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Feed Regulatory Renewal - Consolidated Modernized Framework - Supplementary CFIA Responses

June 2018

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Purpose

In keeping with the layout of the consolidated proposal and consultation summary report, this supplementary response combines and summarizes the following new or updated policy directions (influenced by on-going stakeholder engagement and current Agency priorities) that the CFIA intends to cover in the course of completion of a formal regulatory amendment proposal for publication in the Canada Gazette Part I in 2019:

Introduction

The Canadian Food Inspection Agency (CFIA) undertook a consultation from February 1, 2016 to April 8, 2016 on a comprehensive Consolidated Modernized Regulatory Framework Proposal for livestock feeds to:

As a result of this consultation, the Agency prepared and posted a Consultation Summary - Respondent Comments and CFIA Responses in January 2017 that included the policy directions the CFIA would be taking in preparing modernized regulations. In the interim however,

The Agency is also moving forward on five strategic priorities to help safeguard food, animals and plants in order to enhance the health and well-being of Canada's people, environment and economy. Building on the considerable consultation, research, design and planning completed over the past few years to continuously improve how the CFIA does business and to maximize the Agency's capacity to respond to risk now and into the future:

  1. Modern Regulatory Toolkit - The CFIA's modern regulatory toolkit, which focuses on outcome-based regulations with new compliance promotion tools, supports the Agency's role in protecting Canada's food, plants and animals, while facilitating product innovation.
  2. Integrated Risk Management - The CFIA's decisions and actions are based on risk and science. The Agency's new risk management tools; analytics and surveillance contributes to informed resource allocations and enforcement priorities while also bolstering the CFIA's ability to adapt quickly and respond to emerging risks in a changing global environment.
  3. Consistent and Efficient Inspections - A single inspection approach focused on regulatory outcomes and effectiveness of industry controls, supported by guidance and mobile tools, will contribute to greater efficiency and agility for the Agency when responding to emerging risks.
  4. Digital-First Tools and Services - Electronic access as the preferred method of requesting and receiving services from the CFIA, through applications such as My CFIA and Ask CFIA, will support industry compliance with regulatory requirements while helping to manage and prevent food safety risks.
  5. Global Leader - The CFIA's collaboration with partners around the world will support the development of international rules and standards, fairness in trade practices, enhanced use of technology, increased regulatory cooperation and improve market access for industry.

The modernization of the Feeds Regulations (Regulations) is taking these priorities into account in order to benefit the collective Canadian feed industry, which includes livestock producers, commercial feed manufacturers, retailers, importers, exporters, ingredient manufacturers, and food processors. In addition to aligning with other international feed regulatory regimes, modernization also maintains the objective of ensuring the regulations are as outcome-based, efficient and as flexible as possible while also continuing to ensure feeds are safe and contribute to the production and maintenance of healthy livestock, safe foods of animal origin, and that they do not pose a significant risk to the environment.

Modernized regulatory requirements

Complete lists of ingredients on feed labels

Recap

For most feeds, the current Feeds Regulations require a full list of ingredients or that the following statement is included on labels:

"A list of the ingredients used in this feed may be obtained from the manufacturer or registrant. / La liste des ingrédients de cet aliment peut être obtenue du fabricant ou du titulaire de l'enregistrement."

In both the Agency's 2013 Feed Labelling Regulatory Framework Proposal and 2015 Feed Regulatory Renewal Consolidated Modernized Framework Proposal, the CFIA indicated its intention to remove the option of providing the statement in lieu of requiring solely a full list of ingredients on feed labels. In trying to provide some flexibility regarding ingredient lists, the Agency subsequently posted the Proposal - Feed Ingredient Collective Terms on Labels in 2015 and an amended set of collective terms in the Feed Labelling Collective Ingredient Terms Proposal Consultation Summary report in 2016.
Most stakeholders have remained generally opposed to having the Regulations amended to require a full list of ingredients being provided on feed labels indicating that this requirement would:

