1. FEFAC FEFAC Feed safety action plan The FEFAC European Feed Manufacturers Guide (EFMC)

2. I.Introduction to FEFAC II.Establishment and review of the EFMC III.Future challenges 20-21 February 2008TAIEX workshop in Novi Sad (Serbia) 2

3. 3 FEFAC membership situation, 01 January 2009 Active membersObserver members Associated members Austria – VFÖBelgium - APFACA/BEMEFA Cyprus – CAFMCzech Republic – CMSO ZZN Denmark – DAKOFOFinland - FFI France – SNIAGermany – DVT Greece – SEVIZ Ireland – IGFA Italy – ASSALZOO Lithuania – LGPANetherlands – NEVEDI Poland – IZBAPortugal – IACA Slovakia – AFPWTCSlovenia – SFIA Spain – CESFACSweden – SvL/FFS United Kingdom – AIC Croatia Turkey Norway - FHL EMFEMA Switzerland – VSF First contacts with Estonia, Latvia, Malta, Romania, Bulgaria, Hungary - HGFA 20-21 February 2008

4. FEFAC committees Animal nutrition Chairman: K. Larsson (SLR) Vice-Chair: P. Radewahn (DVT) Industrial compound feed production Chairman: A. Sebastia (CESFAC) Vice-Chair: J. Piçarra (IACA) Milk replacers Chairman: G. Kleinhout (SNIA) Vice-Chair:H. Boeve (NEVEDI) Chairman: R. Sijtsma (NEVEDI) Vice-Chair: J.F. Labarre (SNIA) Fish feed Chairman: A. Allodi (ASSALZOO) Vice-Chair: K. T. Maeland (FHL) Premix and mineral feed EFMC Chairman: S. Ferrari (ASSALZOO) Vice-Chair: Y. Dejaegher (BEMEFA) 4

5. FEFAC secretariat staff members Alexander DÖRING – Secretary General Arnaud BOUXIN – Deputy Secretary General Julien TAÏEB – European Affairs Manager Françoise LIBER – Executive Secretary Susana CHAO – Administrative Secretary Roseline DEIANA – Receptionist Anne PETERS – Translator + Webmaster Annette WAXWEILER - Translator 20-21 February 2008TAIEX workshop in Novi Sad (Serbia) 5

6. The Role of FEFAC To support its Membership by: Lobbying Interpreting EU Policy Representing Memberships’ views Forecasting Communicating 20-21 February 2008

7. FEFAC mission is to: represent, defend and promote the interests of the European compound feed industry to the European Institutions; lobby for a legislative framework and its implementation, without discrimination in EU Member States so as to maximise market opportunities for EU compound feed companies; safeguard conditions of free access to raw materials, the proper functioning of their markets and the definition of their quality; develop professional rules and good manufacturing practices that ensure the quality and the safety of compound feed; encourage the development of animal productions responding to the market requirements, so as to maximise market opportunities for EU compound feed companies. 7

8. Role of FEFAC – long term lobbying and communication strategy Food & feed safety ObjectiveContinuous move to pro-active position through comprehensive and consistent communication strategy at European/national level with objective to promote the feed industry’s image in a positive manner to stakeholders ProblemThe prevailing negative image of the feed industry in public opinion and at the level of EU decision-makers means that the EU legislator may continue to impose stricter rules on industrial feed compared to food production FEFAC lobby approach Implementation and further upgrading of the EFMC guide for compound feed, premixes and medicated feed as key communication tool Promotion of new Feed Hygiene Regulation Maintain formal consultation status at EU level for any future feed safety related EU legislation initiative Ensure effective international representation via IFIF and contribution to int. organisations like Codex Alimentarius, FAO/WHO/WTO and OIE dealing with global harmonisation of feed safety standards ActionFastest possible adoption of core EFMC principles and distribution to feed ingredient suppliers; recognition by stakeholders 8

9. TAIEX workshop in Novi Sad (Serbia) The EFMC …. Is the first Community guide to good practice for the EU industrial compound feed and premixtures manufacturing sector for food-producing animals Meets the demands of EU Feed/Food legislation harmonisation (Jan. 2006, Feed Hygiene Reg. (EC) No 183/2005) Only covers safety related issues Help ensure safety of food through adherence to good Manufacturing practice during purchase, handling, storage, processing and distribution of feed for food producing animals 20-21 February 2008 9

10. 10 Development of the European Feed Manufacturers Code (EFMC) July 2005 – FEFAC expert group evaluation of EFMC with regard to possible accreditation January/October 2005 – National Benchmarking of Codes against EFMC and development of new national Codes on basis of EFMC November 2005 – Public launch event of EFMC with participation of European Commission (DG SANCO) April/May 2006 – Preliminary report from Standing Committee on the Food Chain and Animal Health January 2007 – EFMC positive assessment by Standing Committee March 2007 – Publication of the EFMC in the OJ C 64 (2007)

