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AgVetLink Special issue for Veterinarians May 2006

Animal Feeds

For several months now the ACVM Group has been working with the New Zealand Standards and Policy Groups of NZFSA to prepare a public discussion document covering the regulatory control of animal feeds. It should be noted that ‘animal feeds’ include all oral nutritional compounds for all kinds and classes of animals, including dog and cat foods as well as stock feeds.

Schedule 4 requirements

As you will already know, animal feeds and feed supplements are exempt from registration under the ACVM Act, but the products and their manufacture must comply with the minimum standards set out in Schedule 4 of the ACVM Regulations 2001. This means that they must comply with:

• minimum labelling requirements;

• ‘fit for purpose’ criteria;

• restriction to general health claims related to a nutritional benefit only; and

• restrictions on the inclusion of therapeutic or pharmacological substances and only feed additives that are ‘generally regarded as safe’ (GRAS).

Codes of practice

The ACVM Group has not been prescriptive about what in detail must be complied with or how compliance must be achieved. In addition, we have not imposed verification requirements, leaving the industry to establish best practices in their own codes of practice (one already approved for the New Zealand Feed Manufacturers Association and one being developed by the New Zealand Petfood Manufacturers Association).

Compliance

The ACVM Group investigates suspicions and allegation of non-compliance, and expects to see evidence of taking due care to comply with the Regulations or prosecutions may be taken. The Group’s experience is that, in general, there is a high level of compliance and very few ‘adverse events’ related to non-compliant animal feeds. This has given the Group a reasonable level of confidence that risks are being managed adequately.

Different regulatory control

One main reason for the review is that the dog and cat food sector of the industry is regulated under the Animal Products Act 1999, which sets quite different regulatory obligations with a higher level of regulatory intervention because of the animal products content (meat and offal) in their products.

This difference in regulatory control has raised questions such as:

• What is the appropriate level of regulatory control and intervention for animal feeds?

• Are there grounds for different levels of control for different kinds of animal feeds or should they all be regulated in the same way?

The ACVM Group (and NZFSA as a whole) considers that there are grounds for variable levels of control based on the potential risks posed by different kinds of products. However, it also considers that the level of control should be no more than what is necessary and sufficient to manage the relevant risks.

Discussion document

The public discussion document, which should be released for comment soon, will be available on the website (www.nzfsa.govt.nz/acvm). It proposes a regulatory scheme that tries to strike a balance between assuring adequate mitigation of risks and the inevitable cost of complying with any regulatory requirements. It considers the relative risk profiles of different kinds of products and suggests the kind of regulatory intervention that would be appropriate.

It is hoped that veterinarians will provide comment on the proposals based on their experience.