European Former Foodstuff Processors Association

EFFPA

-To represent, defend and promote the interests of the Former foodstuff processing industry to the European Institutions; -To lobby for a legislative framework and its implementation, without discrimination in EU Member States so as to maximise the feed use of food products not used for human consumption; -To develop professional rules and good manufacturing practices including the sourcing of former foodstuffs that ensure the quality and the safety of the produced feed; -To promote the feed use of former foodstuffs as the number two option after human consumption in a sustainable way responding to the objective of a sustainable feed and food chain; -To promote pre-competitive research with a view to improve the efficiency of the conversion of former foodstuffs in feed and its sustainability, as well as the establishment of standards (eg methods of analysis for packaging residues).

Lobbying Activity

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development) and Fédération Européenne des Fabricants d'Aliments Composés

6 Jun 2025 · Exchange of views on circular feed production and its contribution to sustainable feed and livestock production.

Response to Update of list of sustainable biofuel feedstocks

2 Jan 2023

Please find attached the feedback of the European Former Foodstuff Processors Association
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

EFFPA is the European Former Foodstuff Processors Association. Former foodstuff processors convert food losses at food factory level into animal feed for food-producing animals. EFFPA supports the overall ambitions to stimulate a clean energy transition. This is also necessary for former foodstuff processors to further reduce GHG emissions linked to their energy and transport use in and around their factories. However, EFFPA’s experience with the Renewable Energy Directive has been fairly negative though so far. Since the development of the first Renewable Energy Directive, there has been pressure from the subsidised anaerobic digestion sector for the same ‘food by-product biomass’ (e.g. bread, biscuits, breakfast cereals) used by former foodstuff processors. There have been clear cases where the feed use of ‘food by-products’ from a food business operator were thwarted because of the financial capacities that were driven by the need to meet advanced biofuels targets. The Renewable Energy Directive II does intend to tackle this with clear requirements as regards the waste hierarchy and sustainability criteria. As the pressure for decarbonisation in the energy sector will only increase and the search for new advanced biofuels feedstocks goes on, EFFPA cannot stress enough that negative impacts on the former foodstuff processing sector must be continuously considered. EFFPA therefore welcome the notion that “the risk of unintended incentives for using unsustainable biomass will be assessed and minimised through appropriate safeguards”. The reduction of GHG emissions in livestock farming is also a key objective in the EU 2030 Climate Target Plan. A successful strategy that the feed industry applies is to reduce the amount of ‘land-requiring’ feedstuffs (i.e. feed crops) and increase the use of co-products such as former foodstuffs. The Commission must take the bio-economy perspective and avoid that “Peter is robbed to pay Paul”, meaning that the push for more sustainable biofuels goes to the expense of more sustainable feed production. In this regard, the extent to which ‘potential former foodstuffs’ are intentionally downgraded to waste status is worthy of investigating. It is somewhat ironic that feed crops in a certain way benefit from a ‘protected status’ of being labelled an advanced biofuels. If the scope of advanced biofuels moves too much into the territory of ‘feed co-products’, the RED may in fact be driving the feed crop use and reliance of livestock farming. www.effpa.eu
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Response to Update of the 2012 Bioeconomy Strategy

16 Mar 2018

EFFPA is the European Former Foodstuff Processing Association, representing associations and companies that convert food losses such as bread, biscuits and chocolates into animal feed. EFFPA welcomes the initiative the review to Bioeconomy Strategy from 2012. Former foodstuff processors are grateful for being part of the EU Circular Economy Action Plan on food waste reduction, with the amendment to the Waste Framework Directive to improve industrial symbiosis (highlighted in the review) between former foodstuff processors and food manufacturers as the prime example. By providing non-land requiring feed materials, which are mostly not human-edible, former foodstuff processors play their part in the food chain’s bioeconomy. As EFFPA stated during its presentation at the European Bioeconomy Policy Day in November 2017, growth of the former foodstuff processing sector to further reduce food waste also depends to which extent food manufacturers and food retailers can make the valorisation of their feed-grade food losses part of their sustainable business strategy. The development of LCA tools that support decision making in food waste management and help with accountability would be of added value, thereby also allowing for an indirect implementation of the food waste hierarchy and the bioeconomy’s cascading principles. In the effort to stimulate the bioeconomy contributions to the Energy Union, it is well-known that the stimulation of advanced biofuels should not be in competition with food and feed applications, which have higher circular economy potential. In that light it is important that support schemes for advanced biofuels are able to demonstrate they only valorise biomass not fit for the food and feed chain, to not distort the market for feed-grade food losses destined to animal feed.
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Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

25 Jan 2018 · Food waste

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and Fédération Européenne des Fabricants d'Aliments Composés

4 Jul 2017 · Food waste

Response to Amending the Annexes for the labelling of compound feed and pet food

23 Jun 2017

EFFPA, the European Former Foodstuff Processors Association, welcomes this amendment. When former foodstuffs are created at food business operator level, further processing is very often required to make the material suitable for animal consumption, in particular for packaged former foodstuffs. This amendment to Annex VIII confirms the legal practice of purchasing packaged former foodstuffs as a feed material at the level of food manufacturing and it gives credibility to mechanical packaging removal as a legitimate process in feed manufacturing to make it appropriate for animal consumption. EFFPA does believe the labelling description could be made more simple by omitting the “feed with..” part, to avoid an emphasis is put on a certain contamination. Specifically to packaged former foodstuffs, it may create the perception that there is an intrinsic ‘packaging contamination’ concerning the food products used as feed. Also the precedent set by legislation on undesirable substances, where words like “excessive levels of..” are used, could create unnecessary confusion. In addition, the reason for non-compliance is already clear with mentioning the processing requirement, which in practice will be focused on “packaging removal”. Given it is has a legal status as feed, the term “former foodstuffs” could be used in the labelling requirement description. EFFPA members would also appreciate if ‘recent’ agreements between food business operators and former foodstuff processors on labelling practices of former foodstuffs in the Member States can be taken into account. For translation purposes, EFFPA members see an advantage in using the term “feed materials” instead of “feed”. A reworked proposal for the labelling requirement could be: Former foodstuffs, only to be used as feed materials after … (designation of the adequate process in accordance with part B of the Annex to Regulation (EU) No 68/2013).
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