FEFANA

FEFANA

FEFANA is the European association representing manufacturers and traders of specialty feed ingredients.

Lobbying Activity

Meeting with Christine Singer (Member of the European Parliament)

9 Dec 2025 · Omnibus Food & Feed Safety

FEFANA urges EU to simplify feed additive renewal and transport

23 Sept 2025
Message — FEFANA proposes ending the 10-year renewal rule for additives to align with other sectors. They also support digital labelling and clearer rules for transporting export-only ingredients.123
Why — Simplified rules would reduce administrative costs and recover millions in lost export revenue.45

Meeting with Claire Bury (Deputy Director-General Health and Food Safety) and

17 Sept 2025 · EFSA’s performance evaluation

FEFANA urges EU to streamline feed additive authorization rules

23 Jun 2025
Message — FEFANA requests faster authorization processes and digital labelling to reduce costs. They propose ending ten-year renewals and prioritizing biomass for food and feed.123
Why — Simplified rules would reduce operational costs and help EU companies compete globally.45
Impact — Biofuel and construction firms lose access to biomass under the proposed consumption hierarchy.6

Meeting with Alexander Bernhuber (Member of the European Parliament)

17 Jun 2025 · Futtermittelverordnung

Meeting with Koen Van Dyck (Head of Unit Health and Food Safety)

8 Apr 2025 · Revision of Regulation (EC) N° 1831/2003

Meeting with Christine Schneider (Member of the European Parliament)

30 Sept 2024 · Animal nutrition

Meeting with Stefan Köhler (Member of the European Parliament) and Eurogypsum

17 Jul 2024 · Politischer Austausch

FEFANA calls for faster EFSA approvals and streamlined procedures

8 Apr 2024
Message — FEFANA requests faster assessment timelines to address a significant backlog of feed additive dossiers. They suggest adopting practical pre-submission advice and technical hearings similar to the pharmaceutical sector. Additionally, EFSA guidance must be better aligned with existing European Union legislation.123
Why — Faster procedures would reduce market access delays for new additives and increase regulatory predictability.45
Impact — Lengthy delays and regulatory inconsistencies hinder innovation and encourage companies to develop products outside Europe.67

FEFANA Calls for Impact Assessment of EU Chemical Agency Streamlining

28 Mar 2024
Message — FEFANA calls for a thorough impact assessment to evaluate business costs and administrative burdens. They request a review clause to monitor potential delays in regulatory approvals.12
Why — This would prevent administrative burdens and ensure the sector remains innovative and competitive.3

FEFANA warns chemical data platform will burden feed industry

28 Mar 2024
Message — The organization requests aligning the scope of studies with existing food law practices to avoid administrative friction. They call for a full impact assessment and consultation with industry experts before setting technical standards.12
Why — Harmonizing requirements would protect investment returns and prevent further delays in processing product applications.3
Impact — Business operators face higher costs and more complex administrative processes under the current proposal.45

FEFANA urges green taxonomy status for specialty feed ingredients

3 May 2023
Message — FEFANA proposes specialty feed additives be recognized as enabling technologies under the Taxonomy. They request manufacturing additives with verified emission reduction records qualify as green business activities.12
Why — Labeling these activities as green would help the industry attract and scale up sustainable investment.3

FEFANA urges EU to align chemical rules with global standards

17 Oct 2022
Message — FEFANA requests that the EU avoids introducing new hazard classes unilaterally. They want the EU to seek inclusion in global standards first.12
Why — Maintaining alignment with global standards protects the competitiveness of EU operators.3
Impact — EU businesses risk international isolation if the EU acts without global consensus.4

FEFANA calls for caution on chemical data transparency

16 Aug 2022
Message — The group requests a thorough impact assessment to avoid excessive administrative burdens. They demand protection for confidential business information and fair compensation for data owners.123
Why — Industry would see lower costs through simplified procedures and less repetitive testing.4
Impact — EU businesses suffer from processing delays and compromised returns on their investment.5

Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

12 Apr 2022

FEFANA welcomes the opportunity to provide feedback to the Commission’s call for evidence: “Chemicals – making best use of EU agencies to streamline scientific assessments”, details provided in the attached document accordingly.
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FEFANA Urges Feed Nutrition Focus to Combat Antimicrobial Resistance

