Chapter 3 - Specific Registration Information by Feed Type
3.18 Ruminant and Horse Supplements
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Regulation of Ruminant and Horse Supplement Feeds
Over the past several years, confusion has arisen regarding the regulatory status of ruminant and horse feeds manufactured in Canada termed "supplements" to the point where it is generally believed that the majority of these products are exempt from mandatory registration. This section will clarify the regulatory status of "supplement" feeds and identify which products require registration.
The definition of a livestock "supplement" feed in section 2 of the Feeds Regulations is a broad one that allows this category of product to be fed in 3 different ways:
(a) fed undiluted as a supplement to other feeds,
(b) offered free choice with other parts of the ration separately available, or
(c) further diluted and mixed to produce a complete feed that is acceptable for registration.
Within the regulations in general and for the purposes of paragraph (c) above, section 2 also contains a definition for "complete feed", that is
"complete feed" means a feed that, when used for the kind of livestock and for the purposes stated on the label, will provide all of the nutritional requirements necessary for the maintenance of life or for promoting production except
(a) water, in the case of monogastric animals other than horses, and
(b) water or roughage, in the case of ruminant animals and horses (aliment complet)"
For the purposes of the Regulations, the complete feed for a ruminant or a horse is not the same as its complete diet (or total ration).
Although subsection 5(1) requires that all feeds be registered, subsection 5(2) contains a long list of specific exemption criteria for products defined within the scope of the regulations. With respect to "supplements", paragraphs 5(2)(d) and (e) outline the exemption criteria:
"(d) any complete feed, supplement or macro-premix manufactured in Canada that is designed to be fed to beef cattle, dairy cattle, sheep, swine, chickens, turkeys, horses, goats, ducks, geese, salmonid fish, mink or rabbits where...
(i) the feed is not designed to replace whole milk in the ration of the livestock, ...
(iv) in the case of a supplement or macro-premix, the nutrient level guaranteed for those nutrients listed in Table 4 of Schedule I is such that when the supplement or macro-premix is used according to the directions for use it will not supply the complete feed with any nutrient at a level higher than the maximum listed in that Table for that nutrient but will supply the complete feed, in conjunction with the other ingredients, with a level of nutrient that meets or exceeds the minimum listed in that Table for that nutrient, ..."
"(e) any consultant formula feed manufactured in Canada if ...
(iii) in the case of a supplement, macro-premix or micro-premix, the nutrient level guaranteed for those nutrients listed in Table 4 of Schedule I is such that when the supplement, macro-premix or micro-premix is used according to the directions for use it will not supply the complete feed with any nutrient at a level higher than the maximum listed in that Table for that nutrient but will supply the complete feed, in conjunction with that supplied by the other ingredients, with a level of nutrient that meets or exceeds the minimum listed in that Table for that nutrient, ..."
Given the above definitions and exemption criteria, "supplement" feeds to be offered undiluted or free choice to ruminants or horses are not exempt from mandatory registration.
Example products required to be registered include:
- molasses-based blocks or liquid suspension feeds:
- free choice or blocked "mineral" supplements for cattle, sheep, goats etc. on pasture or range;
- any supplement where directions for use indicate further mixing is required but the other complete feed ingredients or proportions are not identified to permit the use of exemption from registration criteria (e.g. TMR cattle supplements containing ionophores)
- consultant-formula supplements of the kind described above
Supplements labelled with directions for use where both further mixing and feeding undiluted or free choice are indicated will not be required to be registered if the supplement's labelling can be used to verify it is exempt from registration.
Supplements requiring to be registered will be accepted and processed per the procedures and application fees for registration outlined in Chapter 1.
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