Editor’s note – The following is a speech, in part, given by Niels Leth Nielsen, Daka SARVAL A/S, at the European Fat Processors and Renderers Association 16th Annual Congress in early June in Messinia, Greece.
This year is not much different from previous years for European renderers although we are facing more challenges than in recent memory. Changes to regulation, mainly affecting specified risk material, has meant modifications to categories of raw materials and created huge market problems.
The European market is overloaded with category 3 mixed-species processed animal proteins (PAPs), which is harming category 2 products in the fertilizer market. The only outlet for mixed PAP in the European Union (EU), the pet food market, cannot absorb these extra quantities. The consequences are that prices for these products have dropped dramatically, stocks are being built up, and some renderers may have to incinerate these PAPs or category 2 meat and bone meal.
The easy way out of this problem is for the European Commission (EC) to lift the ban on export of ruminant PAP to third countries (outside the EU). The European Fat Processors and Renderers Association (EFPRA) has been very proactive this year trying to not only get this export ban lifted, but also to have better market access for European rendered products.
EFPRA staff held a meeting late last year with Ladislav Miko, deputy director general of the EC Health and Food Safety, known as DG Santé. A meeting was later held with Eric Thevenard, who is responsible for transmissible spongiform encephalopathy legislation at the EC.
In the meeting with Miko, EFPRA presented its main targets for 2016 as:
• the export of ruminant PAP;
• finalizing species test;
• feeding ruminant PAP to non-ruminant; and
• method 1 processing for ruminant PAP only.
The European rendering industry meets all the mega trends the world is facing for the time being: optimal use of resources, which is in line with the circular economy; highly sustainable, much better than soy, palm, and rapeseed; and a very low carbon footprint.
EU renderers agree with the argument that we must avoid another epidemic of bovine spongiform encephalopathy (BSE), but our systems are the safest and most secure around the world. BSE is a disease of the past yet at the end of the day, who is paying the ultimate price for poor market access of rendered products? It is the farmers in Europe, who currently have a very poor economy, no matter which kind of farmer, but mainly dairy and pig. So relaxation of the feed ban and the ban on PAP exports is crucial to improve not only the rendering economy but the economy of the whole agricultural chain.
There were 2,166 cases of BSE in the EU in 2001. Compare that to 7 in 2013 and 11 in 2014, of which 3 were feed-borne classical BSE. EFPRA must continue to fight hard to fulfill its main targets, especially opening up export markets for ruminant PAP. Ruminant PAP is already used in third countries, either from their own production or imported from the United States, Canada, Australia, New Zealand, or other non-EU countries. The EU also imports meat, fish, and shrimp from Southeast Asia that most likely have been fed with ruminant PAP. As animal proteins fed PAPs are already on our plates, the EC has to accept that third countries can control BSE themselves.
Regarding the lifting of the feed ban on non-ruminant PAP use within the EU – poultry PAP to pigs and porcine PAP to poultry – we are still waiting for PCR tests that must be available before the EC will propose to lift the ban. The problem is that the tests cannot distinguish between legal ruminant ingredients, such as milk, and ruminant PAP. EFPRA has claimed that this can easily be resolved by testing the ingredients – the PAP – and not the finished feed where more ingredients are mixed into the final diet. Yet the EC is reluctant.
EFPRA’s point of view is that EU legislation must follow World Organization for Animal Health, or OIE, rules. For example, OIE allows ruminant PAP to be used in non-ruminant feed, which is done all over the world except in the EU.
Again, I will claim that the EU has the safest and most controlled rendering system in the world. If EU legislators and member states postulate that the feed ban and other obstacles for the rendering industry are maintained in order to protect the EU population, this cannot be the case given that we import products that have been fed PAPs, which might not even be category 3 in the way EU classifies animal by-products.
This is a long and hard fight and EFPRA seeks allies to align with its members to put constant pressure on the commission. With great help from Italian colleagues, EFPRA has sought the assistance of a Brussels, Belgium-based law firm that has produced a legal opinion on the existing ban of exporting ruminant PAP. The legal opinion has been sent to European Commissioner for Health and Food Safety Vytenis Andriukaitis.
The legal opinion is very detailed in 15 pages, but the conclusion is very clear and states as follows:
“The export ban for PAPs derived from ruminants is, for the reasons outlined above, clearly disproportionate and discriminatory, as well as inconsistent with other measures previously adopted by the EU. Therefore, it is not only in contradiction with the proportionality and non-discrimination principles, but also with the precautionary principle. Moreover, it appears to be inconsistent since it disregards the international rules currently in force on this matter and the classification by risk categories adopted by the OIE.”
This is a very clear conclusion in my opinion. EFPRA has not yet received an answer from the commissioner but if it is negative, the group must consider whether to ask other parties involved to raise a court case against the EC. However, EU member states are the key. Even if the EC response is positive, and I think it will be, a lift of the ban must be supported by a majority of member states.
So, dear friends, you must all do your homework and approach the European government and authorities in charge about this issue and seek support from national stakeholders, such as farmer organizations. For the time being, we know that very few EU countries are 100 percent in favor of lifting the ban on export of ruminant PAP, which includes Denmark, Finland, and the Netherlands. More countries are not directly against it but want more information. Germany is strictly against lifting the ban.
EFPRA and the EC know there is a gray market out there but for sure this is not the way forward. European renderers must have opportunity to export their products in order to maintain the reliability of the industry.
August 2016 RENDER | back