24 Mar 2022
Message — FEFANA highlights how specialty feed ingredients optimize animal nutrition and lower antibiotic reliance. They argue that adequate nutrition increases resilience and helps maintain high health standards.12
Why — This would promote specialty feed ingredients as essential tools for sustainable livestock production.3
Impact — Manufacturers of therapeutic antibiotics may face lower demand for veterinary treatments.45

Response to Import conditions and border controls of trade samples and certain composite products

23 Nov 2021

FEFANA (the EU Association of Specialty Feed Ingredients and their Mixtures) welcomes the opportunity to provide feedback on this EC consultation. Please find attached the detailed FEFANA position paper. FEFANA shares the concern of both, food and feed business operators, that Vitamin D3 and cholesterol should not be regarded as a ‘product of animal origin’ and should be allowed for import without any restriction in order to preserve animal health and welfare in the EU. Notwithstanding the fact that Vitamin D3 should remain as an ‘organic chemical’, if the EC would still insist on the change of classification to ‘product of animal origin’, it should be considered to exempt Vitamin D3 and cholesterol from official controls under Article 48(h) of Regulation (EU) 2017/625 as ‘categories of animals or goods posing a low risk or no specific risk and for which controls at border control posts are therefore not necessary’ for the continuity of the trade from third countries into the EU.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

FEFANA welcomes the opportunity to offer feedback on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals. FEFANA appreciates that, for the implementation of the Green Deal, the chemicals strategy for sustainability sets out a number of ambitious actions. However, we wish to underline the importance of a broader dialogue between industry and authorities prior to any legislative proposals for a revision of the CLP Regulation and its annexes. The Globally Harmonised System (GHS) has been adopted at international level by the United Nations and provides a system to harmonise the criteria for classification of substances and mixtures relating to physical and health hazards during handling (e.g., worker safety), environmental hazards, as well as the rules of labelling and packaging for hazardous substances and mixtures. The GHS framework should continue to be a guidance for internationally harmonised classification and labelling of hazardous chemicals, also for the EU, via Regulation (EC) No 1272/2008. EU business operators value the achieved harmonisation for handling of chemicals in their workplaces where labels and safety data sheets are consistently used. Any unilateral implementation of new hazard classes without consultation of the UN GHS goes against the EU aim of “having a leading role and promoting the implementation of existing international instruments”. We are concerned that the EU unilateral introduction of new hazard classes will not only isolate the EU from other member countries of the UN GHS process, but is likely to create distrust in the value of global harmonisation, which is key to meet the objectives set by the EU in the Green Deal. In addition, the timeline set by the EU Commission for amending the CLP Regulation is very ambitious. For this reason, a broader dialogue between industry and authorities is needed before possible adaption of new EU requirements.
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Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

31 May 2021 · Exchange on Farm to Fork Strategy with European Livestock Voice

Response to Agriculture - List of products and substances authorised in organic production

22 Apr 2021

FEFANA, the EU Association of Specialty Feed Ingredients and their Mixtures, would like to share its views on the EC proposed "list of products & substances authorised in organic production (update)". Please refer to the document in the Annex for the full FEFANA feedback.
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Response to Feed additives - revision of EU rules

20 Jan 2021

FEFANA, the EU Association of Specialty Feed Ingredients and their Mixtures, would like to share its views on the EC Inception impact assessment - Ares(2020)7546840 – on the Revision of the Feed Additives Regulation(EC) No 1831/2003. Please refer to the document in the Annex for the full FEFANA feedback.
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Response to Amending the rules concerning feed additives applications and assessment in view of the new “Transparency Regulation”