In the case of collective terms, the Agency was not able to arrive at a consensus with stakeholders despite two proposals and indicated in the Consolidated Modernized Framework Proposal Consultation Summary report (2017):

"Given the limited feedback provided along with the fact that the CFIA will be investigating alternative measures for providing ingredient information to the purchaser, the CFIA has concluded that it will not pursue the completion of a list of collective terms for incorporation into the regulations by reference as an option for reducing labelling burden."
Recent developments

Subsequent to these proposals and reports, and for the purposes of preparing a cost/benefit analysis, the CFIA collaborated with the feed industry and livestock producer organizations in 2017 to collect information on baseline and anticipated costs associated with complying with the current regulations and the proposed regulatory changes. The information was collected by way of surveys tailored to commercial and on-farm feed manufacturers. In the case of the commercial feeds surveys, information was requested regarding current and anticipated labelling costs associated with moving towards a mandatory list of feed ingredients on labels.

In the analysis of survey respondents' feedback to the ingredient lists survey questions, Agency economists have estimated that the annual cost of this proposed regulatory would be in the order of $19.5 M / year.

CFIA Supplementary Response

The CFIA has listened to the on-going concerns of stakeholders respecting the logistical issues and estimated cost impact in respect of the proposed requirement to include full lists of ingredients on all feed labels.

Given these considerations, the CFIA has reviewed its position on ingredient lists on labels and proposes to return to the current requirement with some enhancements to ensure feed users have access to the information they require. The new proposed approach is as follows:

  • Every person who manufactures, sells, or imports a feed shall provide a label containing the following information:
    • the name of each single ingredient feed used in the feed or the statement "A list of the ingredients used in this feed may be obtained from the manufacturer" [for feeds not requiring CFIA registration]
    • in the case of a feed that is required to be registered, the name of each single ingredient feed used in the feed or the statement, as required by the CFIA at the time of registration
  • When the statement is used on a label,
    • the list of ingredients must be provided by the registrant, importer or manufacturer in writing within 3 business days of the day on which a written request is received
    • each single ingredient feed shall be identified in accordance with the name for that ingredient in the Regulations
    • the list of ingredients is not required to be provided if the request is made more than 3 years after the date on which the feed was manufactured or imported.

This approach provides the feed industry with the flexibility to include a full list of ingredients on the label at their discretion and purchasers with the opportunity to get ingredient information upon request in a predictable, timely and consistent manner.

Additional permissible claims

Recap

In its 2016 Proposal - Permissible Claims on Feed Labels, the CFIA put forward a Permissible Claims List that would allow the labelling of certain ingredients and mixed feeds with claims set out in the list without the need for pre-market assessment and approval by the CFIA of those claims on a product-by-product basis. It was also proposed that the Permissible Claims List would be incorporated by reference in the Regulations, thus providing greater flexibility in amending the document as required. In response to this proposal, the CFIA published the Permissible Claims on Feed Labels Proposal - Consultation Summary in 2017 with a revised Permissible Claims List.

Following the publication of the consultation summary, additional stakeholder concerns were received with respect to the following claims proposed in the Permissible Claims List:

"Manufactured in a facility that does not handle antibiotics or accept ingredients manufactured with antibiotics"
"Manufactured in a facility that does not use any animal products"

Stakeholders indicated that the related conditions set out in the List would not align with, nor support current industry practices that enable the use of claims on food products under "raised without the use of" livestock production systems. In response, the CFIA published the Consultation Summary of the Permissible Claims on Feed Labels Proposal - Supplementary CFIA Response in March 2017. As a result of the on-going concerns and a food labelling modernization consultation in progress at that time, the CFIA indicated it would, in the short term, remove these claims from the proposed List and would continue to work with the feed industry, livestock producer groups and food processors to develop alternative permissible claims and would further consult on them.

