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Archived - Proposal - Feed Ingredient Collective Terms on Labels

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December 2015

As part of the Feed Labelling Regulatory Framework Proposal published by the CFIA in November 2013, it was proposed that all feeds would have to have a complete list of ingredients on the label. This will allow purchasers to:

It was also proposed that "collective terms" would be allowed for specific ingredient groups to provide flexibility for labelling least cost formulated feeds and to be in line with feed labelling regulations in the United States. Upon request by the purchaser, the actual list of ingredients must be provided so that purchasers are able to know what ingredients are actually used in the feed.

In the context of this proposal, a "collective term" refers to a name given to a group of feed ingredients used for a common purpose. Collective terms make it easier to label "best-cost" formulations (using the best combination of ingredients to meet a specific nutrient profile for the feed at the lowest possible cost) as labels need not to be changed each time an ingredient is changed. Collective terms recognize a general classification of ingredient origin, which perform a similar function, but do not imply equivalent nutritional values. When a collective term is used, individual ingredients within that group cannot be listed on the label.

In the United States (U.S.), collective terms are allowed to be used in place of individual ingredient names on feed labels in accordance with rules set out in the Code of Federal Regulations (21 CFR 501.110) administered by the U.S. Food and Drug Administration (FDA). This section defines the collective terms allowed to be used and states that the animal feed ingredients listed under each of the collective names are the products defined by the Association of American Feed Control Officials (AAFCO). The terms are as follows, and AAFCO lists the specific feed ingredients for each term in their Official Publication:

  1. Animal Protein Products
  2. Forage Products
  3. Grain Products
  4. Plant Protein Products
  5. Processed Grain By-Products
  6. Roughage Products
  7. Molasses Products

Taking into consideration the U.S. collective terms, the CFIA is proposing the following seven (7) similar collective terms for use on feed labels in Canada:

  1. Forage Products
  2. Roughage Products
  3. Grain Products
  4. Processed Grain By-Products
  5. Brewers and Distillers By-Products
  6. Dairy By-Products
  7. Plant Protein Products and By-products

Due to the animal health risks and restrictions on the feeding of some animal protein products to certain species (e.g. animal proteins prohibited from feeding to ruminants), the CFIA proposes to exclude having a collective term for this grouping of ingredients for feed labels in Canada. Individual animal protein products will still require listing on feed labels. To capture some of the lower risk products, the collective term "Dairy By-products" is proposed for dairy related ingredients.

Appendix 1 lists each proposed collective term and the Feeds Regulations Schedule IV ingredients which fit under each term. For reference, the current Schedule IV ingredient numbers are also included.

Appendix 2 provides the collective terms, and their ingredients, which are used in the U.S. for referenceFootnote 1.

While the lists are similar, please note that not all ingredients listed per a collective term in the U.S. may be approved in Canada. Only approved Schedule IV and V ingredients may be used in feeds for the Canadian market, regardless of whether a collective term is listed on the label.

When labelling a product, if multiple ingredients are used that are included in a collective term, then the collective term can be used in the list of ingredients on the label instead of the individual ingredient names. For example:

Each proposed collective term is not intended to represent every possible ingredient that could be substituted. They are intended to represent the majority of the most common ingredients used in feeds and are not intended as a way to hide the identity of ingredients from purchasers.

The collective terms should reflect ingredients of similar purpose.

Have your say

We are seeking feedback on the proposal for Feed Ingredient Collective Terms on Labels:

  • Are the collective terms being proposed appropriate for the labelling of feeds in the Canadian marketplace?
    • Preliminary feedback from regulated industry on this proposal has indicated that a collective term for Animal Protein products (excluding those from ruminant sources) would be desirable. Is having such a collective term something the CFIA should further explore?
  • Are the ingredients proposed under each of the proposed collective terms appropriate?
  • Are there any ingredients that should be added to any of the proposed collective terms?
  • Given that we anticpate that complete feeds and supplements will represent the majority of feeds that use collective terms on the label, would it be appropriate to restrict the use of collective terms to feeds manufactured in Canada, while requiring imported feeds to list the actual ingredients? Are there many imported feeds that anticipate taking advantage of the flexibility provided by collective terms?
  • 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. Written comments may be forwarded by January 17, 2016 to:

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

Appendix 1 - Proposed Collective Terms

1. Forage Products may include one or more of the following:

2. Roughage Products may include one or more of the following:

3. Grain Products may include one or more of the following:

4. Processed Grain By-products may include one or more of the following:

5. Brewers and Distillers By-products may include one or more of the following:

6. Dairy By-products may include one or more of the following:

7. Plant Protein Products and By-Products may include one or more of the following:

Appendix 2 - AAFCO Collective Terms (2015 Official Publication)

Animal Protein Products

Forage Products

Grain Products

In any of the normal forms such as whole, ground, cracked, screen cracked, flaked, kibbled, toasted or heat processed:

Plant Protein Products

Processed Grain By-Products

Roughage Products

Molasses Products

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