11. Country (association) Scope of national scheme * Accreditation possible Certification system available Governmental endorsement Austria (VFÖ)MYES Belgium (OVOCOM) PM, RM, M, T, FAYES Croatia (CFIA)M, PM Cyprus (CFA) Czech Republic (CSMO ZZN) PM, MYES Denmark (DAKOFO) MYes Finland (FFDIF)M France (SNIA/SYNCOPAC) MYES Germany (QS)M, T, RMYES Ireland (IGFA) – integration of UK’s code M, PM, RM, TYES NO Italy (ASSALZOO)M, PM, TNOMarch 2008YES * M = Feed manufacturing PM = Pre-mixtures RM = Raw materials T= Transport FA = Feed additives

12. Country (association) Scope of national scheme * Accreditation possible Certification system available Governmental endorsement Lithuania (LGPA) Luxembourg (OVOCOM) PM, M, TYES Netherlands (PDV) RM, PM, M, TYES Poland (IZBA Gospodarcza) M Portugal (IACA)PM, MYES Slovakia (AFPWTC) MYES Slovenia (GZS)MYES Spain (CESFAC)PM, MYES SwedenCode not requested at the moment ___ SwitzerlandM, PM, RM, TYES United Kingdom (AIC) M, PM, RM, TYES * M = Feed manufacturing PM = Pre-mixtures RM = Raw materials T= Transport FA = Feed additives 12

13. EU feed & food safety legislation Regulation (EC) No 178/2002 Horinzontal legislation Vertical legislation Regulation (EC) No 1829/2003 Regulation (EC) No 1831/2003 Regulation (EC) No 882/2004 Regulation (EC) No 183/2005 Regulation (EC) No 1830/2003 Directive 2002/32/EC Directive 2002/2/EC Veterinarian legislation Regulation (EC) No 999/2001 Regulation (EC) No 1774/2002 20-21 February 2008 TAIEX workshop in Novi Sad (Serbia) 13

14. Responsibilities of feed business operators Article 17 of GFL: « Food and feed business operators at all stage of production, processing and distribution within the businesses under their control, shall ensure that foods or feeds satisfy the requirements of food law which are relevant to their activities and shall verify that such requirements are met. » 20-21 February 2008TAIEX workshop in Novi Sad (Serbia) 14

15. TAIEX workshop in Novi Sad (Serbia) The EFMC … Covers all stages for manufacturing of premixtures, compound feedingstuffs and medicated feed from intake of feed ingredients to distribution of final products Provides practical information for benchmarking of Codes of Practice to facilitate mutual recognition of national Codes of Practice Ensures that coexistence of nationally developed Quality Assurance Systems does not lead to unjustified EU trade barriers 20-21 February 2008 15

16. TAIEX workshop in Novi Sad (Serbia) European Feed Manufacturers Guide Key points Building up an HACCP-based QA system all along the feed chain: –Scope –Full traceability –Recall procedure –Sourcing of feed materials –System certified by an independent body Making sure that all operators in the feed chain are under control (role of the legislator) Collaboration with downstream partners Collaboration with upstream partners 20-21 February 2008 16

17. 17 Outcome of the Standing Committee (SC) assessment of the EFMC Positive assessment of the EFMC on 29 January 2007 Minor corrections requested by the SC before publication already integrated in a revised version of the EFMC The section dedicated to medicated feed shall be reviewed and developed in collaboration with MS Publication of the EFMC in the OJ C 64 (2007) 20-21 February 2008TAIEX workshop in Novi Sad (Serbia)

18. Hygiene requirements for the manufacturing of medicated feed: 2 sets of legal provisions Feed Hygiene Regulation (EC) No 183/2005: –Regulation covering … –common feed safety/hygiene requirements, with … –voluntary … –European / national… –Guides to good practice Medicated Feed Directive 90/167/EC: –Directive covering … –medicated feed, with … –mandatory compliance with … –national … –Good Practice rules 20-21 February 2008 18 TAIEX workshop in Novi Sad (Serbia)

19. Principles of the new EFMC version regarding medicated feed Introduction: –Medicated feed is a feed (ref. to summary record of the Veterinary Pharmaceutical Committee – 20 March 2007) –National codes of practice take precedence over EFMC Core part of EFMC: –Withdrawal of all references to medicated feed from the previous version of the core part of EFMC New Annex 1: Sector note medicated feed –Development of a specific annex mirroring the structure of the EFMC and providing specific requirements for medicated feed 20-21 February 2008TAIEX workshop in Novi Sad (Serbia) 19

