Livestock Feed Controls in Scotland review Partial Business and Regulatory Impact Assessment

2. Options

2.1.1 Option 1 (Preferred option) - Amend regulation (EC) No. 999/2001 to authorise the use of certain proteins of animal origin in feed to non-ruminant farmed animals

The following animal proteins would be allowed in non-ruminant animal feed:

• Poultry PAP in pig feed.
• Porcine PAP in poultry feed.
• Insect PAP in pig and poultry feed.
• Ruminant collagen and gelatine in non-ruminant feed.

The requirements of the amended regulation would continue to be monitored and enforced by the APHA through the NFA. The NFA is responsible for testing animal feed for the presence of prohibited proteins. It is also responsible for auditing holdings and feed mills to ensure facilities are fit for purpose and no cross-contamination can occur.

The proposed amendments are enabling and businesses would only make use of the flexibilities if it were cost-beneficial for them to do so.

The proposed deregulation could encourage innovation and investment e.g., in the insect protein sector in GB. In the medium term this could generate benefits to Government and industry, such as contributing to sustainability goals through the use of alternative protein sources.

2.1.2 Option 2 – Do nothing

This option would involve making no changes to the existing legislation. Feeding animal protein to non-ruminant animals would continue to be prohibited, with very limited exceptions. This would leave GB regulations divergent from NI and an uneven playing field with the EU. There will be an unnecessary burden on industry as the legislation will be disproportionately restrictive, given the TSE risk level and scientific evidence and advice. This could hamper innovation in the insect protein sector, limiting the achievement of sustainability goals in the medium term.

2.1.3 Sectors and Groups Affected

As Option 2 (Do nothing) does not introduce any new legislation, they have not been taken forward for a cost benefit analysis. Under the ‘Do Nothing’ option, current controls will be maintained, with restrictions on the use of animal proteins in non-ruminant feed. This option incurs no additional direct costs or benefits. However, there will continue to be an uneven playing field between GB and the EU. This could result in the lack of investment in the GB feed industry, displacing to the EU e.g. investment on the production of insect protein. This lack of alignment with the EU could also have a negative effect on hoped-for negotiations with the EU on a veterinary and Sanitary/Phytosanitary agreement to ease bilateral trade.

Costs and benefits have been estimated using an appraisal period of 10 years.