Announcement of New FABRA Chairman – November 2024

At FABRA’s Board Meeting and AGM in November Barney Williams of Advanced Proteins was unanimously elected as the new FABRA UK Chairman.

Barney brings an excellent blend of technical and operational experience to the role for his 2-year tenure, built up over 20 years in our industry.

The Board thanked outgoing Chairman Jane Brindle for her hard work and dedication over the last 2 years, in particular with work on energy and carbon schemes and in further raising the profile of the organisation with Government Stakeholders.

Chairman’s Update – December 2024

As we reach the end of 2024, and also the end of my two years as FABRA Chairman, it is time to review progress made and important areas for the coming year.

It has been an interesting year with a General Election interrupting progress in the summer. However, this gave us opportunity to share our industry concerns with new Ministers and the Select Committees that oversee their work. Work on the planned amendments to the Animal By Products Regulations to allow for non-ruminant (pork and poultry) PAP to be reintroduced into certain animal feeds has been re-started by DEFRA. A public consultation has been released in Scotland, with a similar one to follow for England and Wales. FABRA have been working with our European counterparts at EFPRA on publicity for this, with position statements and background information to inform Stakeholders.

The review of UK Best Available Techniques (BAT) for preventing and minimising the environmental emissions and impacts from our industry is well underway now, with a good attendance at the first Technical Working Group by FABRA Members. This important process will define mandatory standards for the sector over the coming years. FABRA continues to play a lead role with the other meat industry associations in our industry sub group as we all prepare for the next steps. Evidence and data collection for defining Key Environmental Issues and setting emission and consumption benchmarks is next.

The landscape for energy legislation is looking slightly different under the new Government with a much faster route to Net Zero as a priority for the Energy Secretary. We have held meaningful discussions with the Department for Energy Security and Net Zero (DESNZ) in recent months and are working towards minimising the carbon tax impact on the sector, while highlighting the contribution our industry makes towards sustainable recycling and the circular economy. 2025 will be a busy time as we provide evidence on energy efficiency improvements and consumption rates to DESNZ to inform their setting of Targets for our members under the new the Climate Change Agreement Scheme.

Another important area for future consultation is the review of the veterinary agreement for trade with the EU. The new Government is committed to reviewing SPS arrangements and there will be opportunity to lobby for improvements and a ‘levelling up’ of import and export requirements. Later in 2025 we expect to have a decision from the World Organisation for Animal Health on the UK’s application for negligible BSE risk status. If approved, this will be the first step in a lengthy process for re-opening some of our product markets that were closed when we left the EU, as well as markets in other 3rd countries that are limited by our BSE risk status. An interesting period ahead.

Jane Brindle
Chairman
FABRA UK

List of Acronyms
ABP – Animal By Products
BSE –  Bovine spongiform encephalopathy
DEFRA – Department for Environment, Food and Rural Affairs
EFPRA – European Fats and Proteins Rendering Association
PAP – Processed Animal Protein
SPS – Sanitary and Phyto-Sanitary

UK Consultation on Livestock Feed Controls Review

 FABRA UK Consultation Response - December 2024

The Livestock Feed Controls Review regards proposals for the removal of the UK prohibition on feeding non-ruminant farmed animals, other than fur animals, with protein derived from non-ruminant animals and insects.

The legislation reapproving the use of Processed Animal Proteins (PAPs) in pig and poultry diets in the EU entered into force on 8th September 2021. Stakeholders across the UK livestock sector, animal feed industry, meat processors and retailers are now assessing the UK Government’s consultation on amending the same prohibition in UK law.

PAPs are a solution to finding more sustainable, highly nutritious animal feeds and offer a low carbon protein alternative to soybean for animal feed. The UK’s circular economy ambitions add significant weight to amending the rules on the use of PAPs in farmed animal feed which is in accordance with DEFRA’s Food & Drink Waste Hierarchy.

Our members produce PAPs, and we support their reintroduction into pork and poultry diets. The EU recognised that legislative changes must include reliable protein testing strategies, robust controls and give appropriate assurances to support trade. The UK Government assessed the health risks ahead of the UK consultations and is satisfied that suitable controls, now used in the EU are available to address matters.

PAPs are produced from safely sourced and traceable animal by-products derived from healthy slaughtered animals fit for human consumption or food processing. This eliminates the possibility of intra-species consumption, and the highest standards of hygiene and traceability mean our products are safe and suitable as healthy ingredients for animal feed.