Recent developments

In response to its most recent consultation on food labelling modernization, the CFIA published the What We Heard Report - Food Labelling Modernization Initiative Phase III Engagement on Key Proposals to Modernize the Food Labelling System in February 2018.  With regard to "Stream 2" of this consultation on New Approach for Truthful and Not Misleading Labelling, the report indicated that:

Additional claims

In its on-going review and development of the modernized feed regulatory framework, the CFIA has continued to seek and identify opportunities where additional permissible claims could be provided for certain feeds to preclude product-by-product assessment and registration requirements.

CFIA Supplementary Response

Consumer value claims

Collaboration within CFIA and with feed and food stakeholders will continue as the modernization of the feed and food labelling regulations, policies and programming evolves in the coming months.

Additional Claims

Appendix I sets out the most current Tables of Permissible Claims for Feed Labels document that the CFIA will propose to incorporate by reference in the modernized regulatory framework. Table D in the document contains several new claims and associated conditions relating to technical (non-nutritive) claims.

Deleterious substances

Recap

In the current Feeds Act, the following prohibitions and exceptions apply:

Absence of registration, etc.
3 (1) No person shall manufacture, sell or import into Canada any feed unless the feed

(a) has, in accordance with the regulations, been approved by the Minister or registered;
(b) conforms to prescribed standards; and
(c) is packaged and labelled in accordance with the regulations.

Exception

(2) Paragraphs (1) (a) and (b) do not apply to any feed consisting of whole seeds or grains of cultivated farm crops if it is free from prescribed deleterious substances.

For the purposes of the exception in section 3(2) above, the current Feeds Regulations list the following as deleterious substances:

4 The following substances are hereby prescribed as deleterious substances for the purposes of sections [3] of the Act:

Recent developments

The Agency is proposing to remove certain technical standards and Schedules from within the framework of the current Regulations and incorporate documents containing the technical standards by reference in the Regulations instead (for example, the Proposal - Maximum Chemical Contaminant Levels in Livestock Feeds and the Proposal - Required Nutrient Guarantees (Table 3 of Schedule I)).  Given the technical nature of these deleterious substances, the CFIA is proposing to follow this same approach for the modernized regulatory framework.

Most of the chemicals on the deleterious substance list have been phased out or are only used in non-agricultural settings. The exceptions are carbaryl and malathion.

Carbaryl

There are 30 pesticide products containing the active ingredient carbaryl which are currently approved for use in Canada. 6 are registered by the Pest Management Regulatory Agency (PMRA) for agricultural uses. 2 products are registered for use on crops, 2 products are registered for use directly on livestock to control fleas, lice and other pests, and 2 products are registered for use on both crops and livestock. 2 products are registered for commercial use on ornamentals, turf and trees. The remaining products are registered for domestic or manufacturing purposes. Carbaryl maximum residue limits (MRLs) established by the PMRA range from 0.02-15 ppm in food commodities. Carbaryl MRLs in food commodities (synonymous with food ingredients) range from 0.02-2 ppm (2 ppm in barley, oats, rye and wheat; 1 ppm in corn; 0.5 ppm in dry soybeans and sunflower seeds; 0.02 ppm in flaxseeds). The current action level applied for carbaryl detections in grains and oilseeds tested by the CFIA as part of the National Feed Inspection Program is 0.04 ppm. Based on monitoring data from the National Feed Inspection Program, carbaryl has only been detected at trace levels in one feed ingredient sample over the past 9 years.

Malathion

There are 20 pesticide products containing the active ingredient malathion which are approved for use in Canada. 11 of these products are registered for agricultural uses. 5 products are registered for use on crops, 2 are registered for use on stored grains, and 4 are registered for use in backrubber devices for cattle to control flies, lice and other pests. Malathion MRLs established by the PMRA range from 0.5 to 8 ppm in various food commodities. For food commodities like raw cereals, barley and grain which are similar to feed ingredients listed in Schedule IV the MRLs are 8 ppm, the same as the current action level used for malathion detections in grains analyzed under Program 20 of the National Feed Inspection Program. Malathion residues have been detected every year (4 detections per year on average) in grains collected under that National Feed Inspection Program between 2009 and 2018, with the detected levels ranging between 0.012 and 0.62 ppm.

