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Consultation Summary on Nutrient Guarantees on Feed Labels – Respondent Comments and CFIA Responses

June 13 – July 15, 2016

Introduction

Building on considerable consultation, research, design and planning work completed over the past few years to continuously improve how the CFIA does business. The Agency is 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.

To maximize the Agency's capacity to respond to risk now and into the future, all work being done by the CFIA will align with these five priorities:

  1. Modern Regulatory Toolkit – Outcome-based regulations with new compliance promotion tools
  2. Integrated Risk Management – New risk management tools, analytics and surveillance to inform resource allocations and enforcement priorities
  3. Consistent and Efficient Inspections – Single inspection approach focused on regulatory outcomes and supported by mobile tools and guidance
  4. Digital-First Tools and Services – Electronic access as the preferred method of requesting and receiving services, and
  5. Global Leader – Pursue improved international standards, fairness in trade practices, enhanced use of technology and regulatory cooperation

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.

The requirement for nutrient guarantees on mixed feed labels is just one aspect of the Regulations that is being reviewed as part of the comprehensive modernization project. Currently, Table 3 of Schedule I of the Feeds Regulations specifies those nutrients that must be guaranteed on a label for all feeds of a similar type to provide relevant information to the purchaser when selecting feeds that best suits their livestock needs and requirements. In addition, feed manufacturers who wish to provide nutrient guarantees on their livestock feed labels that are not required by Table 3 are subject to mandatory registration of the product. The CFIA recognizes the inflexibility of the current approach and the regulatory burden associated with mandatory registration. Furthermore, there is the realization that additional nutrient guarantees, other than those listed in Table 3 of Schedule I, may be equally important in supplying meaningful and useful information to the purchaser.

The CFIA undertook a consultation from June 13, 2016 to July 15, 2016 on a proposal to continue to specify nutrient guarantees that must be included on a feed label based on the intended species and feed type. It was also proposed that certain other nutrient guarantees that are truthful, verifiable and not misleading, in addition to those required by regulation, be allowed on livestock feed labels in the future at the discretion of the packager ("voluntary guarantees"). Finally, the proposal indicated that these nutrient guarantees would be included in a document to be incorporated by reference in the Regulations to allow the flexibility to amend the list(s) in a timely manner, as necessary.

This report consolidates and summarizes the comments received in response to the nutrient guarantees on feed labels proposal and the CFIA's response to those comments.

Appendix I includes the revised required nutrient guarantees for specific feed articles and additional voluntary guarantees that may be included on feed labels, based on the feedback received.

The CFIA would like to thank everyone who participated in the consultation, for contributing their time to the consultation process and sharing their views.

About the consultation

The primary mode of consultation involved the preparation and posting of the Proposal – Required Nutrient Guarantees on the CFIA website, and outreach directly to industry stakeholders, government partners and CFIA staff. 16 sets of written comments were received in response to the nutrient guarantees proposal.

What we heard

Respondent profile

Table 1: Respondent profile
Category of Respondent Distribution
Feed Industry – Individual 9
Feed Industry – Association 4
Livestock Producer – Individual 0
Livestock Producer – Association 1
Other Feed Inputs 1
Government (Canadian Federal/Provincial) 1
Total 16

The feed industry association comments represent Canadian and American commercial feed manufacturers, as well as some larger feed ingredient supplier organizations. The Canadian feed manufacturers association represents 90% of commercial feed manufactured in Canada, while the US association represents about 75% of commercial feed manufactured in the US. The "Other Feed Inputs" listed in the table above included a response from an industry consulting firm.

Key respondent messages

There was considerable interest among respondents regarding the alternative oversight approach presented in this proposal. Respondents indicated they agreed with the concept of continuing to require certain mandatory nutrient guarantees on feed labels as well as permitting additional guarantees on a voluntary basis and felt this combined approach would:

While stakeholders provided many suggestions for improvement regarding the nutrient guarantees that would be required and those considered voluntary, the CFIA did not receive any comments indicating an outright disagreement with the proposed change to the current regulatory approach.