The animal by-products processing sector has an established and essential role in enhancing the sustainability of the animal-based food supply chain, bringing benefits such as optimal use of resources, waste minimisation, reducing greenhouse gas emissions, minimising nutrient leakage and avoiding deforestation by utilising local materials that would otherwise be waste. The reauthorisation of PAPs in animal feed will add this optimal outlet for our low carbon products and close the circular bioeconomy loop.

FABRA UK’s Factsheet “Livestock Feed Controls Review - FABRA-FS-010” discusses the background of the prohibition and the sustainability merits of PAPs. FABRA UK has also prepared a series of questions and answers to help interested parties understand more about PAPs. These cover issues such as:

·       the legal rules and regulations
·       how PAPs are produced
·       what it means for consumers
·       how animal safety is maintained at all stages of the supply chain

You can download a copy of the questions and answers here.

Additional information is available from our counterparts at the European Fat Processors and Renderers Association (EFPRA) which has a range of material about the removal of the EU feed prohibition.

If you have any comments or questions on this Position Statement, please contact us.

 

 

ABOUT PAPs

ABOUT PAPs

Q        What are PAPs?

A         Processed Animal Proteins (PAPs) pronounced P-A-P are made from animal by-products (ABPs) from meat production. These are parts of the animals that are not consumed by humans. PAPs come from healthy slaughtered animals fit for human consumption. Sourcing and quality are veterinary controlled to ensure safety.  

Q      Where are PAPs used?

A         PAPs have a multitude of applications. Thanks to the excellent nutritional value of the protein. PAPs can be used in aquafeed, animal feed and pet food.

Q      Are PAPs safe for animals to eat?

A         Yes, PAPs are made from Category 3 animal by-products that originate from healthy animals. All Category 3 material is classed as fit for human consumption at the point of slaughter. Sourcing and processing PAPs is always under veterinary control to ensure safety all the way along the supply chain. Pets, carnivorous or omnivorous fish such as salmon or shrimps, and omnivorous animals – pigs and poultry – require a diet with rich protein sources to thrive.

Q      Is it natural for animals to eat PAPs?

A         Yes, for many animals it is. Animals that eat meat wholly or as part of their natural diet benefit from a rich source of protein in their diets which helps them to develop, grow and be healthy.

ABOUT LEGAL RULES AND REGULATIONS

Q      What rules are there on using PAPs in the UK?

A         The UK’s Animal By-Products regulations implement the EU ABP Regulations and are retained as of the point the UK left the EU. EU Regulation 1069/2009 and 142/2011 set out health rules concerning animal by-products not intended for human consumption. EU Regulation 999/2001 sets rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies. The rules which prevent the feeding of PAPs to farm animals is often referred to as the ‘feed ban’ and remains in UK law because the EU’s changes to their rules on PAPs for feed came after we left the EU.

Q      What are the proposed changes to the UK rules on using PAPs?

A         There is currently a consultation about amending the UK feed ban to allow poultry PAPs to be used in pig feed, and porcine PAPs to be used in poultry feed. A similar amendment was successfully made to EU legislation in 2021. Bringing UK legislation in line will create a level playing field for UK farmers, renderers, feed manufacturers and others in the animal food chain.

Q Why is the UK government considering changing the regulations on PAP

A         Measures for the eradication of BSE must be regularly evaluated and adapted due to risk and new control tools. The industry has installed a range of innovations and quality control systems to guarantee product quality and safety.

Sustainable: using PAP’s can help to build a circular economy for the UK as in Europe. Safe animal by-products will not go to waste or into lower value applications. UK feed producers and farmers can be less dependent on alternatives such as imported, less sustainable soy and contribute to the UK net zero ambitions.

Safe: PAPs are safely sourced and processed from safe category 3 animal by-products. Modern tracking, tracing and quality control systems (HACCP) ensure safety at every stage. On top of this, sourcing, transporting and processing PAPs are under full veterinary control.

Healthy: The nutritional rich ingredients contribute to the development, growth and health of livestock and have additional animal welfare benefits.

Q      What were the changes to the rules on using PAPs in the EU in 2021?

A         Legislation effective from September 2021 permits PAPs from pigs to be used in poultry feed and PAPs from poultry to be used in pig feed in the EU. They also allow insect derived PAP to be used in pig and poultry feed.

Q         Changes in regulation are a ‘slippery slope’, how do we know that intra-species consumption won’t be allowed next and then feeding to cows and sheep?

A         The rules prohibiting PAPs in ruminant diets and intra-species consumption will not
change. Rules may only change to allow additional types of PAPs to be used in pig, poultry and aquafeed as and when this is proven to be safe.

CONSUMERS

Q         We have managed without PAPs in feed for 30 years, why change the rules now?

