5 Must-Have Features in a Reliable Feed Additive Supplier

According to feed law, additives are included in the definition of feed, but due to the various special features they are presented separately. Historically, the first comprehensive legal summary of common additives was made with Directive 70/524/EEC, which was only replaced more than three decades later by the current Additives Regulation (EC) /. The currently valid definition for additives is: "Feed additives" are substances, micro-organisms or preparations, other than feed materials or premixtures, which are intentionally added to feed or water, in particular to fulfil one or more of the functions mentioned in Article 5(3). In comparison, feed is described according to Regulation (EC) 178/ as follows: "Feed" means any substance or product, including additives, whether processed, partially processed or unprocessed, intended for oral animal feeding.

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Another important definition is that of "oral animal feeding": this is the intake of feed into the animal's digestive tract through the mouth or beak in order to meet the nutritional needs of the animals or to maintain the productivity of normally healthy animals. In addition to a separate regulation in Regulation (EC) 767/, this text is the basis for the fact that, apart from other misleading claims, all statements on effects of feed additives in the direction of prevention or therapy of diseases are inadmissible, unless they concern the scope of application of coccidiosis defence substances (coccidiostats) or that of feed for specific nutritional purposes (dietetic feed) according to Regulation (EU) /354.

Additives are the only product group within feed for which authorisation is required. For this purpose, an application must be submitted to the European Commission and accompanied by the required application documents or those prepared in accordance with Regulation (EC) 429/. The subsequent procedure follows a specific timetable, but it is difficult to estimate the exact time horizon until an authorisation regulation is available. Experience shows that a procedure is rarely completed before one year has elapsed and can also take several years. Further details and information on authorisation can be found on the website of the European Food Safety Authority (EFSA) and on the website of the Federal Office of Consumer Protection and Food Safety in Germany.

Feed additives are a very extensive and heterogeneous group, which is divided into five categories, which in turn consist of various functional groups (for a complete breakdown, see Annex I of Regulation (EC) /):

1. technological additives (preservatives, antioxidants, binders, emulsifiers, stabilisers, gelling agents, silage additives, anti-caking agents, release agents, substances to reduce mycotoxin contamination (mycotoxin reducers), hygienising agents, etc.),
2. sensory additives (the most extensive category of colourings and flavourings in products),
3. nutritional additives (vitamins, trace elements, amino acids, urea, etc.),
4. zootechnical additives (digestibility enhancers, gut stabilisers, substances favourable to the environment, other zootechnical additives and agents to stabilise the physiological condition),
5. coccidiostats and histomonostats (currently only coccidiostats are authorised).

The assignment of an additive to a category and functional group is quite easy to recognise on the basis of the identification number: For example, silage additives always start with the string 1k, binders with 1g and vitamins with 3a. However, there are also products with authorisations for several functional groups (e.g. individual amino acids that can also be used as flavourings), but the number only indicates one of the possible groups. The EU Register of Additives contains a clear presentation of all currently authorised additives with the linked original authorisation regulations. It should be noted that the register itself is only informal; only the respective authorisation regulations are legally binding.

The register also lists products that still have the old E-numbers or only numbers. This does not mean, however, that all food additives are also permitted or that groups such as phytogenic flavourings can be used in principle. These "old products" are additives for which an application for authorisation as a feed additive had to be submitted before 8 November and for which the procedure could not yet be completed in the course of the re-evaluation of all additives. Therefore, only those products for which an application for authorisation and the necessary application documents are available may be used until the re-evaluation is completed.