Very few comments were received from livestock producers or their associations; however, the limited comments the CFIA did receive focused mostly on the importance of continuing to require specific nutrient guarantees for specific feed types to enable producers to select feeds based on their needs.

Feedback on the proposed required nutrient guarantees

Format and incorporation by reference

The proposal suggested that the current Table 3 of Schedule I in the Feeds Regulations would be updated to ensure that the labeled nutrient guarantees continue to provide purchasers with useful information. In addition, it was further proposed that this table would be removed from the Regulations and replaced by a document to be incorporated by reference in the Regulations to provide increased flexibility in amending the guarantees in the future. 1 respondent suggested the revised nutrient guarantees table was difficult to follow and proposed using the format found in the Association of American Feed Control Officials (AAFCO) 2016 Official Publication instead. 2 respondents also questioned why the required nutrient guarantees for complete feeds differed from those required for supplements or premixes and felt these feed types should carry similar guarantees.

Those respondents commenting on the aspect of incorporating the requirements by reference in the Regulations were generally in agreement with this approach to allow updating of the document, as needed.

CFIA Response

To provide greater clarity on the nutrient guarantees required to be present on a livestock feed label, the CFIA intends to develop industry guidance regarding feed labelling and will consider the suggestion of including a summary table, similar to that found in the AAFCO 2016 Official Publication, as part of the guidance material.

The required nutrient guarantees are based on the intended use of the feed in question. For example, complete feeds are labelled in a way where the main nutrients are guaranteed on the label whereas a supplement is generally meant to provide a wider range of nutrient supplementation, such as multiple vitamins and minerals. Given this rationale it seems reasonable to maintain the current format for labeling complete feeds and supplements, however, manufacturers will be permitted to include additional voluntary nutrient guarantees on their feed label(s) (including labels for complete feeds), without requiring mandatory registration of the feed.

The CFIA will seek to incorporate this document by reference in the Regulations. In keeping with the CFIA's Incorporation by Reference Policy, the CFIA will provide a plan regarding the frequency and process for the review and revision of the incorporated document as part of the formal Canada Gazette Part I publication.

Suggestions for improvement

Purportedly present and copper guarantees for feeds

The details for guarantees outlined in the required nutrient guarantees list included the use of the term "purportedly present" for a number of nutrients throughout the list, including copper. The use of this term caused confusion for some respondents who questioned whether this would include background levels and one respondent suggested that any guarantee should only be based on what was intentionally added.
The proposal indicated that copper in a complete feed would be required to be guaranteed as a minimum amount in swine feeds and a minimum and maximum amount in sheep feeds. Additionally, copper in a supplement or premix, if intentionally added or purportedly present, must be included as a minimum amount in feeds for all species and as an actual amount for sheep feeds. 2 respondents commented on the wording of the required copper guarantee proposed, indicating:

CFIA Response

The term "purportedly present" has been included in Table 3 of Schedule I of the Feeds Regulations for many years and is used to identify the intrinsic presence of the specific nutrient in question. For example, the amount resulting from background levels of the nutrient originating from all ingredients being used in the formulation of the feed. In an attempt to provide greater clarity, "purportedly present" will be further defined in the incorporated document as part of the formal Canada Gazette Part I publication.

Given the toxic effects copper can have on sheep, it is important for the purchaser of feeds to be aware of the amount of copper intentionally added to the ration as well as any amount included as background levels from ingredients used in the feed, to allow for the safe use of the feed. To provide greater clarity with the labeling requirements in the future, the details for copper guarantees in complete feeds will be amended to include direction to account for added and background levels of copper. For example, "Minimum and maximum amount of copper, if intentionally added or purportedly present, in milligrams per kilogram". In addition, the details for copper guarantees in supplements and premixes will be amended to replace the term "actual" with "maximum". For example, "The maximum amount of copper in milligrams per kilogram". These amendments will clarify that manufacturers must account for intentionally added copper amounts as well as levels found in the associated ingredients being used when identifying the nutrient guarantee on the label.