25 Aug 2020

FEFANA is the united voice of the specialty feed ingredients industry in the European Union. Our membership comprises manufacturers and traders of feed additives, functional feed ingredients, premixes and other mixtures of specialty ingredients that enter the food chain via feed. The products of our industry are key elements for optimized feed formulations. They enable more efficient and sustainable livestock production through reduced use of natural resources, less waste and livestock emissions, reduced need for antibiotics and contribution to high-quality animal products. Amendments to Regulation (EC) No 429/2008 are of fundamental importance to the industry of specialty feed ingredients and their mixtures as this implementing act details the rules for the preparation and the presentation of applications and the assessment and the authorisation of feed additives. The impact of the changes resulting from the future enforcement of the draft legal text is still unknown owing to non-availability of the practical details of implementation. In fact, the European Commission has requested the European Food Safety Authority to detail the new rules for feed business operators in a document called “Practical Arrangements (PAs)”, which is yet to be released. This guidance will be key in order to enable a full evaluation of the actual “workability” of the new rules for the sector. We understand that some of the proposed rules are: • Either not enforceable: e.g. in case of renewals, the EFSA public consultation on supporting studies should precede the date of submission by a considerable amount of time in order to be able to execute/re-submit all planned/requested studies well before the prescribed deadline for submission of the renewal dossier (1 year prior to date of expiry; art. 14 of Reg. (EC) N. 1831/2003). • Or very challenging: in practice, especially during the initial period after the date of application of the new regulation, applications might have to contain both, notified and non- notified, studies if the latter were commissioned before 27 March 2021. As an outcome of an initial assessment carried out by feed business operators (FBOs), FEFANA calls for the establishment of an adequate transitional period which would avoid FBOs to face unintended administrative consequences foreseen by the legislation in case of incompliance with the obligatory notification of commissioned studies (6 months application temporary suspension). Different from other sectors of regulated products, FBOs do not have experience with electronic-submission systems. We believe that the announced autumn 2020 release of the EFSA Practical Arrangements (PAs) details of the binding new procedures for the pre-submission phase such as definition of “study”, modalities for notification of studies, public consultation mechanisms, will not leave sufficient time for FBOs to get prepared and ready to comply with the considerable amount of new rules, especially, as has been understood at the recent EFSA Sounding Board meeting of 15 July 2020, if EFSA would go beyond the requirements of the new legislation. FEFANA calls for understanding and support that applicants need adequate time to review, assess and adapt to the different elements of the new procedures. FEFANA requests that the amended Regulation (EC) No 429/2008 contains adequate transitional periods for feed additive applications and a transitional period of at least 18 months in case of renewals planned for submission after the application date of 27 March 2021 of Regulation (EU) 2019/1381 on the transparency and sustainability of the EU risk assessment in the food chain.
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Response to Intellectual Property Action Plan

12 Aug 2020

We wish to respond to the consultation on the Roadmap for an Intellectual Property Action Plan which is due to be published later this year. The Action Plan undertakes to provide a comprehensive concept for the protection and promotion of innovation and investments in Europe. The breadth of scope is to be welcomed, but this also requires the inclusion of a framework for intellectual property relevant to the area of feed and food and the bioeconomy and the agri-food chain generally. The inclusion of the latter, in our view, is mandatory. Feed additives are ‘regulated products’ and as such are an example for a whole range of other products developed at considerable effort. The European Food Safety Authority (EFSA) defines regulated products as products, claims and processes including substances used in food and feed (such as additives, enzymes, flavourings, and nutrient sources), food contact materials and pesticides, genetically modified organisms, food-related processes and processing aids. These need to be safety-assessed before being authorised to be marketed. In the process of risk assessment, applicants are required to publish research carried out in product development. These documents contain sensitive data that often represent the value of the product, the intellectual property interests and business strategy of applicants. Such disclosure definitely enables easy and uncontrolled access to data, facilitating abuse, for example by competitors using studies for their own registration processes in different parts of the world. This is particularly relevant to study proposals and reports which represent a company’s investment and know-how, notably in relation to non-safety-related efficacy and identity data for feed additives. Two points we wish to make it relation to IP of food and farm products: · The protection of proprietary data needs a comprehensive, thought-through approach · Publication of proprietary data needs to be limited to sufficiently protect confidential information For both points we give some explanations in attachment (below an extract). 1) The protection of proprietary data needs a comprehensive, thought-through approach Regulated products in food and feed law are many. They are regulated in different acts and each act contains provisions on IP protection. These provisions, however, are differently worded and vary (data protection, market exclusivity, etc.). Union law, although regulating the IP for decades, appears to have never made an attempt to develop an overarching concept for IP protection for these products. The Intellectual Property Action Plan – in the name of better regulation and also in order to make EU law future-proof – should mark the starting point for the development of a comprehensive approach for IP in the area. Some of the EU legislation dealing with regulated products: feed additives, food contact material, food improvement agents, plant protection, biocides, novel food, veterinary medicinal products...) 2) Publication of proprietary data needs to be limited to sufficiently protect confidential (e.g. composition and or know-how) information Reg. (EC) No 178/2002 – the act of Union law providing the basis for food and feed law – has recently been amended by Regulation (EU) 2019/1381 on the transparency and sustainability of the EU risk assessment in the food chain. The law requires applicants seeking market access for regulated products to disclose (i.e.: information shall be available to be downloaded, printed and searched through in an electronic format) proprietary scientific data used in the risk assessment process carried out by the European Food Safety Authority (EFSA). Under Article 38 of Reg. (EC) No 178/2002 (as amended), scientific literature is part of an application dossier and needs to be published on the EFSA website. This on-line publication, in many instances, will violate existing copyrights of the scientific publication houses. Read more in ANNEX
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Response to Farm to Fork Strategy

