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Proposal – Maximum Nutrient Values in Fish Feeds (Freshwater and Marine)

February 2018

Purpose

As part of a comprehensive, multi-year regulatory modernization process, the Canadian Food Inspection Agency (CFIA) has initiated the renewal of the federal Feeds Regulations (Regulations) as one of several priorities identified for modernization.

The goal of renewing the Regulations is to develop a modernized risk- and outcome- based regulatory framework for feeds which:

Modernization of the Regulations provides the opportunity to review feed controls, standards, labelling and other regulatory requirements. The purpose of this proposal is to:

Background and current situation

Table 4 of Schedule I was created and incorporated into the Feeds Regulations in the 1980s as a mechanism to exempt certain groups of feeds from mandatory registration. The original Table 4 established nutrient ranges (minimums and maximums) as exemption criteria for feeds for chickens, turkeys, swine, beef and dairy cattle, and sheep. In 1990, via two regulatory amendments, the table was first expanded to include horses, goats, ducks, and geese; and then for rabbits, mink, and salmonid fish. Since that time, there have been no other substantive changes to the table or to any of the nutrient ranges.

Currently, the feed can be exempted from registration if:

Feeds that provide nutrients which fall outside the ranges listed in Table 4, and that do not meet any additional exemption criteria, require assessment and registration by the CFIA prior to manufacture and sale.

In the case of fish feeds, Table 4 of the Regulations currently establishes nutrient ranges only for salmonid species, for example, salmon and trout. The Feed Regulatory Renewal Consolidated Modernized Framework Proposal – November 2015 (Consolidated Proposal) proposed that the scope of the species to which the Feeds Regulations apply would be expanded to include feeds for animals that are raised for human consumption. In addition, the Consolidated Proposal suggested clarification would be provided regarding which species of fish would be subject to the Regulations. As such, the species of fish has been expanded to include those raised commercially in Canada.

As indicated in the Consolidated Proposal, both the CFIA and stakeholders recognize that some of the values in Table 4 may no longer have the same nutritional relevancy that they did when the table was first introduced. Stakeholders have also indicated that they feel that Table 4 prevents innovation for new feed products. However, many of the maximum nutrient levels which are currently set out in Table 4 have health and safety implications that must be considered.

Proposal

It is proposed that:

  1. Table 4 be removed from the Regulations and no longer serve as a trigger to register feeds based on specified ranges of nutrient content and
  2. maximum nutrient levels be established for fish (freshwater and marine) feeds

This proposed approach addresses stakeholder concerns regarding Table 4 and its relevance in current industry practices, as well as claims that the nutrient ranges provided in Table 4 impede new products from entering the marketplace. Furthermore, it addresses concerns regarding the harmful impact that higher levels of certain nutrients may have on livestock or the resulting food products, and underscores the modernized regulatory framework's focus on health and safety for humans, animals, and the environment. It is further proposed that:

Considerations

The domestic feed industry considers that the Table 4 nutrient ranges are out of date, and that this table is no longer an appropriate regulatory tool for feeds. However, there remains a continued need for an enforceable regulatory framework regarding maximum nutrient concentrations in livestock feeds for health and safety reasons. For instance, levels of certain vitamins in livestock rations (for example, vitamins A, D, and E) in excess of nutritional requirements can be harmful to livestock or can be concentrated into tissues that are used for human consumption, thus posing potential risk to human health. Similarly, certain minerals (for example, copper, iodine, phosphorus and zinc) fed in excess of livestock requirements can also contribute to increased human and environmental risks.

A significant proportion of minerals fed in excess of requirements are excreted into the environment via urine and feces. Consequently, even though the maximum tolerable level (MTL) of a given mineral may be significantly greater than the nutritional level, feeding at the maximum tolerable level may result in negative impact on the environment.

An analysis of fish nutritional requirements and maximum tolerable dietary nutrient levels was conducted by the CFIA with the following scope:

Information sources used in the review and development of nutrient maximums in fish (marine and freshwater) feeds included:

Appendix I sets out the proposed maximum nutrient values for fish (marine and freshwater) feeds.