In the US, there are similar MRLs established for carbaryl and malathion in food commodities. MRLs for forages have also been established and are significantly higher than limits set for other food commodities.

Based on the higher use of products containing malathion and the consistent detection of malathion residues in grain ingredients sampled under the National Feed Inspection Program, the CFIA believes that malathion should be removed from the deleterious substances list and added to the chemical contaminant regulatory guidance document with the associated action level. Carbaryl, while still used for some agricultural purposes, is rarely detected in feed and, therefore, it is not necessary to set an action level for this contaminant in the guidance document.

CFIA Supplemental Response

  1. The CFIA proposes to remove the list of deleterious substances currently prescribed in section 4 of the Regulations and establish a document, the List of Prescribed Deleterious Substances, which will be incorporated by reference in the Regulations instead. This approach would provide more flexibility and timely revision of substances on the list.
  2. In the case of carbaryl, the CFIA proposes to retain this chemical on the List of Prescribed Deleterious Substances given very few products are approved for agricultural purposes and it is seldom detected in feeds or feed ingredients.
  3. In the case of malathion, the CFIA proposes to remove malathion from the list of deleterious substances and add the following standards to the other proposed Maximum Chemical Contaminant Levels in Livestock Feeds:
Contaminant Proposed Maximum Level
Malathion in grains (rice, rye, corn, barley, wheat, oats) 8 ppm
Malathion in non-grain single ingredient feeds < 0.04 ppm
Malathion in mixed feeds 4 ppm

Permissions

Notice of submission scheme for feed ingredient submissions (updated)

Recap

In both the 2013 Feed Ingredient Assessment and Authorization - Regulatory Framework Proposal and 2015 Feed Regulatory Renewal Consolidated Modernized Framework Proposal, the CFIA indicated it would be moving to adjust its feed ingredient assessment and approval process to the model illustrated in Figure 1 below.  Included in this revised process would be a mandatory notification of submission step in which the Agency would provide a list of submissions that are in the application queue for the information of external parties.

As an outcome of the consultations on this proposed process, the 2017 Consultation Summary -Respondent Comments and CFIA Responses regarding the Consolidated Modernized Framework Proposal indicated:

"Based on the comments received, the support for the Notice of Submission process was split. Some respondents felt that this would be beneficial, as stakeholders would know what was going to be entering the market. Others felt that such a process might give away confidential information or prevent companies from applying to have innovative ingredients approved for use in Canada. There were also a couple of questions asking for clarification on what type of information would be posted. A couple of questions were raised with respect to protecting confidential information."
Figure 1: Proposed feed ingredient assessment and authorization process
Figure 1: Proposed feed ingredient assessment and authorization process.  Description follows.
Description for Figure 1: Proposed feed ingredient assessment and authorization process

This is a basic cycle diagram that shows the steps in the proposed feed ingredient assessment and authorization process. There are six steps in the main cycle.

  1. Application
  2. Notification of application
  3. Assessment
  4. Assessment outcome
  5. Authorization/positive list
  6. Post-authorization controls

Recent developments

During engagements with stakeholders subsequent to the posting of the consultation summary report, feed and other industry groups have indicated that a notice of application step in the assessment and authorization process should be voluntary and not mandatory. If applicants wished to have an application made publically available, this could be indicated to the CFIA as part of the application process and the Agency would proceed accordingly to disclose/not disclose information about the application in its submission queue.

CFIA Supplementary Response

At the present time, the only product-based notice of submission schemes administered by the CFIA are as follows:

  • the Plant Breeders' Rights Office (PBRO) is legally obliged by the Plant Breeders' Rights Act (sections 10(2), 70(1), and 71(1)) to notify both the applicant and the public at large when an application for a right is received and accepted. The applicant is notified directly via mail and the public at large through the quarterly publication of the Plant Varieties Journal: and
  • The Notice of Submission  process allows developers who have requested safety assessments of plants with novel traits (PNTs) to voluntarily notify the public of their submissions

None of the other Agency programs that involve product-based pre-market assessment and authorization (e.g., for seeds, fertilizers, or veterinary biologics) have notice of application processes, nor are any being contemplated in the near future.

