Feed Labelling – Modernized Regulatory Framework Proposal – Consultation Summary – Respondent Comments and CFIA Responses
What We Heard
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|Category of Respondent||Distribution|
|Feed Industry - Association||7|
|Feed Industry – Individual||12|
|Livestock Producer – Association||2|
|Livestock Producer – Individual||2|
|Other feed inputs||4|
|Government (Canadian federal/provincial)||3|
Thirty sets of comments were received. The feed industry association comments represent Canadian and American commercial feed manufacturers, as well as some of the larger feed ingredient groups. The Canadian feed manufacturers association represents 90 percent of commercial feed manufactured in Canada, while the US association represents about 75 percent of commercial feed manufactured in the US.
Key Respondent Messages
The feed industry associations indicated that they consider the requirements in the proposal will not reduce the compliance burden and will be costly for the industry. The general comments from the other respondents were a split between a general agreement with the proposal and concerns about compliance burden.
Very few comments were received from Livestock Producers, either from organizations or individuals. While these groups represent the a large proportion of purchasers of feeds, the limited comments received focussed mostly on a desire for ingredient listings on labels, controls over imports, and that regulatory burdens are minimized.
The comments received on the proposal pertained to all of the proposed labelling requirements for feeds. Clarification was requested with respect to a number of the proposed requirements. The CFIA responses to respondent comments are set out below.
Mandatory Labelling Requirements (Section 4.1)
Respondents raised concerns in this section of the proposal with regards to the provision of manufacturer information, list of ingredients and lot numbers on labels. All of the subsections did receive comments and a few questions for clarification were received. Respondents were not in favour of requiring the actual location of manufacture to appear on feed labels and requested that a head office or corporate address be allowed instead, especially for companies that have multiple manufacturing facilities. They indicated that a corporate contact would be able to provide a customer with information better than an individual facility.
Respondents raised concerns about requiring a list of ingredients on all feeds, however most indicated that allowing the use of collective terms would help. A couple of respondents representing individual livestock producers raised concerns that the use of collective terms would allow feed companies to not disclose specific ingredients.
Respondents were generally in agreement with the requirement for a lot number on feed labels. Concerns were expressed for feeds that are in bulk or made via a continuous production system. In both these cases there are challenges with differentiating one specific "lot" from the next as there is no clear break between lots.
The CFIA appreciates the concerns raised with regards to requiring a location of actual place of manufacture on a feed label. The manufacturer contact information is intended to provide information to the consumer so they can contact the manufacturer if they need to, and to provide information so that the CFIA can identify where a feed was manufactured in the event of a feed investigation. The CFIA is exploring options which would achieve the desired outcome of the company being able to determine where a specific product was manufactured to facilitate traceability. The combined use of a lot number and manufacturer contact information may be sufficient to achieve this. A head office contact would be acceptable provided the lot number can be used to indicate the facility where the product was made. If the lot number does not provide that information, CFIA proposes that the actual place of manufacture would be required on the label.
The list of ingredients provides useful information to the purchaser of the feed and will be especially necessary as the requirement for feed registration will be limited. The CFIA proposes to require the list of ingredients, in descending order on the label for feeds. This requirement is consistent with the Codex guidance, the US, and other international jurisdictions. The CFIA proposes that the use of collective terms will be allowed. Collective terms will be clearly defined and the CFIA will further consult with stakeholders on what is included under the terms.
The CFIA appreciates the concerns that were raised with regards to lot number. It is not anticipated that the size of a batch or lot would be specified in regulation, and it would be up to the feed manufacturer to determine the best way to assign lot numbers to their products. Lot numbers and product identification are part of the traceability and recall components of the preventive control plans proposed in the Hazard Identification and Preventive Controls module.
Additional Labelling Requirements (section 4.2)
Respondents were opposed to the requirement for bilingual labelling. Many indicated that feed mills often serve a small local area where there is no demand for a bilingual label. Concerns included, the cost to both create the bilingual label and to have information translated, access to translators, the accuracy of translations, and that this may result in making labels larger and more complex than necessary. Multi-lingual or international labels also received comments. Respondents indicated that the current proposal did not provide enough flexibility. Additional questions for clarification were also posed on this section.
Bilingual labelling is a Government of Canada requirement under the Official Languages Act. The CFIA will strive to minimize the impact of this requirement on stakeholders by exploring the use of other approaches including a minority language exemption similar to that in Food and Drugs Act, and will endeavor to provide guidance on bilingual labelling, including acceptable translations for commonly used label information. In a broader context, the CFIA has committed to working with regulated industry to address the issue of multi-lingual labels.
Specific Requirements for Feed Types (section 4.3)
Most of the requirements set out in this section of the proposal did not prompt much feedback. Comments received on Veterinary Prescription feeds indicated an issue in the province of Quebec which requires all medicated feeds to be prescribed. Concerns were raised about not being able to make these feeds in advance of the prescription being issued in order to capitalize on manufacturing efficiencies.
Imported feeds generated the most feedback. The comments ranged from requests to keep mandatory registration for imported feeds, to support for removing all registration requirements.
Issues regarding the duality of regulations that apply to veterinary prescription feeds in Quebec are recognized as being of concern, but are specific to the provincial regulations and thus outside of the scope of the federal feed regulations.
The CFIA continues to explore options for imported feeds, and will be informed by the integrated Agency inspection model with regards to licensing and a general Agency approach for imported products.
Prohibitions (section 4.4)
Respondents were generally in favour of the requirements set out in this section of the proposal. One respondent indicated that while they recognize the need for some prohibitions, they should be used only when they serve a useful purpose and industry should be consulted.
The CFIA agrees that prohibitions should be used when they serve a useful purpose and will continue to consult as this process moves forward.
Voluntary Labelling (section 4.5)
Respondents were generally in agreement with proposals identified and discussed in this section. With regards to Brand Names, they agreed that it is useful to have some rules, however, comments included a request for additional consultation before putting any restrictions on brand names in place and more information to specify what would be allowed or not allowed as part of a brand name. One respondent also expressed concern that while the information must be truthful and not misleading, the burden of proof would be left to the users.
The CFIA agrees that it is useful to allow brand names on products and recognizes that there are concerns regarding what would be considered acceptable. This will be further addressed via guidance. The CFIA continues to propose that feed labelling must be truthful and not misleading and has a Complaints and Appeals process that allows stakeholders to register complaints and appeals related to quality of service, administrative errors and regulatory decisions.
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