Selenium, Grit, Fluorine and Zinc Guarantees for Feeds

The required nutrient guarantees list included a condition to guarantee selenium as a minimum amount, if intentionally added or purportedly present. One respondent commented that requiring minimum guarantees for selenium if intentionally or purportedly present would be difficult to determine given the fluctuation of ingredients being utilized with the industry practice of least cost formulation and the challenge of determining the selenium values for all ingredients used in a feed. Furthermore, it was suggested by this respondent that the only way of determining selenium levels is by an assay test which can provide quite variable results.

The required nutrient guarantees list included a condition to guarantee the maximum amount and kind of grit in complete feeds, supplements and premixes for poultry. One respondent questioned why the maximum per cent and kind of grit was a required nutrient guarantee and felt this guarantee provided limited information and should be included as a voluntary guarantee only.

The required nutrient guarantees list included a condition to guarantee the maximum amount of fluorine in supplements, premixes and mineral feeds. One respondent indicated that guarantees for fluorine for cattle, sheep and horses are redundant and serve no real purpose to the purchaser while another respondent suggested only guarantees that can be validated should be imposed.

The required nutrient guarantees list included a condition to guarantee the minimum amount of Zinc in complete feeds for swine rations. One respondent requested that this be removed from the proposed required nutrient guarantees list to mirror the direction taken by AAFCO.

CFIA Response

Selenium

While identifying the amount of selenium, or any nutrient, within the ingredients being used may pose a challenge initially, publications exist which contain ingredient nutrient profiles which could be referenced when determining the guarantees for a specific feed. Further to that, a facility may decide to implement a service agreement program requiring the seller of the ingredient to provide nutrient information of their product at time of sale, as part of a preventive control plan for the manufacturing facility.

Grit

The CFIA agrees with the comment that the maximum per cent and kind of grit should not be included in the proposed required nutrient guarantees list and commits to moving this guarantee to the voluntary nutrient guarantee list.

Fluorine

Based on the feedback received, and to provide a more consistent approach to contaminants, it has been decided that feed labels will not be required to guarantee fluorine. Fluorine limits currently listed in Section 19 (1)(b) of the Regulations have been included in the Proposal – Maximum Chemical Contaminant Levels in Livestock Feeds. Feed manufacturers are still responsible for ensuring that they do not exceed the maximums for fluorine.

Zinc

The CFIA appreciates the comments regarding zinc guarantees, but given the useful information this provides purchasers, the CFIA intends to continue to require minimum zinc guarantees on feed labels intended for swine.

Feedback on the proposed voluntary nutrient guarantees

Energy guarantees

The proposal suggested the minimum, maximum and actual guarantees for Energy would be permitted as a voluntary nutrient guarantee on feed labels and went on to include conditions allowing Energy to be further specified as Net Energy (NE), Digestible Energy (DE) or Metabolizable Energy (ME). 4 respondents indicated a concern with allowing this proposed voluntary guarantee, stating:

One of these respondents went on to suggest that if energy content is to be included as a voluntary guarantee, a standardized unit and measurement methodology should be included in the proposal to ensure consistent application of this guarantee so it will provide a meaningful comparison value for customers.

CFIA Response

The CFIA agrees with the respondents who indicated the guarantee for energy values, other than for gross energy, may be unsuitable (for example; misleading, non-verifiable) given there is no standardized methodology for confirming such guarantees. For this reason, the proposed list of voluntary nutrient guarantees (Appendix I) has been amended to exclude guarantees for any energy values, other than for gross energy.

Any manufacturer who wishes to use any other energy guarantee, for example, Net Energy (NE), Digestible Energy (DE) or Metabolizable Energy (ME), will have to apply for feed registration and provide scientific rationale and support for the use of that guarantee on feed labels.