6 Mar 2020

FEFANA welcomes the initiative of the European Commission to launch a Farm to Fork Strategy as a key component of the European Green Deal in order to tackle climate change, protect the environment and preserve biodiversity through faster transition towards sustainable food systems. Such an ambition requires a holistic approach, where each part of the value chain plays a fundamental role in the achievement of the overall goals, and where the legal framework promotes and facilitates the development of new technologies and solutions unleashing the innovation potential of the agri-food system. It is fundamental that the Strategy reflects sound scientific principles as this is the most effective route to finding solutions to pressing societal problems. The European Commission roadmap provides an interesting overview of current challenges and key elements of the strategy toward a more sustainable food chain. Nevertheless, the current roadmap does not recognise the essential role of suppliers into the farming system, such as the specialty feed ingredients industry, when referring in section C Better Regulation to “Consultations will aim to collect relevant information on the challenges encountered by primary producers, food producers, processing and retail and by the citizens”. We would appreciate a rectification of such omission. We encourage the European Commission to consider our industry as a partner in the implementation of the strategy. The sector provides solutions to key societal problems in the context of the new Green Deal. Specialty feed ingredients can, for example, reduce the carbon footprint emissions from animal farming, reduce the need for antibiotics by maintaining animals in optimal health and, thus, with higher resilience to stressors, such as pathogenic micro-organisms; contribute to resource efficiency and a circular economy by improving the nutritional value of current (limited) resources and by enabling the use of co-products, making them digestible for the animals. In addition, they are key elements for high quality animal products for healthier diets, thanks to optimised animal feed formulations with innovative products. An in-depth analysis of the sector’s contributions can be found in the attached position paper. The Farm to Fork Strategy should recognise the essential role and efforts of companies and farmers, whom have already achieved great progress in reducing greenhouse gas (GHG) emissions from the EU livestock sector below 6% of the EU’s total GHG emissions (source: https://ec.europa.eu/eurostat/statistics-explained/index.php?title=File:Figure_1_Contribution_of_agriculture_to_total_GHG_emissions_(%2525),_EU-28,_2015.png ). Each sector is a partner investing time and resources to bring new solutions to current issues, while creating jobs, ensuring stability in the rural areas and providing safe, nutritious and high-quality food for our tables. The Farm to Fork strategy provides an opportunity to ensure a level playing field for the industry through a modern EU regulatory framework that provides for safe use of feed ingredients while encouraging innovation to the benefit of the ambitious targets of the strategy. In this frame, FEFANA also welcomes the on-going evaluation of Regulation (EC) No 1831/2003 on additives for use in animal nutrition, and the recently started initiative to assess the fitness of the EU legislative framework for new genomic techniques, as steps towards exploiting the potential of modern technologies and innovation to meet society’s demand of high-quality and sustainable food, while producing less pollution and emissions. Finally, FEFANA and the specialty feed ingredients industry are committed to provide their expertise for the implementation of a successful Farm to Fork Strategy. FEFANA is ready to further engage with the European Commission in dedicated future actions e.g. as a member of a stakeholder group guiding the implementation of the ‘Farm to Fork’ Strategy.
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Response to Amending Regulation (EC) No 1272/2008 relating to emergency health response