Implementing a voluntary feed ingredient application notification step would likely only provide a partial listing of the applications in the CFIA's submission queue which would be of limited value to either external parties or to the CFIA itself.

Given the lack of consensus expressed by stakeholders on requiring a mandatory notice of application step as part of a feed ingredient assessment and authorization process, the limited value of implementing a voluntary step and the absence of such a step across other CFIA product-based regulatory programs, the CFIA proposes to remove this step altogether from the proposed process.

Oversight of exports

Recap

The current regulations exempt feeds intended for export. This allows for potentially unsafe feeds to be exported to other markets, particularly where CFIA certification is not required. Regulatory modernization is building a much more robust domestic feed safety system (i.e., through the establishment of updated feed safety standards, manufacturing standards, PCPs and licensing), thereby providing opportunities to leverage new or expanded market access for feeds and feed ingredients, livestock or livestock products.

Under the "Exporters" heading in the Permissions section of the 2015 Feed Regulatory Renewal Consolidated Modernized Framework Proposal, the following was proposed:

To increase assurance that feeds in international trade originating from Canada are safe, it is proposed that all feeds manufactured in Canada intended for export meet Canadian standards for safety and other domestic compliance requirements.

In the 2017 Consultation Summary report regarding the Feed Regulatory Renewal Consolidated Modernized Framework Proposal the following outcomes were identified in the Permissions - Persons or establishments (exports) section of the report:

[N]o clear consensus emerged with respect to the approach proposed by the CFIA for exporters and feed products destined for export markets. Comments from respondents included the following:

Recent developments

The notion of applying domestic feed safety standards to exports was again proposed in 2 subsequent proposals in 2017:

  1. Proposal - Maximum Chemical Contaminant Levels in Livestock Feeds ; and
  2. Proposal - Contaminant Standards for Aflatoxins, Deoxynivalenol, Fumonisins, Ergot Alkaloids and Salmonella in Livestock Feeds

In response, industry associations and individual companies again indicated they are generally opposed to the application of domestic safety standards to exports as it would:

CFIA Supplementary Response

Given the additional feedback received from stakeholders and greater clarity on the approach that the food program is taking, it is proposed that the CFIA follow the approach for the export of food products in the Safe Food for Canadians Regulations.

Feeds intended for export would be required to be manufactured:

  • by a CFIA licence holder
  • in accordance with a PCP
  • in accordance with documentation demonstrating that the importing country's requirements are being met
  •  If the importing country does not specify its own requirements, Canadian safety standards would apply.

Enforcement

Administrative monetary penalties for violations of the feeds regulations (new)

Recap

The Agriculture and Agri-Food Administrative Monetary Penalties Act (AAAMP Act) was enacted in 1995 as an alternative to the penal system and as a supplement to existing enforcement measures. The intent of the legislation was to establish a fair and efficient monetary penalty system for the enforcement of certain agri-food laws administered by the CFIA. Implementation of administrative monetary penalties (AMPs) across the various laws listed in the AAAMP Act was to be phased in over a number of years. In the case of feeds, AMPs for violations of certain provisions of Part XIV of the Heath of Animals Regulations (Food for Ruminants, Livestock and Poultry, Rendering Plants, Fertilizers and Fertilizer Supplements or "feed ban" regulations) were implemented following the detection of bovine spongiform encephalopathy (BSE) in Canada in 2003. No AMPs have been implemented for any violations of the Feeds Act or Feeds Regulations to date although the scope of the AAAMP Act does provide the authority to implement AMPs for the Feeds legislation.

AMPs are one of several enforcement tools available to the CFIA in responding to situations where regulated parties do not comply with regulations. The intent is to discourage non-compliance by creating financial disincentives, which in turn, should result in behaviour changes and improved compliance.