Additional feedback

Suggested additions

In addition to the suggested improvements provided by stakeholders mentioned above, the CFIA received a number of additional recommendations to be included as voluntary nutrient guarantees, which are listed below.

Linoleic acid

2 respondents indicated a desire for a linoleic acid guarantee to be included as a voluntary nutrient guarantee, especially for poultry feeds. They suggested that linoleic acid is an essential nutrient for reproduction and is commonly considered in poultry formulations; however, it is currently not permitted to include these levels as a guarantee on the feed label.

Simple sugars

One respondent suggested including Simple Sugars. For example, ESC (Ethanol Soluble Carbohydrates) and Starch, as these guarantees are frequently being requested by customers and the analyses are routinely performed by most labs.

Target species

One respondent suggested that the voluntary nutrient guarantees list would be made easier to follow if each guarantee included a column to identify which species the guarantee applies to, similar to "Column III – Target Species" of the Required Nutrient Guarantees list.

CFIA Response

Linoleic acid

The CFIA appreciates the suggestion for the inclusion of linoleic acid as a voluntary nutrient guarantee; however, the fatty acid requirements have not yet been fully determined for most species. Therefore, at this time, it seems reasonable to continue to require anyone wishing to include this additional guarantee on a feed label to submit an application for registration and provide evidence to support the proposed inclusion rate. As the intent is to incorporate this document by reference in the Regulations, if the science allows for fatty acid requirements to be defined in the future, the list of voluntary guarantees can be modified accordingly.

Simple sugars

The CFIA agrees with the respondent that simple sugars would be a useful guarantee and commits to including the minimum, maximum or actual levels of any type of sugar and starch in the finalized voluntary nutrient guarantee list (see Appendix I).

Target species

While the target species column in the required nutrient guarantees list assists in clarifying which guarantees are applicable to which species, the same is not required in the voluntary nutrient guarantees list, as these guarantees are generally not species specific. Furthermore, for those limited guarantees that would be species specific, clarification will be provided in the "Conditions" column.

Process to update document

One respondent requested clarification from CFIA regarding the procedures to update or amend the nutrient guarantees list (required or voluntary) in this proposal, stating avenues should exist for industry or other stakeholders to petition the CFIA, through a scientific white paper or other means, for the inclusion of additional guarantees.

CFIA Response

In keeping with the CFIA's Incorporation by Reference Policy, the CFIA will provide a plan regarding the frequency and process for the review and revision of the incorporated document as part of the formal Canada Gazette Part I publication. Respondents will be provided the opportunity at this time to review and provide additional comments on the proposed procedures.

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. A draft of the Required Nutrient Guarantees List and the Voluntary Nutrient Guarantees List will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I – Tables of nutrient guarantees and conditions for feed labels

Table 1: Mandatory nutrient guarantees
Item Feed Article Particulars of guarantee (see note)
1. A complete feed
  1. Minimum per cent of crude protein, which shall include the equivalent crude protein content.
  2. If the feed is for feeding to ruminants, the maximum per cent of equivalent crude protein from non-protein sources intentionally or purportedly present.
  3. Minimum per cent of crude fat.
  4. Maximum per cent of fibre expressed as crude fibre or acid detergent fibre.
  5. Minimum per cent of the following: sodium (Na), calcium (Ca), phosphorus (P).
  6. If the feed is for feeding to swine, the minimum amount of zinc (Zn) and copper (Cu) in milligrams per kilogram.
  7. If the feed is for feeding to sheep, the minimum and maximum amount of copper, in milligrams per kilogram if intentionally or purportedly present.
  8. Minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product.
  9. If the feed is designed to replace whole milk, the minimum per cent of protein from milk sources.
  10. If the feed is for feeding to horses or rabbits, the minimum per cent of crude fibre.
  11. Minimum selenium in milligrams per kilogram, if selenium is intentionally or purportedly present.
  12. If the feed is for feeding to salmonid fish, the minimum Vitamin C in milligrams per kilogram if intentionally or purportedly present.
2. A supplement

