method 7, EFPRA asked the European Commission why EU renderers cannot get permission to export ruminant processed animal proteins (PAPs) for pet food to third countries. Ruminant PAPs are allowed in pet food inside the EU and finished pet food that includes ruminant PAPs is allowed to be exported to third countries. DG SANCO has asked EFPRA to examine if there is a market outside the EU for ruminant PAPs for pet food, which I am confident about, and this survey is ongoing at this time.
Another important issue is the revision of the Renewable Energy Directive. EFPRA was very pleased with the proposal from the commission that maintained double counting for biodiesel produced from category 1 and 2 animal fats as well as from used cooking oil. Yet many committees in the EU Parliament as well as some member states want to eliminate double counting and instead introduce a minimum target for advanced biofuels. On the positive side, most of the committee’s acknowledge that tallow methyl esters (TME) and used cooking oil-based biodiesel are advanced biofuels.
Double counting has been an excellent marketing tool for TME and today nearly 600,000 metric tons of tallow is sold for TME production in the EU. In fact, TME is more or less the only advanced biofuel sold on a commercial basis in Europe. EFPRA is not, in principle, against a minimum target of two to four percent (whichever it might be) for advanced biofuels as long as rendered fats and oils are included in the scheme. However, if this minimum target is not intended to be mandatory before 2020, EFPRA foresees that if double counting disappears as a marketing tool, there will be no market from 2014 to 2020. Who will buy a more expensive biofuel when not getting any benefits? EFPRA’s proposal is to maintain double counting for TME or at least maintain it until the sub-target for advanced biofuels is mandatory.
EFPRA has been very active in this matter, with letters to key members of the European Parliament, the European Commission, the Irish presidency, and the incoming presidency from Lithuania. Furthermore, EFPRA staff has had meetings with a few crucial Parliament members explaining the industry’s position. We will continue being very active in this extremely important area, but we foresee a long period before a revision of the Renewable Energy Directive is approved as there are rather big differences in the positions among member states.
On a different topic, beginning June 1, non-ruminant PAPs are again allowed to be used in aquaculture feed. Of course, it is too early to see the reaction in the market, but the European Feed Manufacturers’ Federation and Federation of European Aquaculture Producers are fully supportive of this allowance. However, as always, there is resistance from some retailers. EFPRA will continue to be active in this field with solid and honest information about rendered products as safe and very valuable ingredients in aquafeed.
Furthermore, we will work hard with the European Commission to have a further relaxation of the feed ban, which still is awaiting validation of the needed species test. As it looks now, and informed officially by the commission, we can foresee an opening for poultry/avian PAPs for pig feeds during 2014 and, more importantly, porcine PAPs for poultry feed in 2015.
The latest industry statistics shows a slight decrease in the total amount of animal by-products received by EFPRA members (see “European Raw Material Volume Declining” on page ??). This trend is more significant in some countries where the industry faces more competition from other areas, like the sale of animal by-products for human consumption (mainly in China), biogas and composting, and the mink industry sourcing animal by-products directly from slaughterhouses. This competition is a challenge for the rendering industry, but that’s what keeps us awake, or ought to keep us awake. We all must strive to be better in order to be more competitive.
Looking at other areas, EFPRA is a member of DG SANCO’s Advisory Board for Human, Animal, and Plant Health with one of the big issues being food waste. More than 87 million metric tons of food, about 35 to 40 percent, is wasted in the EU every year. EU officials are very concerned about how to minimize this huge amount of waste, or if not, how it can be recycled. Here, renderers can play a role and some already do. The challenge is to move the products up the pyramid, where landfill is at the bottom, then incineration, then energy such as biogas, and further up the pyramid to animal feed, reusing and adding value to the food waste. The rendering industry has the knowledge in most of these fields so we can take part in solving this huge challenge in an intelligent way.
August 2013 RENDER | back