A         The rules on pig and poultry feed were brought in as a precaution. Scientific evidence and experience from Europe show that it is safe to make these changes to the rules. Farmers in Europe can use PAPs in pig and poultry production which puts UK farmers at a slight disadvantage because there remains a high level of trade in meat products between the UK and Europe.

Q         Do we make PAPs in the UK?

A         Yes, there are many facilities making PAPs in the UK. At present, PAPs are often exported rather than used locally because of the regulations. Changing the rules will mean that more PAPs can be used as animal feed in Britain, so we rely less on feed imports.

Q      Are PAPs environmentally friendly?

A         Reusing PAPs means that the whole animal is used, not just the parts we like to eat as meat.  Using PAPs in feed helps create a circular economy which reduces environmental damage from greenhouse gas emissions and land-use change associated with non-sustainably sourced plant-based protein sources like soymeal.

Q      How will I know if meat in the shop has been fed PAPs?

A.        PAPs are excellent feed ingredients. They comprise a small number of the nearly 2000 ingredients available to use in compound feed. Retailers decide on the specification of their meat products including feed and welfare standards to reflect the demands and expectations of their customers.

Q      Will it affect the price of meat in the shops?

A      PAPs are one of many feed ingredients. Using it in animal production will not make
         any appreciable difference in consumer meat prices one way or the other.

Q      Does the use of PAPs comply to Halal standards?

How do I know that I am not eating pork, when consuming chicken?

A         Poultry feed may contain 5–10% PAPs derived from pigs, which is digested by the bird and used for its own growth and development. Poultry producers have full control over which ingredients are used in feed to meet the needs of their customers. Halal certification schemes ensure meat is reared and slaughtered according to Islamic principles.

FEED VALUE AND AVAILABILITY

Q      Which products will be allowed in the market if the feed ban is lifted in the UK?

A         Poultry PAPs and porcine PAPs were already available for pet food and aquafeed. A wider approval will / does allow use in specific livestock diets: poultry PAPs in pig diets, and porcine PAPs in poultry diets.

Q         How much PAP can be used in pig and poultry feed?

A         Research suggests that 5–10% is the optimum inclusion rate for PAPs in feed. Feed technologists will use linear programming to determine the actual level.

Q         Can poultry oil and pork fat be used as well?

A         Rendered animal fat has never been prohibited for use in feed. Pork fat, poultry oil and fat of mixed animal species, are all produced exclusively from rendering Category 3 materials. They are a well acknowledged feed ingredient, and their use is completely independent from changes to the feed ban for proteins (PAPs).

Q      What is the available volume of PAPs for the feed industry?

A         PAPs volumes depend on animal slaughter volumes and ABP raw material availability. So higher volumes in the UK market will only arise if there is a dramatic increase in slaughter rates, which isn’t expected.

Q         Can we calculate the digestibility and composition of PAPs from before the feed ban came into effect?

A         It is advised to use new scientific data. Before the feed ban the composition and processing was different. Based on actual scientific research, there are average numbers available. You will find this information in white papers from our European Counterparts EFPRA, and in research reports. For additional specific information please contact a supplier.

Q         To what extent do the animal proteins used 25 years ago (before the feed ban) differ from the PAPs available now?

A Feed grade animal protein defined as PAPs are only made from Category 3 material, the safest type of by-products which are from healthy slaughtered animals and processed on segregated lines under strict veterinary controls in line with UK legislation. Before the introduction of legislation approximately 25 years’ ago, material from various sources became meat and bone meal. It did not have the same high standards for sourcing and processing as modern PAPs. In the UK meat and bone meal now only refers to material from Category 1 and 2 by-products which does not re enter the feedchain but are reused for technical purposes. 

Q      What is the price of PAPs?

A         This cannot be answered by EFPRA as every company determines its own commercial policy. Please contact a supplier.

ABOUT PAP PRODUCERS

Q         How can we trust that PAP producers, feed producers and farmers are following the rules?

A         The UK Competent Authorities regularly inspect production facilities to ensure the strict rules under the Animal By-Products and feed legislation are followed. In the meat supply chain, there are also various quality control, tracking and tracing systems in place and these accredited systems are independently audited by approved auditors.

Q      Why should we trust you?

A         As an industry, we recognize that trust in our products is essential.  Without trust our industry cannot exist in the long run. Consumers need to know their food and the feed for animals are safe. We are guided by a scientific approach to production and safety using technology and testing to ensure our products meet the high standard required.

Q         Is the change in regulation simply about profitability for producers?

A         Developing higher value markets for PAPs reflects a wider move to a more sustainable, circular economy as well as being a business opportunity. Using all the parts and pieces of an animal without wasting valuable materials is inherently more sustainable. Using these materials as high value feed contributes to building a circular economy which is beneficial for everyone.