The AAAMP Act provides for the issuance of two types of AMPs: a "notice of violation (NOV) with warning" and a "notice of violation with penalty". As part of the CFIA's overall approach to enforcement, AMPs are intended to be applied within a suite of enforcement responses ranging from sending a letter of non-compliance to prosecution. AMPs may be used as a stand-alone enforcement measure or combined with other enforcement measures to achieve desired compliance.

Recent Developments

In November 2016, the CFIA posted a Draft Administrative Monetary Penalties Policy for public review and comment that included the Policy Statement, "The CFIA will apply AMPs to discourage non-compliance of regulated parties through fair, timely and effective application of financial disincentives within the Agency's graduated enforcement approach."  The Policy goes on to elaborate on guiding principles, roles and responsibilities, monitoring and reporting mechanisms and other considerations the Agency will follow in the applications of AMPs across agri-food sectors.

To support compliance and enforcement of the CFIA's proposed Safe Ford for Canadians Act/Regulations, (SFCA/R) the CFIA published a proposed set of AMPs violations in the Canada Gazette, Part I on October 21, 2017 for public review and comment. The Agency's proposal would see these AMPs finalized and implemented now that final publication of the SFCR occurred in June 2018.

CFIA Supplementary Response

In keeping with the statement in the Agency's draft AMPs Policy and the Agency's current strategic priority of having a modern regulatory toolkit (discussed in the Introduction above), a proposed suite of AMPs for violations of the modernized Feeds Act/Regulations will be prepared and published for public review and comment following the publication of the modernized Regulations. In the CFIA Forward Regulatory Plan: 2018-2020 updated in March 2018, the Agency has signalled its intention to proceed with Amendments to the Agriculture and Agri-Food Administrative Monetary Penalties Regulations (Feeds Regulations).

Next steps

The CFIA is preparing a formal regulatory proposal for publication in the Canada Gazette Part I which will incorporate the comments received on all the consultation proposals, public meetings, stakeholder workshops and submissions, and other outreach activities that have been used over the course of the project.

Appendix I - Tables of permissible claims for feed labels

Table A - General claims
Item

Column 1

Type of Claim

Column 2

Conditions - Approved Statement or Claim

Column 3

Conditions - Feed

Column 4

Conditions - Label

1. Claims respecting highlighting the presence of an ingredient

Contains XX

Contains XX as a [purpose], e.g.: "Contains ethoxyquin as an antioxidant"

The feed must contain the named ingredient. May indicate the purpose of that ingredient as per its approved label or classification in the "Canadian Feed Ingredients Table".
2. Claims respecting Phytase (or other enzyme) Contains XX (source) as a source of phytase The feed must contain the enzyme at the manufacturer's approved use rate.

A guarantee of the activity level for the named enzyme must be included in the guaranteed analysis.

Source of phytase must be displayed on the label, e.g.:

"Contains 6-phytase produced by Arffung japonica as a source of phytase"

May include the brand name of the phytase voluntarily, e.g.:

"Digital Digit Sky Phytase - Contains 6-phytase produced by Arffung japonica as a source of phytase"

3. Claims respecting Organic

Organic

Contains X% organic ingredients

Canada Organic Logo

The feed must meet all of the conditions of the Organic Products Regulations, 2009.
Table B - Nutritional Claims
Item Column
Type of Claim

Column 2

Conditions - Approved Statement or Claim

Column 3

Conditions - Feed

Column 4

Conditions - Label

1. Claims respecting a Source of nutrient (vitamin, mineral, energy, fat, fibre) Source of XX The feed must contain the named nutrient at a level that meets at least 25% of the animal's minimum daily requirement, as defined by the National Research Council (2012).

A guarantee for the named nutrient must be included in the guaranteed analysis.

Qualifier words are not permitted to be added to the claim, e.g.:

"good";

"high in";

"excellent"; etc.

