ARCHIVED - Proposal – Required Nutrient Guarantees

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June 2016

Purpose

The Canadian Food Inspection Agency (CFIA) has embarked on a comprehensive change agenda to strengthen its foundation of legislation, regulatory programs, and inspection delivery. These directions set the context for the renewal of the federal Feeds Regulations (Regulations).

The goal of modernizing the Regulations is to develop a modernized risk- and outcome- based regulatory framework for feeds which:

  • safeguards feeds and the food production continuum;
  • attains the most effective and efficient balance between fair and competitive trade in the market; and
  • minimizes regulatory burden.

The modernization of the Regulations is providing the opportunity to review the nutrient guarantee requirements for feed labels currently set out in the Regulations (Table 3, Schedule I). The modernization also identifies possible updates or amendments to the current requirements, including the use of incorporation by reference to allow for more flexible and timely modifications of the requirements in the face of changing marketplace conditions.

Current Situation

At present, all livestock feeds manufactured, sold, or imported into Canada must include a label containing an accurate statement of the guaranteed analysis in respect of the feed. Table 3 of Schedule I of the Feeds Regulations specifies those nutrients that must be guaranteed on a label to ensure all feeds of a similar type provide the purchaser with relevant information for the safe and efficient use of the product, as per sub-section 24.(1) of the Regulations:

Subject to subsections (2) and (3), the guaranteed analysis required by these Regulations for the purposes of the labelling of a feed shall include the appropriate particulars set out in Column II of an item of Table 3 of Schedule I for the feed described in Column I of that item.

Furthermore, section 30 of the current Regulations further stipulates that only those nutrient guarantees indicated in Table 3 of Schedule I are permitted to be included on a feed label:

The label for a feed shall not show a guarantee for a nutrient that is not required to be guaranteed unless

  1. the amount of the nutrient guaranteed is such that, when used as directed, the complete diet including the feed will supply at least the minimum generally accepted requirements for that nutrient for the intended class of livestock; and
  2. the guarantee is approved in writing by the Director as conveying useful information to the feed purchaser.

Consequently, feed manufacturers wishing to provide additional nutrient guarantees on their livestock feed label, other than those stipulated in Table 3 of Schedule I for that species and type of feed, are subject to mandatory registration of the resulting product and must provide information to support each additional guarantee during the pre-market assessment and authorization process conducted by the CFIA.

Proposal

As indicated in the Feed Regulatory Renewal Consolidated Modernized Framework Proposal – November 2015, it is proposed that the current approach with respect to requiring specific nutrient guarantees for specific feed types outlined in Table 3 of Schedule I will remain. Even so, these requirements would be examined and changes recommended, as applicable, to ensure that the labeled nutrient guarantees continue to provide purchasers with useful information.

Appendix I includes the proposed amended Table 3 of Schedule I, indicating the proposed required nutrient guarantees for specific feed types. The CFIA will explore incorporating the amended table by reference. However, if these required guarantees are expected to remain relatively static over time, the table may be retained in the Regulations as an outcome of this review process.

Incorporation of documents by reference is a drafting technique that brings the content of a document into a regulation, without the need to reproduce the document in the regulation itself. The CFIA has developed the Incorporation by Reference Policy to articulate a clear and comprehensive process for identifying documents that could be incorporated by reference.

The nutritional information contained in the required guaranteed analysis of a feed label is essential to ensure that producers are able to select feeds that will best suit their livestock needs, as well as to ensure that feed products are used safely and efficiently. However, additional nutrient guarantees, other than those listed in Table 3 of Schedule I, may be equally important in supplying meaningful and useful information to the purchaser.

The Regulations will continue to specify nutrient guarantees that must be included on a feed label based on the intended species and feed type. Further, it is proposed that:

  • nutrient guarantees, in addition to those required by regulation, would be permitted on livestock feed labels in the future;
  • a list of approved additional nutrient guarantees would be established and incorporated by reference in the Regulations;
  • the guarantees must be truthful, verifiable, and not misleading;
  • only approved sources of the nutrient(s) would be permitted; and
  • the inclusion of additional guarantees on a feed label would be voluntary (i.e., not required).

Appendix II includes a proposed list of additional guarantees that may be included on a feed label. The proposed list does not include all possible guarantees as supplying guarantees for some nutrients or ingredients used in feeds may conflict with other policies and approaches. In some cases, additional guarantees would not be considered to provide information useful to the user (e.g., a guarantee for vanadium) or may identify nutrients with no clear feed purpose (e.g., omega-fatty acids). There will be future opportunities to add further guarantees to the list as science, industry practices, and policies change.

