Use in water
Regulation (EC) No 1831/2003 acknowledges that feed additives can be intentionally added to feed or water. Within the frame of the applications for authorisation of feed additives, several applicants, therefore, included ‘use in water’ as a new use for the additives. It must be noted that ‘use in water’ is not a new practice. Our industry has been innovative in this field for several decades with different specialties formulated for use in water.
Specific equipment to supply nutrients via water is also available for on-farm use, as well as in pastures. However, the definitions of two categories of feed additives – i.e. technological additives and sensory additives – restrict their use to feed only. FEFANA is working closely with the European Commission to clarify the conflicting issues that have arisen with the feed additives regulation, allow their use in animal drinking water and reflect current practice. This would require an eventual amendment of the feed additive regulation.
Once clarification of the situation regarding these additives has been achieved, it will be possible to finalise the authorisation procedure of the additives for which a decision is pending, due to a legal gap on ‘use in water’. In other cases, where the EFSA does not recommend the approval of two routes of administration for the same product, the additive has not been authorised to be used, as such, in water (e.g. Vitamin A – Regulation (EU) No 2015/724). However, the European Commission and the EU’s Member States recognise that such prohibition does not apply to those additives incorporated in compound feed subsequently administered via water (see Recital 6 of Regulation (EU) No 2015/724). This means that it is possible to supply Vitamin A to animals via their drinking water, as long as this is done through a complementary feed specifically formulated for that purpose. Such feed specialties often contain also other vitamins and compounds of trace elements, for example.