19 Aug 2019

FEFANA (EU Association of Specialty Feed Ingredients and their Mixtures) fully supports the year extension of the first compliance date to the new rules introduced by Regulation (EU) 2017/542 with a view to clarifying certain issues concerning their workability and, accordingly with sensed solutions, facilitating their implementation. FEFANA appreciates the European Commission, Member States and ECHA efforts and resources dedicated to the assessment of workability issues to be identified consistently across different sectors. FEFANA welcomes any change to the legal text which brings a simplification of the notification process for industries without undermining the emergency response. However, FEFANA members are still concerned about practical aspects related to feedingstuffs. It is therefore appropriate to defer any compliance date in order to: • develop the necessary solutions and make necessary change to notify under the new “streamlined” rules; • allow sufficient time to a number of operators to become familiar with the tools. Indeed, preferably only once solutions how to address detected workability issues will have been developed and all appropriate changes to the new rules have been made, compliance deadlines should be newly established. This should thus give the opportunity to the industry to comply with Annex VIII of Regulation (EC) No 1272/2008 by the deadline. Finally, we would like to take this opportunity to underline that FEFANA experts are looking forward to further contribute to debates looking at possible solutions for the issues identified by concerned operators in the animal feed industry. FEFANA is looking forward to further discuss previously highlighted aspects within the ad-hoc CARACAL subgroup tasked to follow up on workability issues.
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Response to Amendment of products and substances allowed in organic production

7 Aug 2019

FEFANA welcomes the opportunity to offer feedback on the draft implementing regulation and Annex concerning the list of substances that can be used in organic production, as of great relevance to the specialty feed ingredients’ industry. On behalf of FEFANA members and experts, we would like to point out the following: • “Lactic, formic, sodium formate, propionic and acetic acid” are present in the newly proposed draft Annex III (Annex VI of the Organic Regulation) as (e) Silage additives. The additives lactic acid and acetic acid are not authorized as silage additives under Reg. (EC) No 1831/2003 (and therefore against the same principle stated under Annex VI of Reg. (EC) No 889/2008). Furthermore, such amendment of the Annex is not mentioned in the corresponding draft implementing regulation. • “Sweet chestnut extract” proposed as flavoring under the new draft: the EU Register of Feed Additives only mentions “Castanea sativa Mill.: Chestnut extract”. Product names should reflect what is included in the EU Register and corresponding implementing regulation (OJ) in order to avoid confusion and misuse. Furthermore, certain ambiguity is caused by the insertion of “sweet chestnut extract” as a separate line with respect to “flavouring compounds (only extracts from agricultural products)”, which is understood to include all botanical flavourings listed in Annex I of the EU Register of Feed Additives. • Another nomenclature issue appears in correspondence to (b) compounds of trace elements (issue present both in the current Annex VI and the proposed draft). The codes 3b8.10 and 3b8.11 no longer apply, as the ID numbers have been amended to: 3b810 and 3b811 (Selenised yeast Saccharomyces cerevisiae CNCM I-3060, inactivated and Selenised yeast Saccharomyces cerevisiae NCYC R397, inactivated). Further issues concerning ID numbers can be identified, as for example sodium selenite (re-authorised 3b801), and potentially more. • Generally speaking, FEFANA and its experts encourage and recommend an alignment between Annex VI of (EC) No 889/2008 and the EU Register of Feed Additives, including the repartition of the list into category, functional group name and ID number of the substance, in order to avoid any misunderstanding for users, producers and authorities.
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FEFANA urges protection for intellectual property in risk assessments

25 Jun 2018
Message — FEFANA calls for a postponement of the decision until a comprehensive impact assessment is completed. They request that transparency measures exclude non-safety-related efficacy data and protect companies' inventions from disclosure. The association also emphasizes the need to prevent competitors from accessing and abusing proprietary business strategies.123
Why — These changes would protect their market position by preventing competitors from using their research.4
Impact — Stakeholder groups lose the ability to perform alternative evaluations of the industry's data.5