Q         Do rendering companies have dedicated plants or specific processing lines in place to produce PAPs?

A         Every company can decide if they want to produce and offer PAPs and how they will implement the UK regulations for processing which require segregated facilities for producing PAPs. Competent authorities have to approve the production facilities.

ANIMAL SAFETY

Q.       Wasn’t Mad Cow Disease (BSE) caused by cows eating feed containing other animals?

A         Mad Cow Disease was the most well-known transmissible spongiform
encephalopathy (TSE). The disease was a problem 20–30 Years ago. It was caused by the intra-species consumption of the brain and spinal column which is now classified as specified risk material and must be disposed of as Category 1 material. The contemporary animal protein industry has a wide range of measures and quality systems in place to produce safe ingredients for compound feed.

Q      How do you prevent BSE happening again?

A      The rendering industry takes a range of measures to do this:

·      PAPs are made from safe Category 3 animal by-products originating from healthy slaughtered animals. There is veterinary surveillance of the entire reprocessing chain.
·      Producers use segregated processing lines to avoid cross contamination (intra-species contact and material of different risk categories). All processing methods guarantee safe products at the highest level.
·      PAPs are only approved for omnivorous and carnivorous animals. PAPs are not used to feed ruminants such as sheep and cows
·      PAPs are safe. Production processes are carried out under strict supervision of quality management systems and controls. Audits are executed on a regular basis.
·      PAP producers follow stringent legislation which ensures livestock and consumers have healthy feed and food. National competent authorities regularly inspect facilities producing PAPs.

Q      Are PAPs just a new name for meat and bone meal (MBM)?

A         PAPs are made only from Category 3 material, the safest type of by-products which are from healthy slaughtered animals and processed on segregated lines under strict veterinary control in line with EU / UK legislation.

Before the introduction of legislation approximately 20 years’ ago, there were no categories for animal by-products. Material from various sources became meat and bone meal. It did not have the same high standards for sourcing and processing as the PAPs that are now available.

The term meat and bone meal is still used in the animal by-products industry. In Europe and the UK, meat and bone meal only refers to material from Category 1 and 2 by-products. They do not re-enter the feed chain but are reused for technical purposes, such as biofuel and Category 2 MBM fertiliser.

Outside Europe and the UK, legislation is different, meat and bone meal can still refer to material from a range of sources.

Chairman's Update June 2024

It’s time to take a moment and review the first six months of 2024.

At the beginning of the year the first phase of the Border Target Operating Model (BTOM) was introduced for imports to the UK. There have been some teething problems as you would expect, but the introduction of the changes in staggered phases has been easier to manage than the post Brexit experience of Health Certificates and Physical Checks on our exports being mandatory from Day One. There is still some work to do to complete the process and some unanswered questions in relation to movements of material to Great Britain from the Republic of Ireland.

The review of UK Best Available Techniques (BAT) for preventing and minimising the environmental emissions and impacts from our industry is one of the most important challenges we face and has now commenced, with an introductory meeting and the first questionnaire to complete. This will set the scene for discussions to come and FABRA’s members will be preparing for participation in the Technical Working Group activities later this year. The process will define mandatory standards for emissions, consumptions, management systems and processing techniques for rendering and slaughterhouses.

The UK General Election in July is already having an impact on our work as Government Departments withdraw from meetings and consultations in accordance with Civil Service rules. However, we are pleased to note that the UK’s application for Negligible BSE Risk Status is still on track to be submitted  at the end of July 2024. Unfortunately, the planned consultations on potential amendments to the Animal By Products Regulations to allow for non-ruminant (pork and poultry) PAP to be reintroduced into certain animal feeds will have to wait. We will be contacting Ministers as soon as they are in post after the Election to chase this up and to discuss the issues of energy taxes and Net Zero, which remain challenging for the sector.

Sustainability remains a widely debated topic and FABRA has contributed data to a European study to review the carbon footprint of rendered products. This updates an earlier study and also looks at the footprint of ABP derived protein meals and fats compared to plant sources. FABRA’s Technical Advisor has also been active in the Sustainability Committee of our European counterparts – EFPRA. Below is a link to their interactive Sustainability Charter.
https://www.sustainability.efpra.eu/ 

Jane Brindle
Chairman
FABRA UK

List of Acronyms

ABP – Animal By ProductsBAT – Best Available Techniques
BTOM - Border Target Operating Model
DEFRA – Department for Environment, Food and Rural Affairs
EFPRA – European Fats and Proteins Rendering Association
PAP – Processed Animal Protein