2. Claims respecting digestibility Promotes phosphorus and calcium digestibility Phytase - the feed must contain an approved source of phytase at the manufacturer's approved level. A guarantee for Phytase activity level must be included in the guaranteed analysis.
2. Claims respecting digestibility
  1. Promotes energy digestibility
  2. Promotes fat digestibility OR Lipase is an enzyme that hydrolyzes lipids
  3. Promotes phosphorus and calcium digestibility
  4. Promotes protein digestibility

Non Starch Polysaccharide (NSP) Enzymes - the feed must contain one or more of the following classes of enzymes at the manufacturer's approved level:

  1. Carbohydrates
  2. Lipases
  3. Phytases
  4. Proteases
A guarantee of the activity level for the named enzyme must be included in the guaranteed analysis.
2. Claims respecting digestibility Promotes fat digestibility Lecithin - the feed must contain an approved source of lecithin at the manufacturer's approved level. A guarantee for lecithin must be included in the guaranteed analysis.
Table C - Performance Claims
Item

Column 1

Type of Claim

Column 2

Conditions - Approved Statement or Claim

Column 3

Conditions - Feed

Column 4

Conditions - Label

1. Claims respecting Anion / Cation supplement(s) Contributes to reduction of the risk of hypocalcaemia in dairy cows

The feed must contain sources of anions and cations.

When used as directed results in reduced dietary cation/anion balance (DCAB)

A guarantee for Calcium, Phosphorus, Sodium, Chloride and Sulfur must be included in the guaranteed analysis.

A guarantee for actual cation/anion balance expressed in mEq/kg must be included in the guaranteed analysis.

The formula used to determine DCAB must be included on the label.

Directions for use must indicate feeding to dry dairy cows during 1 to 4 weeks pre-partum.

2. Claims respecting Buffer supplement(s) / feed(s)

To improve butter fat test in dairy cows

Buffer

Buffered

The feed must only be fed to ruminants.

The feed must contain sources of buffering ingredients:

  1. Sodium sesquicarbonate;
  2. Sodium bicarbonate;and/or,
  3. Magnesium oxide.
  1. Feeds consisting of a mixture of buffer ingredients:
    1. No nutrient guarantees are permitted;
    2. The actual level of buffer ingredient(s) may be included in the guaranteed analysis.
  2. Feeds consisting of a mixture of buffer ingredients and other nutrient source(s):
    1. Guarantees for required nutrients normally shown for a similar feed not containing buffer ingredients;
    2. Nutrients guaranteed cannot include the nutrient values from the buffering ingredients (e.g. sodium from sodium bicarbonate cannot be included in the guaranteed analysis);
    3. The actual level of buffer ingredient(s) may be included in the guaranteed analysis.
Table D - Technical (non- nutritive) Claims
Item

Column 1

Type of Claim

Column 2

Conditions - Approved Statement or Claim

Column 3

Conditions - Feed

Column 4

Conditions - Label

1. Claims respecting Acidifying products

Acidifier(s) for feeds

Reduces pH of feeds

Feed acidity regulators

The feed must contain approved source(s) of acidifying ingredients e.g. potassium diformate; sodium bisulfate; butyric acid

Directions for use must not exceed the limits set for the acidifying ingredient(s) in CFIT

When used as directed the product results in reduced pH of the feed

The acidifying ingredient or product must not be encapsulated

Does not supply significant source of nutrients

No nutrient guarantees are permitted
2. Claims respecting Antioxidant products

Reduces oxidation of fats and nutrients

Reduces oxidation in livestock feed

Feed antioxidant(s)

Prevents or retards oxidation of feeds

The feed must contain sources of approved antioxidant(s) e.g. ethoxyquin; BHT and BHA; tocopherols, propyl gallate

When used as directed the product results in reduced oxidation in the feed

Directions for use must ensure that the maximum limits specified for each of the antioxidant ingredient(s) (CFIT) are not exceeded

Does not supply significant source of nutrients

No nutrient guarantees are permitted

The minimum amount of each antioxidant ingredient must be guaranteed.