Anticipated outcomes

This modernized regulatory approach to the oversight of maximum nutrient content in fish (marine and freshwater) feeds would:

Stakeholders are being provided with an opportunity to comment on all proposals, including the maximum nutrient values being suggested for each species or class of species, before they are incorporated into a regulatory framework.

References: A complete bibliography is available upon request

Have your say

The CFIA is seeking feedback on the proposal to modify the regulatory requirements related to maximum nutrient content in livestock feed:

  • Do you have any concerns with the proposal to remove the Table 4 nutrient levels from the Feeds Regulations and no longer exempting feeds from registration based on the nutrient content of the feeds?
  • Do you have any concerns with the proposal to establish maximum nutrient values for livestock feeds?
  • Do you have any concerns with the proposed maximum nutrient values outlined in Appendix I for fish feeds?
  • Would the proposed amendments to the Feeds Regulations be effective in protecting human and animal health and the environment?
  • Are there options not mentioned in this proposal that should be explored?
  • Any additional feedback?

We strongly encourage you to provide your input and feedback, which is critically important to the success of the regulatory modernization initiative. Please send written comments by March 30, 2018 to:

Sergio Tolusso
Canadian Food Inspection Agency
Animal Feed Division
59 Camelot Drive
Ottawa, ON K1A 0Y9
Email: sergio.tolusso@canada.ca
Fax: 613-773-7565

Appendix I – Proposed maximum nutrient values for fish feeds

List of regulated fish families
Current Proposed
Salmonids
(Salmon, Trout, etc.)
Salmonids (Salmon, Trout, etc.)
Cichlids (Tilapia, etc.)
Anoplopomatids (Sablefish, etc.)
Pleuronectids (Halibut, Sole, etc.)
Percids (Perch, etc.)
Other (remaining commercially raised fish species)

Considerations:

Macro-minerals

Calcium (Ca)
Class Current
(% of complete feed, as fed)
Proposed
(%, at 88% dry matter [DM])
Fish (All) 3.0 No requirement specified (NRS)

Considerations:

Phosphorus (P)
Class Current
(% of complete feed, as fed)
Proposed
(%, at 88% DM)
Fish (All) 2.5 3.5

Considerations:

Magnesium (Mg)
Class Current
(% of complete feed, as fed)
Proposed
(%, at 88% DM)
Fish (All) 0.3 0.3

Considerations:

Sodium (Na)
Class Current
(% of complete feed, as fed)
Proposed
(%, at 88% DM)
Fish (All) 1.2 NRS

Considerations:

Potassium (K)
Class Current
(% of complete feed, as fed)
Proposed
(%, at 88% DM)
Fish (All) 1.3 NRS

Considerations:

Sulfur (S)
Class Current
(% of complete feed, as fed)
Proposed
(%, at 88% DM)
Fish (All) NRS NRS

Considerations:

Trace minerals

Cobalt (Co)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) NRS 3.0

Considerations:

Copper (Cu)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) 75.0 30.0

Considerations:

Iodine (I)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) 20.0 70.0

Considerations:

Iron (Fe)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) 500.0 750.0

Considerations:

Manganese (Mn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) 150.0 150.0

Considerations:

Selenium (Se)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) 0.1 (total) 2.0 (total)

Considerations:

Zinc (Zn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) 300 250

Considerations:

Vitamins

Vitamin A
Class Current
(IU/kg)
Proposed
(IU/kg of diet at 88% DM)
Salmonids 25,000 100,000
Cichlids N/A 10,000
Anoplopomatids N/A 25,000
Pleuronectids N/A 25,000
Percids N/A 25,000
Other N/A 25,000

Considerations:

Vitamin C
Class Current
(mg/kg)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) NRS NRS

Considerations:

Vitamin D
Class Current
(IU/kg)
Proposed
(IU/kg of diet at 88% DM)
Fish (All) 10,000 10,000

Considerations:

Vitamin E
Class Current
(IU/kg)
Proposed
(mg/kg of diet at 88% DM)
Fish (All) NRS NRS

Considerations:

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