Regulation (EU) No 225/2012 – amending Annex II to Regulation (EC) No 183/2005 on Feed Hygiene with regards to the approval of establishments placing on the market, for feed use, products derived from vegetable oils and blended fats and as regards the specific requirements for production, storage, transport and dioxin testing of oils, fats and products derived thereof – was adopted in a context of crisis.
It was apparently deemed, at that time, to be the best option to deal with the perceived need to reinforce the implementation of feed legislation in the oil and fat sector.
It basically required the Feed Business Operators (FBO) to be subjected to an approval, rather than to registration under the Feed Hygiene Regulation, and to compulsory monitor and report requirements for such products. The emergency context might certainly explain these measures, which were required by the legislator to be reviewed after two years. Based on the experience gained with the application of this Regulation in the last two to three years, FEFANA recognises that this piece of legislation unbalances the Feed Hygiene Regulation, which has served for the development of good practice approaches and HACCP implementation within the approved establishments. Finally, it has had disproportionate impact on the feed additive sector that was not targeted by these measures. FEFANA considers that the Feed Hygiene Regulation creates an over-arching, feed safety system approach, and that the creation of sector-specific rules within its Annex II creates confusion and challenges the fundamental principle of co-responsibility that underpins this Regulation.