Livestock feed controls review: consultation

Detail on proposed policy changes

Policy Aims

• Ensure feed controls in GB are proportionate to current TSE risk and are in line with the latest scientific evidence and advice.
• Support industry and ensure our regulations allow and encourage investment in livestock industries
• Support industry to achieve Scottish Government sustainability goals.

Benefits of the proposed changes

Environmental benefits

The use of animal proteins in non-ruminant feed has potential environmental benefits, through a reduced dependency on soybean-based feed. Approximately 76% of global soy production goes towards livestock feed, mostly for pigs and poultry^[17]. In 2022, the UK imported 3.46 million tonnes of soybean equivalents, with 90% either used as animal feed or embedded within imported meat, eggs, or dairy products^[18]. The soybean industry is a significant contributor to deforestation and greenhouse gas emissions, with over 75.5 million hectares cultivated globally^[19] and only 24% UK’s soya used in animal feed in 2022 was farmed in a way that did not contribute to deforestation or the conversion of natural ecosystems^[20].

Defra is conducting research and development, including life cycle analysis, on the potential environmental benefits of using insect protein in animal feed in comparison to soymeal and fishmeal. As farmed animals, insects are prohibited from being fed manure, catering waste, and feed material containing or derived from catering waste. We are aware of innovation in the insect protein sector identifying novel insect substrates that are currently underutilised. These innovations, in the medium-term, could contribute to a more sustainable global supply chain, and reduce the reliance on soybean-based feed.

Economic benefits

These proposed changes would level the playing field with the EU, providing a platform that will encourage investment into the insect protein sector in GB. There is a potential benefit to the insect PAP sector, which would be able to sell their product to a GB market through the use of insect PAP in pig and poultry feed. Elsewhere in the World, insects are becoming increasingly popular in animal feed, with insect meals containing between 50-82% crude protein as well as other important nutrients^[21]. The global market for insect protein was worth approximately $540 million in 2022 and has been forecast to hit $1.4 billion by 2029, with Europe making up around a fifth of the market^[22]. Allowing the use of insect PAP in non-ruminant feed could enable the growth of this market in the GB. We have already seen some evidence of this, for example, in 2017 the EU and UK permitted the use of processed protein from seven species of insect to be used as feeds in fish farms, including black soldier flies and species of mealworms and crickets^[23]. Black soldier flies (and to a lesser extent yellow mealworms) are now being farmed in various locations in the UK. Estimates from the World Wildlife Fund for Nature suggest that demand for insect protein in the UK could be over 500,000 tons by 2050, with half supplied within the country^[24].

There are potential benefits to industry, including animal by-product (ABP) processing plants manufacturing porcine or poultry PAP, as they would also be able to sell to a GB market for use in the production of pig and poultry feed. Data from discussions held with industry suggests that most of the porcine and poultry PAP currently produced is exported for use in pet food, with a small amount used by the UK pet food industry. Porcine ABPs are often mixed with ruminant ABPs, and the mixed PAP products have less value than porcine PAP. Enabling the use of porcine and poultry PAPs in non-ruminant feed could therefore expand the feed market by diversifying product ranges and keeping markets competitive.

Cross contamination monitoring and prevention

It is essential to ensure that, should these changes be adopted, TSE risk is not increased. Scotland is currently recognised by WOAH as having BSE Controlled Risk status. Cross contamination (CC) in the feed chain must be avoided because it could result in illegal feeding. CC would include poultry or porcine protein being fed to the species of origin.

The Scottish Government has worked with Defra, the Welsh Government, industry, FSA, Food Standards Scotland (FSS), and APHA to develop a proposed course of action that will monitor and prevent cross contamination across the feed chain. The proposed changes are not designed to be detrimental to current practices, which will be allowed to continue unaffected. The proposed additional feed options would be available alongside current options. We are seeking views on the proposed additional options in this consultation.

Should these changes be agreed upon, APHA would issue a guidance note explaining the legislative requirements to prevent CC in the feed and food chain. It would build upon the current guidance note^[25], published in 2018 and would be developed with government input.

Unless otherwise specified, current feed hygiene regulations to prevent CC from C&G will apply to each of the below sections.

Slaughterhouses / Cutting Plants

Animal by-products (ABPs) intended to be used to produce poultry PAP must be sourced from slaughterhouses or cutting plants that are registered by FSS as not slaughtering or processing ruminant or pig animals. ABPs intended to be used to produce pig PAP must be sourced from slaughterhouses or cutting plants that are registered by FSS as not slaughtering or processing ruminant or poultry animals.

The only exceptions to this are if FSS, upon inspection, is satisfied that:

• When porcine PAP is produced, slaughter of pigs is carried out in physically separate lines from ruminants and poultry
• When poultry PAP is produced, slaughter of poultry is carried out in physically separate lines from ruminants and pigs
• Collection, storage, transport, and packaging facilities for poultry products are separate from those used for ruminant and pig products.
• Collection, storage, transport, and packaging facilities for pig products are separate from those used for ruminant and poultry products.
• Regular sampling and analysis are undertaken, to ensure no CC.

Rendering plants / Feed ingredient manufacturers / Compound feed plants

Products containing poultry / pig / insect PAP / C&G for feed must be produced in processing plants registered by APHA as exclusively processing products for livestock that can eat that material safely.

The only exception to this is if APHA is satisfied that:

• There is a closed system of production and physical separation of products intended for livestock with different feed requirements (e.g. pig feed containing poultry PAP is kept separate from products intended for ruminant and poultry feed).
• Collection, storage, transport, and packaging facilities for raw and finished material containing poultry / pig / insect PAP / C&G are physically separate from facilities handling materials of other animal origin (i.e. the layout and operation of the site is specifically designed to prevent cross contamination).
• Purchasing, sales, and use records are kept.
• Products are correctly labelled and the accompanying commercial document or health certificate meet legislative requirements.
• Regular sampling and analysis are undertaken to ensure no CC.

Home compounders

Authorisation for the production of complete feed from compound feed containing one of the proposed new PAPs or C&G would not be required if home compounders:

• Are registered by FSS for utilising these compound feeds; and
• Only keep the types of animals that would be permitted to eat the proposed new PAPs or C&G; and
• The compound feed containing poultry or porcine PAP used in their production contains less than 50% crude protein.

Farms

The use and storage of PAP derived from poultry/pigs/insects is not allowed on farms where there are farmed animals that are prohibited from consuming those product(s). The only exception to this is where the APHA, upon inspection, is assured of on-farm measures to prevent compound feed being fed to an animal species for which it is not intended.

Transport

Vehicles and containers that transport poultry, pig or insect PAP intended for feed shall be transported to a processing plant in dedicated vehicles and/or containers.

However, vehicles and containers that have previously transported other PAP can be used, provided:

• They are thoroughly cleaned in accordance with documented procedure which has been authorised by APHA.

Labelling

The words ‘contains poultry derived products – shall not be fed to poultry or ruminants’ shall be clearly indicated on the label of compound feed containing these poultry derived products.

The words ‘contains porcine derived products – shall not be fed to pigs or ruminants’ shall be clearly indicated on the label of compound feed containing these porcine derived products.

Halal and Kosher considerations.

Prior to this consultation, Halal and Kosher certification authorities, who are experts in Sharia and Kashrut law have been contacted. The responses from these organisations will be incorporated into the final policy decision making process. There is the potential that poultry fed on porcine PAP would not be considered Halal or Kosher, if so it would be labelled accordingly. As the proposed changes would be voluntary, businesses will be free to introduce all necessary measures to ensure their products retain religious compliance.