FEFANA Urges Strong IP Protections in Food Safety Transparency

16 Jan 2018
Message — FEFANA demands that new transparency rules must secure the protection of intellectual property rights. They call for an appropriate balance between public access and private ownership. They insist science remain free from pressures caused by emotional public campaigns.123
Why — Protecting intellectual property safeguards investments in research and development for member companies.4
Impact — Public interest groups might see reduced access to raw scientific data for review.5

Response to COMMISSION IMPLEMENTING REGULATION (EU) concerning the denial of authorisation of formaldehyde as a feed additive

18 Dec 2017

The enclosed feedback is provided on behalf of the FEFANA Consortium for authorisation of feed additives used as hygiene enhancers - HYFAC (Hygiene Feed Additive Consortium).
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Response to Evaluation of the feed additives Regulation

22 Sept 2017

FEFANA welcomes the evaluation of Reg (EC) 1831/2003 and will provide its full support to ensure a thorough insight. Since its publication, we have acquired wide reaching direct user experience to assess the impacts of the Regulation, its significance and performance not only in terms of how it relates to current needs of society but also how it will correspond to the future. While the Roadmap provides an extensive summary of purpose and subject of the Evaluation, we would like to emphasise the following relating to parts C, D & E: (1) Ad (C.1) Topics covered: a. FEFANA supports the key focus i.e. ascertaining whether the intended objectives of the legislation that were set in the years before 2003 have been achieved. However, we urge the EC to expand the Evaluation to check its fitness against future requirements of the sector and to take into account the feed-relevant regulations that came into force since 2003, which have a direct impact on the achievement of the originally intended objectives of the Regulation. b. Setting the context the recitals should be amongst the topics covered to assess the coherence of the legal text with relating EU legislation. A non-exhaustive list of items is provided below: - Whereas (12), (23), (24): Dir.82/471/EEC are now repealed by Reg.(EC) No 767/2009 - Whereas (16): refers to the establishment of a simplified authorisation procedure for those additives already authorised for food - Whereas (33): Dir.79/373/EEC was in force - repealed by Reg.(EC) No 767/2009 c. The Roadmap sets the focus seemingly on the ‘pure’ authorisation procedure while, from practical experience, the very specific technical requirements would certainly also need to be considered with a holistic review. A selective list of topics and related articles comprises: i. Trials, Art 3.2 ii. Innovation and new categories/functional groups, Art 6.3 iii. Documents and particulars sent to the Authority, Art 7.3 iv. Assessment procedure; Implementing Reg.; EC guidelines; EFSA techn. guidance, Art 7.3 - 7.6 v. Residues; MRLs, Art 9.7 vi. FA Register, Art 17 vii. CRLs, Art 21 viii. Harmonised implementation, Art 24 d. To fully assess the performance of the Regulation, the Evaluation should consider other legal texts of importance to the feed sector. In this respect, the Evaluation should pay particular attention to identifying and analysing any wanted/unwanted combined effects with other related regulations that might have only become apparent over time. The following regulations should be considered (non-exhaustive list): Reg (EC) 767/2009, Reg (EC) 889/2008, Reg (EC) 1272/2008, Reg (EC) 1107/2009, Reg (EU) 528/2012, Reg (EC) 429/2008, Recom.25/2011, Reg (EU) 2015/327; Reg (EC) 183/2005. (2) Ad (D.2) Previous evaluations and other reports please consider adding: • Review of 10 years scientific support to FAs authorisation: https://ec.europa.eu/jrc/en/science-update/review-10-years-scientific-support-feed-additives-authorisation (3) Ad E. Other relevant information/ remarks: FEFANA would like to point out that through the differentiation of feed additives ‘vs’ feed materials that are both not precisely defined in their respective legislation - which specifically exclude feed materials from feed additives, while allowing for similar intended uses to both - the legislator unintentionally created an unfair market place and market imbalance. Appreciating the initiative of the EC we also understand the complexity of the task. We would like to stress that although the above points have been added for completeness to determine the ToR we strongly believe that it is time for a complete fitness-check aligning the feed legislation with the principles of the General Food Law.
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Meeting with Vytenis Andriukaitis (Commissioner) and

9 Jun 2016 · AMR, Food and feed safety, and animal health