CLP/GHS of feed additives and their mixtures

Feed additives

Industry considers its responsibility towards society and its customers that products are handled properly and safely. Therefore, FEFANA Members successfully developed a CLP-GHS (a Globally Harmonised System of Classification, Labelling and Packaging of Chemicals) listing a number of categories of feed additives over the years, for instance, for Organic Acids and their salts, Vitamins and Carotenoids.

The GHS was adopted at international level by the United Nations (UN) and provides a system to harmonise the criteria for classification of substances and mixtures relating to physical and health hazards during handling, environmental hazards, as well as labelling and packaging rules. Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures (the so-called ‘CLP Regulation’) implements the general principles of the GHS within the EU.

Back in 2012, FEFANA already started working on the harmonisation of the classification for certain categories of substances based on the GHS and in alignment with the EU legislation on CLP. Whilst Annex VI of the CLP Regulation lists the existing harmonised classification and labelling of substances according to the GHS, it does not cover every substance currently defined as a feed additive. In addition, the EU legislator mandates manufacturers and importers of the same substance to make every effort to agree on a single classification for that substance. To achieve this objective and fulfil its commitment to promote worker safety, FEFANA has made great efforts to consolidate the classification of several substances.

More information and the relevant listings are available on the FEFANA CLP-GHS dedicated webpage.

Mixtures

Whilst the position is clear for feed additives in that they fall under CLP Regulation, the situation for mixtures of feed additives is more complex, and is interpreted differently across EU Member States.

Further clarifications are anticipated from the EU authorities, as to whether CLP of chemical substances apply to mixtures of feed additives. FEFANA members are preparing actively for a practical, harmonised and organised implementation of the Regulation in all EU Member States.

FEFANA-FEFAC joint statement on Annex VIII of CLP

Notification to Poison Centers: implementation date for feed additives and premixtures

On 13th November 2020, the Commission published implementing Reg. (EU) 2020/1677. This regulation includes a second amendment to Annex VIII to CLP, which addresses concerns raised during the EC workability study, as well as the addition of article 2.4 (4) that introduces the concept of “mixture with an end use not subject to notification”.

This article results in a de-facto postponement of the date of entry into application of the harmonized PCN obligation for feed additives and premixtures.

FEFANA and FEFAC have produced a joint statement aimed at feed business operators as to better inform them on the date of applicability for relevant products in the feed chain: January 1st 2024.