Substances classification

This tool aims to help the feed business operators and the competent control authorities of EU Member States have a consistent approach for the classification of substances, with regard to the differentiation between feed additives (as defined in the Regulation (EC) No 1831/2003 and its amendments) and feed materials (as defined in Regulation (EC) No 767/2009 and its amendments).

Background

This tool is based on the EC Recommendation 2011/25/EU of 14th January 2011 establishing guidelines “for the distinction between feed materials, feed additives, biocidal products and veterinary medicinal products” and strictly follows the criteria defined in its annex.

The distinction between feed materials and feed additives has critical implications for the placing of these products on the market. Feed business operators and competent control authorities are frequently faced with questions regarding the classification of products. The guidelines were established to avoid inconsistencies and to provide an appropriate level of legal certainty, misclassification having potentially severe consequences. Since the guidelines remain somewhat theoretical, a need for such a useful tool was perceived by the operators. It will bring practical help when using the guidelines. The tool does not aim to substitute for the operators’ or the authorities’ responsibility to take a decision but is expected to be an important benchmark in the decision process.

How does it work?

The tool has been organised and based on a limited number of straight and precise questions. They are familiar to businesses and authorities used to deal with such products. The tool calculates a score based on all answers provided. This score determines the status of the product. There is no hierarchy in the series of questions.

In order to answer most of the questions, information on the substance(s) to be tested should be prepared in advance by the user of the classification tool. This information should include product sheets, MSDS, brochures, internet information, etc. Anything that describes the nature of the product and the way it is used or promoted will be of help. Although the tool is rather robust to possible twists when some oriented answers are given, the quality and reliability of the result will significantly depend on the user’s objectivity. After entering the name of the substance to be evaluated (see text entry box on the top of this page), the system will guide the user through several questions. Additional information is provided with each question. It will help the user answer appropriately. Most questions are to be answered either by Yes or No. A few questions involve a choice through a selection list and others imply text input. Note that some of the inputs are considered as information to justify or consolidate answers given to preceding questions.

During the process, the calculation will go on. Step-by-step, the list of given answers will be displayed on the right side of the screen. This can be used afterwards to document the choices made. The tool offers possibilities to go back to any previous question or re-start from initial step. The result can also be printed or saved.

How to interpret the result?

Raw materials (e.g. wheat, corn) alone are often not able to satisfy pets’ and farm animals’ needs in terms of dietary intake of essential nutrients, necessary to guarantee their good health and, consequently, their welfare. To avoid deficiencies and possible serious shortcomings, specialty feed ingredients such as amino acids, vitamins and trace elements are fundamental in an animal’s diet, taking into consideration their requirements related to deficiencies during different stages of life.

Feed material (functional feed ingredient):

based on the information provided by the user, the product is a feed material as defined under Regulation (EC) No 767/2009 so that, in addition to its use as a macronutrient or as a carrier, it may also be used in order to perform one of the additive following functions as defined in Article 5 of the Regulation No 1831/200. While the distinction does not exist in the EU feed legislative framework, it corresponds to a practical reality: these products are close to the EU additive concept while being legally defined as feed materials. Their access to the market is determined by their feed material legal status, but the way and/or degree of enforcement applied to them is specific.

Feed material:

based on the information provided by the user, the substance is classified as a feed material, as defined under Regulation (EC) No 767/2009.

Feed additive:

based on the information provided by the user, the substance is classified as a feed additive as defined under Regulation (EC) No 1831/2003.

The system furthermore indicates when the final conclusion leaves little doubt or when the conclusion is close to another category. In the latter case, the conclusion will appear in orange.

Disclaimer

The classification tool is intended to help the feed business operators and the authorities to be have the same understanding of a given substance. Moreover, it would help the operator document his/her decision on the way the substance shall be placed on the market in the European Union. However, FEFANA does not take any responsibility in the use of the classification tool and in the further decision made by the operators. The placing of products and substances on the market stays under the sole responsibility of the operator.

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