20. Sector note on medicated feed: key principles Based on existing national good practices for medicated feed In case provisions in national implementing rules are significantly divergent or the Directive leaves it to MS to derogate from basic rules, the wording of the Directive was used, e.g.: –Derogation for intermediate products, –Storage of medicated feed and premixtures, –Derogation for manufacturing before emission of a prescription, –Period of validity of the prescription (max 3 months), –Derogation for medicated feed produced from several medicated premixtures, –Rules for medicated feed for placing on the market of another MS, –Period of record keeping (at least three years), –Derogation for delivery via retailers, –Transport of medicated feed 20-21 February 2008 20 TAIEX workshop in Novi Sad (Serbia)

21. Key principles (1) Designation of a Medicated Feed Manager responsible for –control of orders of medicated premixtures –list of authorised medicated premixtures, –list of approved suppliers, –scheduling programme, –approval of reworks of internal returns –validation of the register Management of risk of carry-over –Control plan (criteria, record keeping, actions in case of non- conformity) –Avoiding manufacturing of “finisher” feed or feed for continuously producing animals after medicated feed –Cleaning procedures 20-21 February 2008TAIEX workshop in Novi Sad (Serbia) 21

22. Key principles (2) Reworks –Returns from farms not accepted –Internal return may be reworked after approval by Medicated Feed Manager Prescription –Delivery of medicated feed only if accompanied by prescription –Prescription valid for no more than 3 months 20-21 February 2008TAIEX workshop in Novi Sad (Serbia) 22

23. EFMC Committee Working programme for 2009 Leadership of the EFMC Committee -Establishment of a voluntary and non-exhaustive E U Catalogue of feed materials -International harmonization of feed safety rules -Developments of the EFMC on Standing Committee request -Monitoring of implementation of national codes of practices Co-leadership of the EFMC Committee -Microbiological criteria for feed -Dialogue with EFIP/IFSA and other feed chain partners Consultation of the EFMC Committee -Development of guidance document on claims -Harmonisation of national practices on manufacturing and marketing of nutritional supplements -Code of good labelling practices 20-21 February 2008 23 TAIEX workshop in Novi Sad (Serbia)

24. Further EFMC developments on Standing Committee request Practical examples of HACCP in feed production Reference to the responsibilities of feed business operators in terms of general requirements of food law Risk-based analysis of best practice to ensure effective tracing of products Other hazards, such as fertilisers and plant protection products 20-21 February 2008 24 TAIEX workshop in Novi Sad (Serbia)

25. FEFAC approach on the future EFMC developments (1) Practical examples of HACCP in feed production –Reviewed section A of EFMC and suggest producing a separate Guide to assist operators in applying a HACCP system Drafting already in progress for presentation subject to clarification of the points below –Suggest detailing principles and not examples –Danger that examples are used exclusively –Operators must apply the principles to every different application –Training is the key to successful HACCP 20-21 February 2008 25 TAIEX workshop in Novi Sad (Serbia)

26. FEFAC approach on the future EFMC developments (2) Responsibilities of feed business operators –Inclusion in the introduction of the Guide, of an explicit reference to the General Food Law guidance document and in particular on article 17 dedicated to the responsibilities of Feed Business Operators –Believe that a Code of Practice should not repeat the law (but require compliance to it) 20-21 February 2008 26 TAIEX workshop in Novi Sad (Serbia)

27. FEFAC approach on the future EFMC developments (3) Risk-based analysis of best practice to ensure effective tracing of products –EFMC already requires product traceability –HACCP deals with cross contamination –Internal traceability provisions in the EFMC should be further improved –Specific requirements will be added to each relevant chapter of EFMC 20-21 February 2008 27 TAIEX workshop in Novi Sad (Serbia)

28. FEFAC approach on the future EFMC developments (4) Other hazards, such as fertilisers and plant protection products –EFMC Requires Raw Material Approval Raw Material Supplier Evaluation Raw Material Checking at Intake HACCP –Together these requirements should address “other hazards” (pesticides mentioned in guidance for HACCP 20-21 February 2008 28 TAIEX workshop in Novi Sad (Serbia)

29. Co-regulation approach: draft regulation on the placing on the market and use of feed Establishment and review of a Community Catalogue of feed materials - First version of the Catalogue: part B of Annex to Directive 96/25/EC + Annex to Directive 82/471/EC - Internet register of notified emerging feed materials - Voluntary and non-exhaustive reference tool for operators Development of a Community Code of Good Labelling practices for food producing animals - Presentation of labelling particulars - Use of claims - Specific section on compound feed for fur animals 20-21 February 2008 29

30. FEFAC Thank you for your attention! www.fefac.org