Animal By-Products in Pet Food

Thoms Meyer

tmeyer@fediaf.org

Badk in 1990, the European legislator regulated which parts of an animal may be used for pet food production. The terms used sent shivers down the spine: "animal waste" and "low-risk material". People looking for a meal rich in iron and vitamins were quite happy to eat beef livers, but the same liver, as surplus from the human food chain, suddenly became "waste" with a definite connotation of "risky". But already then, the European pet food industry had its voluntary code to use only animal protein derived from slaughtered animals passed as fit for human consumption.

The same 1990s legislation applied to farm feed, some of which included a certain proportion of animal protein in the recipes. We all remember the TV-pictures of trembling "mad" cows. When it appeared that the animal protein fed to herbivores was the cause and that vCJD was linked to BSE a plethora of legislation was rapidly enacted to protect the human food chain from the lethal prion.

These measures lay down what may not be used by the meat processing industry, including pet food manufacturing, banning the specified bovine, caprine and ovine tissues believed to carry the BSE/TSE prion. This is now all neatly regulated in the TSE Regulation 999/2001/EC with manifold amendments.

Fediaf welcomed this legal clarification of its existing voluntary raw materials policy.

The Commission then thought "would it not be nice to define better than in 1990 what may be used" and the concept of an animal by-product regulation was born. It then took five long years to complete the legislative process. 16.100.000 tons of animal by-products are generated annually in the EU; not surprising considering that humans eat only about 54% of a slaughtered cow, or 62% of a pig.

100 legalptechnical pages to regulate an annual 16 million tons of products do not seem exaggerated. The key points of Regulation 1774/2002/EC for pet food production confirm Fediaf's longstanding position and are :

• Only material from animals passed as fit for human consumption

• Re-enforcing external and in-house controls/traceability/obligatory HACCP

• No "cannibalism" (animal protein from one species may not be fed to the same species, except for fish food)

Pet food, its processing and microbiological standards are clearly defined:

• "canned pet food "(in hermetically sealed containers)

-          Fc value 3

• "other than canned" (dry and semi-moist)

-          90℃ throughout

-          salmonella and enterobactericeae testing

• "raw pet food"

-          only full human food grade material

-          only processing allowed : freezing

-          salmonella and enterobactericeae testing

• "dogchews" (not only for dogs)

-          heat treatment to destroy pathogens

-          salmonella and enterobactericeae testing

As mentioned earlier, most importantly the Regulation clarifies what animal material may be used:

• parts from animals declared fit for human consumption, but not intended for human consumption

This is further specified, but it is now positively clarified that all material of animal origin used in pet food comes from healthy animals and follows microbiological standards.

Regulation 1774/2002/EC could appear burdensome because of requirements on in-house controls, traceability or full HACCP –but this is the price to pay to ensure the constant supply of safe pet food.