Final Report on Feed

Summary

The expert group for technical advice on organic production (EGTOP; thereafter called „the Group‟) in replying to point a) of the mandate concerning substances assessment concludes on the basis of the knowledge available in the group and information provided with the dossiers and by the Commission that: E 535 Sodium ferrocyanide anti-caking material, should be approved for use as a feed additive in salt for organic animal feed, subject to:
- a maximum dose rate of 20 mg/kg NaCl (the maximum defined for human food) and
- a limited time period, in order to provide a legal basis for current practice in the short term and to encourage the adoption of preferred carbonate alternatives longer term. E 566 Natrolite-Phonolite anti-caking material should be approved for use as a feed additive in organic animal feed, subject to the limit of 25,000 mg/kg complete animal feed specified in EC Reg. 739/2000. E 551a Silicic acid by precipitation anti-caking material should not be approved for use as a feed additive in organic animal feed on the basis of available information about need given the available, more natural alternatives. Further information on this issue should be provided to support the application. E 568 Clinoptilolite anti-caking material should be approved for use as a feed additive in organic animal feed, subject to the limit of 20,000 mg/kg complete animal feed and the livestock classes specified in EC Reg. 1810/2005. E 237 Sodium formate preservative should be approved for use as a feed additive in organic silage, subject to the outcome of the review of the authorisation of this product under Articles 4 and 7 of Regulation 1831/2003 currently in progress.
If approved:
- it should be considered whether formic and propionic acids should be deleted from Annex VI to Commission Regulation (EC) 889/2008;
- the same restrictions relating to weather conditions and silage quality as currently apply to formic and propionic acids under the organic regulations should apply;
o the concept of „difficult‟ silages and/or „poor‟ weather conditions‟ that would determine eligibility to use the products should be clarified. Initial dry matter content or sugar content of the forage might be a basis for this. Humic acid substances are not currently authorised as a feed additive under EU regulations so they cannot be considered for use as such in organic farming. Their classification as feed material was not considered to be appropriate by the Group, which also noted their current designation as pharmacologically active substances with possible implications for animal health.
In reaching these conclusions, the Group considered that compliance with the organic regulation needs to be assessed according to several criteria which are summarised in Annex 1.
The Group in replying to point b) of the mandate concerning the template for the member states dossier with respect to animal feed materials, feed additives, certain products used in animal nutrition and processing aids, developed the document presented in Annex 2 to this report. This includes a section incorporating the criteria for assessment of consistency with the EU organic regulations. The Group considered that it would be helpful to develop some interpretative guidelines to support the dossier template.
The Group in replying to point c) of the mandate concerning technical aspects of transition to 100% organic feed requirements for non-ruminants concluded that while there are technical solutions that can be implemented in the short to medium term, there is a need for further research on alternatives and knowledge transfer, a need to reflect on the nature and principles of organic non-ruminant production (whether semi-industrial or extensive), and a need to consider continuing with derogations for a short period limited to specific ages and types of non-ruminants and specific feedstuffs.