Intended use:

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With regard to the intended use, the following points, among others, must be observed:

• For binders (1g), the definition according to Annex I of the Ordinance on Additives is decisive. According to this, these are technological substances which increase the tendency of the particles of a feed to adhere. This is primarily a matter of feed quality. In connection with binders, it is therefore not permitted to advertise their binding of metabolic products, harmful gases or toxins, as this would be a violation of the permitted use and the authorisation conditions.
• Additives to reduce mycotoxin contamination(1m) may also be called mycotoxin reducers in a compound feed. However, their use is only permitted if the feed law guideline or limit value for the respective mycotoxin is complied with in the compound feed concerned. In addition, it is not permissible to use the term toxin reducer in the context of product labelling.
• In the case of substances that have a favourable effect on the environment, there is only one approved product, 3-NOP (3-Nitro-Oxy-Propanol, 4c1). The application of the binding of harmful gases of different types (ammonia, methane, etc.) in connection with other substances, such as clay minerals or flavouring substances, is therefore not permissible.
• In the case of agents for stabilising the physiological state, there are no approved products yet. However, there are first applications with the aim of using e.g. CBD as an additive to improve resistance to stress factors. In connection with stress, a corresponding special nutritional purpose (dietary feed) for dogs and pigs can be claimed if the legal requirements in this regard are met.

In the case of additives and premixtures (mixture of two or more additives or at least one additive with a carrier), the legal tolerances according to Annex IV of Regulation (EC) 767/ are not applicable, as these only apply to feed materials and compound feed. This results in less leeway in the marketing of these products. In the event of a control by the feed monitoring authorities, only the analytical measurement uncertainty of the test method used specifies the permissible range of deviation from the declared content. Labelling regulations for additives and premixtures can be found in Article 16 of the Ordinance on Additives.

Note for farmers:

The following legal requirements must be met when using additives:

When buying in compound feed, there are no specifications as to which additives may be contained in it.

1. If the farmer is only a primary producer according to Regulation (EC) 183/ on feed hygiene requirements, he may only buy in silage additives and use them for ensiling.
2. For the own production of compound feed with various additives or premixes, an increased documentation requirement applies in the form of an obligation to keep records on the products purchased and used, the recipe of the mixture produced and the intended use of the compound feed produced. In this case, amino acids, urea, flavourings, emulsifiers, antioxidants without maximum content, preservatives, acidity regulators, binders, and flow and coagulation aids may be used. Under these conditions, the LFBIS number is still sufficient for registration as a feed business operator. The feed control is carried out by the provincial control authority (usually the competent official veterinarians of the district administrative authorities).
3. If additives other than those mentioned under points 2 and 3 (e.g. vitamins, trace elements, enzymes, microorganisms) or premixtures containing such additives are used for own compound feed production, registration or even authorisation with the Federal Office for Food Safety (BAES) is required. The farmer concerned is then also subject to the control of this federal authority. There are currently only very few farms that are registered with the BAES (e.g. HBLFA Raumberg-Gumpenstein) and no farm in Austria that has an authorisation.
4. Additives may only ever be used under those conditions for which they are authorised according to the authorisation ordinance. This includes, on the one hand, the target animal species for which the product is intended and also the respective feed type for which the additive was applied for. As a rule, the use is only permitted in compound feed, the usability in straight feed or via the drinking water must be explicitly stated. Furthermore, for individual additives it is stipulated in the authorisation conditions that they may only be introduced into the compound feed as a premix. This applies in particular to products that may cause a higher health risk if mixed in inhomogeneously (e.g. trace element compounds).

Additives are naturally present in various feed materials and can thus have additive-like effects. Well-known examples of this are vegetable oils with vitamin E or animal by-products with vitamin D. Likewise, many macro-components contain different trace element contents or essential amino acids. When using and advertising these products, care must be taken to ensure that the actual function of a feed material as a nutrient supplier or the positive effect on digestion is in the foreground; other advantages or effects for animal nutrition can be cited as a "side effect", so to speak, if this can be proven by scientific data (literature, studies). It becomes problematic with regard to the classification under feed law if straight feeding stuffs are exclusively associated with effects that represent a use subject to authorisation for additives or even medicinal products. For example, alleged positive effects on the environment due to the binding/avoidance of harmful gases by various wood products (e.g. lignocellulose) or promises of healing by herbs, parts of herbs or herbal mixtures.

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