Anticipated Outcomes

This modernized regulatory approach to allowing additional nutrient guarantees on a voluntary basis will:

  • give the feed industry the flexibility to label feeds with nutrient guarantees so as to meet their customers' needs without requiring pre-market assessment and authorization;
  • allow for timely updates to the standards as new information for specific nutrients is provided;
  • allow the CFIA to maintain regulatory oversight for label information to confirm that feeds are suitable for their intended purpose; and,
  • reduce the regulatory burden with respect to the registration of livestock feeds where additional nutrient guarantees can be provided on product labels.

It is important to note that any feed label containing a nutrient guarantee that is not listed in Table 3 of Schedule I or in the list of approved additional nutrient guarantees, will continue to require mandatory registration prior to sale in the marketplace.

Have your say

The CFIA is seeking feedback on the proposal to modify the regulatory requirements related to nutrient guarantees on livestock feed labels:

  • Are the proposed revised nutrient guarantees required on feed labels appropriate?
  • Do you have any concerns with the proposal of allowing voluntary nutrient guarantees for livestock feed labels?
  • Are there nutrient guarantees that should be added to the list in Appendix II?
  • Would the proposed amendments to the Feeds Regulations be effective in protecting human and animal health and the environment?
  • Are there options not mentioned in this proposal that should be explored?
  • Any additional feedback?

We encourage you to provide your input and feedback, which is critically important to the success of the regulatory modernization initiative. Written comments may be forwarded by July 15, 2016 to:

Sergio Tolusso
Canadian Food Inspection Agency
Animal Feed Division
59 Camelot Drive
Ottawa, ON K1A 0Y9
Email: Sergio.tolusso@inspection.gc.ca
Fax: 613-773-7565

Appendix I – Revised Required Nutrient Guarantees (Proposed amended Table 3 of Schedule I)

Item Column I
Feed Article
Column II
Particulars of guarantee in accordance with section 24 (see note)
Column III
Target Species
1. A complete feed; a feed designed to replace whole milk; and a feed (excluding a chop feed) ground or crushed or in meal, cake, pellet, crumble, or biscuit form not otherwise provided for, and to which the particulars specified are appropriate 1) Minimum per cent of crude protein, which shall include the equivalent crude protein content. 1) All species
2) Maximum per cent of equivalent crude protein from non-protein sources intentionally or purportedly present. 2) Ruminants
3) Minimum per cent of crude fat. 3) All species
4) Maximum per cent of fibre expressed as crude fibre or acid detergent fibre. 4) All species
5) Maximum per cent and kind of grit if intentionally or purportedly present. 5) Poultry
6) Minimum per cent of the following: sodium (Na), calcium (Ca), phosphorus (P). 6) All species
7) Minimum amount of zinc (Zn) and copper (Cu) in milligrams per kilogram. 7) Swine
8) Minimum and maximum amount of copper, in milligrams per kilogram. 8) Sheep
9) Minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product. 9) All species
10) If the feed is designed to replace whole milk, the minimum per cent of protein from milk sources. 10) Mammalian species
11) Minimum per cent of crude fibre. 11) Rabbits and horses
12) Minimum selenium in milligrams per kilogram, if selenium is intentionally or purportedly present. 12) All species
13) Minimum Vitamin C in miligrams per kilogram if intentionally or purportedly present. 13) Salmonid fish
2. A supplement or macro-premix If intentionally or purportedly present;
1) Minimum per cent of crude protein, which shall include the equivalent crude protein content. 1) All species
2) Maximum per cent of equivalent crude protein from non-protein sources. 2) Ruminants
3) Minimum per cent of crude fat. 3) All species
4) Maximum per cent of fibre expressed as crude fibre or acid detergent fibre. 4) All species
5) Maximum per cent and kind of grit if intentionally or purportedly present. 5) Poultry
6) Minimum per cent of the following: calcium (Ca), phosphorus (P), magnesium (Mg), sulfur (S), sodium (Na) or potassium (K). The minimum milligrams per kilogram of iodine (I), iron (Fe), copper (Cu), manganese (Mn), zinc (Zn), cobalt (Co) or selenium (Se). 6) All species
7) The actual amount of copper in milligrams per kilogram. 7) Sheep
8) The maximum amount in milligrams per kilogram of fluorine (F). 8) Cattle, Sheep, Horses
9) The minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product. 9) All species
3. A mineral feed 1) Minimum per cent of the following if any is intentionally or purportedly present: calcium (Ca), phosphorus (P), magnesium (Mg), sulfur (S), sodium (Na) or potassium (K). The minimum amount in milligrams per kilogram of iodine (I), iron (Fe), copper (Cu), manganese (Mn), zinc (Zn), cobalt (Co) or Selenium (Se) intentionally or purportedly present. 1) All species
2) Maximum amount in milligrams per kilogram of fluorine (F). 2) Cattle, sheep, horses
3) The maximum amount of copper if any is intentionally or purportedly present, in milligrams per kilogram. 3) Sheep
4) In the case of a mineral feed containing vitamins, the minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product, the minimum number of micrograms of vitamin B12 and biotin per kilogram of product and the minimum number of milligrams of any other vitamins per kilogram of product, if intentionally or purportedly present. 4) All species
4. A micro-premix 1) Minimum amount in milligrams per kilogram of the following if any is intentionally or purportedly present: iodine (I), iron (Fe), cobalt (Co), manganese (Mn), zinc (Zn), copper (Cu) or selenium (Se). 1) All species
2) Maximum amount of copper if any is intentionally or purportedly present, in milligrams per kilogram. 2) Sheep
3) In the case of a micro-premix containing vitamins, the minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product, the minimum number of micrograms of vitamin B12 and biotin per kilogram of product and the minimum number of milligrams of any other vitamin per kilogram of product, if intentionally or purportedly present. 3) All species
5. Salt (Sodium Chloride) to which has been added one or more of the following, namely, an iodine compound, an iron compound, a copper compound, a manganese compound, a zinc compound, a cobalt compound or a selenium compound (Trace Mineral Salt Feed). Minimum per cent of salt (NaCl) and the minimum amount in milligrams per kilogram or any of the following that is intentionally or purportedly present: iodine (I), iron (Fe), copper (Cu), manganese (Mn), zinc (Zn), cobalt (Co) or selenium (Se). All species
6. A mixed feed not otherwise provided for in this Table Guarantees to describe the usefulness of the feed. All species

