Without prejudging the outcome of the analysis on the final Commission draft proposal, FEFAC members consider that:

• The EU Commission should ensure market availability of agricultural raw materials for feed use for food production is not adversely compromised by EU biofuels policy development. In case of global market shortage, priority should be given to food and feed use. The mechanism to manage the market situation must be kept flexible, since supply problems can affect both energy and/or protein sources.
• Following the G-20 Farm Ministers recommendations, it is important to avoid any measure which could aggravate the present market access and supply situation for agricultural raw materials.
• For these reasons, a comprehensive economic impact assessment of the upcoming EU Commission proposal on the supply of agricultural raw materials and co-products should be carried out, under the leadership of DG AGRI, in order to encompass the full market expertise of key operators of the EU feed and food chain on agricultural markets
• As a general principle, the EU regulatory framework should provide operators with legal certainty and predictability.
• Feed is recognised as the most sustainable way to use by-products from the food chain. The EU biofuels legislation should therefore not promote any incentive which could divert these by-products into the use of advanced biofuels.

The Industrial Compound Feed Production Committee will meet on 30 October 2012 to assess in detail the Commission official proposal, which is expected to be published on 17 October 2012, and prepare a recommendation for an official feed industry position to the FEFAC Council meeting in November.