3 Claims respecting Anti-caking products

Anticaking of feeds

Anti-caking agent

Flowing agent

Flow aid

Free -flow agent

The feed must contain approved anticaking ingredients as per CFIT e.g. sodium aluminosilicate; silicon dioxide, diatomateous earth

When used as directed the product results in improved flow or prevent caking of feeds

Directions for use must not exceed the limits set for anticaking ingredients (CFIT) in the feed

Cannot contain flavours, antioxidants, yeast and yeast by-products, vitamins, algae, enzymes, any specialty feeds or any ingredient supplying nutrients to livestock

No nutrient guarantees are permitted

Maximum use rate of 2% of the feed.

4 Claims respecting Chemical mould Inhibitors

Reduces mould growth in feeds

Mould inhibitor

The feed must contain approved chemical mould inhibitor ingredients only as per CFIT

When used as directed the product results in inhibition of mould growth in feeds e.g. propionic acid

Directions for use must not exceed the limits set for the chemical mould inhibitor ingredients in CFIT

Does not supply significant source of nutrients

No nutrient guarantees permitted

Must state the specific moisture level(s) at which the product is effective at inhibiting or reducing mould growth.

5 Claims respecting Forage additives As per the purpose/ claim (s) on the constituent SIF/active ingredients specified in the CFIT.

The feed must contain approved forage additive ingredients as per CFIT

When used as directed the product supply the constituent active ingredients at amounts specified in the CFIT to meet the constituent SIF claim(s)

Directions for use must not exceed the limits set for the forage additives in CFIT at the approved rates

Detailed directions for use to reflect specific mixing instructions, application rates and target forages or feeds as per the constituent active ingredients specifications indicated in the CFIT.

Must add the per cent dry matter content of the forage and/or silage

Guarantees for active ingredients (e.g. organic acids, bacterial counts-CFU, enzyme activity) are required.

6 Claims respecting Odor control products

Potential to reduce odor in barns

Potential to reduce ammonia in barn

The feed must contain source(s) of approved odor control ingredients as per CFIT

When used as directed the product has the potential to reduce odor in barns (i.e. reduction in litter ammonia levels in barns or other indicators of odor) e.g. yucca products)

Directions for use must not exceed the limits set for odor control ingredients in CFIT

Does not supply any significant nutrition

No nutrient guarantee permitted
7 Claims respecting Pelleting product(s

Pellet binder

Pelleting agent

Pelleting aid

The feed must contain only approved pelleting ingredients as per CFIT

When used as directed results in aiding pelleting of feed i.e. improves pellet durability e.g. lignin sulfonate; bentonite

Directions for use must not exceed the limits set for pelleting ingredients in CFIT

Does not supply significant nutrients

No nutrient guarantee permitted
8 Claims respecting
Micro- tracers

Micro tracers for feed

Feed tracers

The feed must contain only source(s) of approved micro tracers as per CFIT

Does not supply significant nutrients

Directions for use must not exceed the limits set for micro- tracers in CFIT

 When used as directed it should code, colors or identify micro -ingredients, grains or feeds

No nutrient guarantee
permitted
9 Claims respecting enzyme products As per the claim(s) on the original registered enzyme products

The feed must contain only registered enzyme(s) at approved use rates and for the specified livestock species in CFIT

If strains used for the production of the original enzyme ,it must be registered as a Part II SIF (CFIT) before use in the enzyme production e.g. phytase, lipase, amylases

Directions for use must not exceed the limits set for enzyme activity in CFIT and must reflect the restrictions in the registered SIF enzyme or strain specifications.

Guarantee of the activity enzyme (s) level must be added to the label

No nutrient guarantee permitted

Detailed directions for use to reflect specific mixing instructions, application rates and target feeds as per the specifications indicated in the original registered enzyme in CFIT.

Source of the enzyme (s) must be displayed on the label e.g. Arffung japonica as a source of phytase;

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