*Note: fibre may be spelled "fiber"

Appendix II – Proposed Additional Voluntary Guarantees

Guarantee Guarantee Type
(Minimum, Maximum, Added or Actual)
Units Conditions
Energy Min
Max
Actual
Kcal/kg
Cal/kg
Kjoules/kg
May be further specified as Net Energy (NE), Digestible Energy (DE) or Metabolizable Energy (ME)
Crude Protein Any % N/A
Crude Fat Any % N/A
Fibre Any % Specify if it is:
Crude fibre
Acid Detergent Fibre (ADF)
Neutral Detergent Fibre (NDF)
Ash Min
Max
Actual
% Fish feeds only
Moisture Min
Max
Actual
% N/A
Salt Any % N/A
Amino acids Min
Max
% May not guarantee "amino acids", must specify the amino acid being guaranteed (e.g., lysine)
Vitamin A Any IU/kg N/A
Vitamin D Any IU/kg N/A
Vitamin E Any IU/kg N/A
Vitamin C Any mg/kg N/A
Calcium Any % May be expressed as Ca in the guaranteed analysis.
Phosphorus Any % May be expressed as P in the guaranteed analysis.
Magnesium Any % May be expressed as Mg in the guaranteed analysis.
Sulphur Any % May be expressed as S in the guaranteed analysis.
Sodium Any % May be expressed as Na in the guaranteed analysis.
Potassium Any % May be expressed as K in the guaranteed analysis.
Iodine Any mg/kg May be expressed as I in the guaranteed analysis.
Iron Any mg/kg May be expressed as Fe in the guaranteed analysis.
Copper Any mg/kg May be expressed as Cu in the guaranteed analysis.
Manganese Any mg/kg May be expressed as Mn in the guaranteed analysis.
Zinc Any mg/kg May be expressed as Zn in the guaranteed analysis.
Cobalt Any mg/kg May be expressed as Co in the guaranteed analysis.
Selenium Any mg/kg May be expressed as Se in the guaranteed analysis.
Fluorine Min
Max
mg/kg May be expressed as F in the guaranteed analysis.
Chromium Any mg/kg May be expressed as Cr in the guaranteed analysis.
Beta-carotene Min mg/kg Label must also guarantee Vitamin A. The Vitamin A guarantee must indicate that it includes Vitamin A activity from beta carotene.
B12 Any µg/kg May be expressed as cobalamin in the guaranteed analysis
Biotin Any µg/kg N/A
Thiamine Any mg/kg May be expressed as Vitamin B1 in the guaranteed analysis.
Riboflavin Any mg/kg May be expressed as Vitamin B2 in the guaranteed analysis.
Niacin Any mg/kg May be expressed as Vitamin B3 in the guaranteed analysis.
Pantothenic Acid Any mg/kg May be expressed as Vitamin B5 in the guaranteed analysis.
Pyridoxine Any mg/kg May be expressed as Vitamin B6 in the guaranteed analysis.
Folic Acid Any mg/kg May be expressed as Vitamin B9 in the guaranteed analysis.
Menadione Any mg/kg May be expressed as Vitamin K3
Menadiole diacetate Any mg/kg May be expressed as Vitamin K4
Choline Any mg/kg N/A
Inositol Any mg/kg N/A
Betain Any mg/kg N/A
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