The European Feed Manufacturers' Federation (FEFAC) says that that the proposed zero-tolerance for intra-species recycling would make the use of non-ruminant PAPs practically impossible in the feed chain outside aquafeed production.

The European Commission presented its TSE Roadmap II proposals in July 2010, in which they concluded that the fight against the BSE disease has been successful thanks to the stringent public health measures taken at EU level, among which the total feed ban for the feeding of processed animal proteins to food producing animals introduced in 2001.

On the basis of this conclusion, the European Commission has tabled a draft proposal in 2011 foreseeing a lifting of the feed ban measure for the feeding of non-ruminant processed animal proteins to pigs, poultry and fish. In other words, the European Commission intends to reauthorise the feeding of:

1. poultry meal to pigs;
2. pigmeal to poultry;
3. pig and poultry meals to farmed fish under strict conditions.

The main control requirements linked to this proposal therefore are the single species dedication of the whole production chain from slaughterhouse to farm level and the “zero-tolerance“ requirement based on analytical controls using the official microscopic method and the new PCR test whose main role is to identify the species-specific animal proteins in feed. Ruminant and the feeding of processed animal proteins to ruminant animals remain banned.

FEFAC members are supporting the reauthorisation of non-ruminant as a valuable protein source, under practical conditions, based on the positive opinions of EFSA on the safety of and their positive contribution to improve sustainability of EU livestock production.

FEFAC members are requesting the setting of a practical tolerance for in non-target monogastric feeds, in order to allow the use of these products in monogastric feed mills, producing feed for poultry and pigs on the same production site.

FEFAC members therefore recommend implementing a step-wise approach by limiting the reauthorisation of non-ruminant processed animal proteins for use in fishfeed only, until the EU has validated a quantification method.

The EU fishfeed sector is the only sector whose production lines are fully dedicated. In line with the EU policy objectives for the sustainable development of EU Aquaculture, EU fishfeed producers could use non-ruminant processed animal proteins to replace fishmeal.