Advice on animal feed labelling, reformulating and traceability requirements during periods of crisis

(Updated April 2022)

Impact to feed supply

Disruption to feed supply chains as a result of periods of crisis have presented significant challenges for the agri-food sector in Scotland and across the UK, EU and internationally including a need to adapt to the challenges associated with shortages of some feed materials, essential feed additives and complementary and compound feedstuffs etc.

This may mean that, for a limited time, some businesses may find it difficult to fully comply with mandatory feed information requirements on product labels. In such circumstances, businesses should continue to work closely with the competent authorities on how best to comply with labelling, safety and traceability requirements.  Enforcement officers approach will be reasonable, proportionate, risk based and considered on case by case basis. However, it is the feed businesses responsibility to ensure that the feed it places on the market is safe and the feed labelling is accurate and does not mislead the user.

Enforcement officers should have regard to the Feed Law Code of Practice (Scotland) 2016 and the guidance issued by the Crown Office to reporting bodies where, in exceptional circumstances, a feed business is required to source alternative raw ingredients as a result of supply chain issues, which could subsequently affect the accuracy of any pre-printed labels.

Reformulation and labelling of animal feed

The current feed labelling and marketing rules are set out in the retained EU Regulation 767/2009 provide requirements for the marketing, labelling and composition of animal feed and ensure that all feed sold and used is safe and does not have an adverse effect on public health, animal health and welfare or the environment. Regulation 767/2009 also provides for a Catalogue of Feed Materials Regulation 2017/1017.

Only authorised feed additives and pre-mixtures can be used and these must be labelled and packaged according to requirements within the retained EU Regulation 1831/2003 and where appropriate specific conditions for use and handling are followed as set out in the Register of GB feed additives authorisations. Businesses manufacturing feed and premixtures containing specified feed additives will also require approval by Veterinary Medicines Directorate.

Where a business has to change their standard feed formulations alternatives may be used under the following criteria:

• The substituted ingredients are permitted for use in GB or NI.
• The substituted ingredients are used in accordance with any legislative criteria e.g. target species, maximum permitted limits, etc.
• Any reformulation must ensure the feed is safe for the intended species or category of animal.
• Accurate information for reformulated feeds to reflect the actual composition of the product, must be provided for the individual product unit(s). This may be achieved by correcting existing on pack information for example by the use of over-labelling.
• Where the reformulation invalidates any claims, the on-pack label must be amended, so as not to mislead the customer. Other advertising materials must also be amended accordingly.

In addition, prior to production and where appropriate the business may wish to notify the customer directly of any deviation from contracted standard formulations e.g. bulk deliveries to farm.

Animal feed products of non-animal origin made at different facilities

Feed business operators continue to have an obligation to provide the competent authority with up-to-date information on any establishments under their control. This includes notifying the competent authority of any significant change in activities and any closure of an existing establishment. Where a business re-locates its production to a different feed premises this takes effect as a new establishment and the following criteria must be followed:

• Feed establishments must be appropriately registered and/or approved with Food Standards Scotland under feed hygiene regulations, further information is available on the this website.
• For traceability purposes existing labels or packaging should be over-stickered with the relevant producer details.

Feed business operators must continue to maintain traceability requirements and follow the hygiene requirements and where applicable their Hazard Analysis and Critical Control Points (HACCP) system in accordance with the retained EU Regulation 183/2005.

Animal by products (ABP) used in animal feed are the responsibility of the Scottish Government and the Animal and Plant Health Agency (APHA). Any establishment producing or using including supplying, storing and transporting ABP will require approval with APHA. See the retained EU Regulation 1069/2009 and Regulation 142/2011 – in addition to any registration or approval requirement under feed hygiene legislation.