In all cases where the nutrient is intentionally or purportedly present;

  1. Minimum per cent of crude protein, which shall include the equivalent crude protein content.
  2. If the feed is for feeding to ruminants, the maximum per cent of equivalent crude protein from non-protein sources.
  3. Minimum per cent of crude fat.
  4. Maximum per cent of fibre expressed as crude fibre or acid detergent fibre.
  5. Minimum per cent of the following: calcium (Ca), phosphorus (P), magnesium (Mg), sulfur (S), sodium (Na) or potassium (K).
  6. The minimum milligrams per kilogram of iodine (I), iron (Fe), copper (Cu), manganese (Mn), zinc (Zn), cobalt (Co) or selenium (Se).
  7. If the feed is for feeding to sheep, the maximum amount of copper in milligrams per kilogram
  8. The minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product.
3. A mineral feed

In all cases where the nutrient is intentionally or purportedly present;

  1. Minimum per cent of the following: calcium (Ca), phosphorus (P), magnesium (Mg), sulfur (S), sodium (Na) or potassium (K).
  2. Minimum amount in milligrams per kilogram of the following: iodine (I), iron (Fe), copper (Cu), manganese (Mn), zinc (Zn), cobalt (Co) or Selenium (Se).
  3. If the feed is for feeding to sheep, the maximum amount of copper in milligrams per kilogram.
  4. In the case of a mineral feed containing vitamins, the minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product, the minimum number of micrograms of vitamin B12 and biotin per kilogram of product and the minimum number of milligrams of any other vitamins per kilogram of product.
4. Premix (micro- and macro-)
  1. Minimum per cent of the following: calcium (Ca), phosphorus (P), magnesium (Mg), sulfur (S), sodium (Na) or potassium (K).
  2. Minimum amount in milligrams per kilogram of the following if any is intentionally or purportedly present: iodine (I), iron (Fe), cobalt (Co), manganese (Mn), zinc (Zn), copper (Cu) or selenium (Se).
  3. If the feed is for feeding to sheep, the maximum amount of copper if any is intentionally or purportedly present, in milligrams per kilogram.
  4. In the case of a premix containing vitamins, the minimum number of International Units of vitamin A, vitamin D or vitamin E per kilogram of product, the minimum number of micrograms of vitamin B12 and biotin per kilogram of product and the minimum number of milligrams of any other vitamin per kilogram of product, if intentionally or purportedly present.
5. Trace Mineral Salt Feed
  1. Minimum per cent of salt (NaCl)
  2. Minimum amount in milligrams per kilogram or any of the following that is intentionally or purportedly present: iodine (I), iron (Fe), copper (Cu), manganese (Mn), zinc (Zn), cobalt (Co) or selenium (Se).
6. A mixed feed not otherwise provided for in this Table
  1. Guarantees to describe the usefulness of the feed.
Table 2: Voluntary guarantees
Item Column I
Guarantee
Column II Guarantee Type
(Minimum, Maximum, Added or Actual)
Column III Units Column IV
Conditions
1. Gross Energy Min
Max
Actual
Kcal/kg
Cal/kg
Kjoules/kg
N/A
2. Crude Protein Any % N/A
3. Crude Fat Any % N/A
4. Fibre Any % Specify if it is:
Crude fibre
Acid Detergent Fibre (ADF)
Neutral Detergent Fibre (NDF)
5. Ash Min
Max
Actual
% Fish feeds only
6. Moisture Min
Max
Actual
% N/A
7. Salt (Sodium Chloride) Any % N/A
8. Amino acids Min
Max
% May not guarantee "amino acids", must specify the amino acid being guaranteed (e.g., lysine)
9. Vitamin A Any IU/kg N/A
10. Vitamin D Any IU/kg N/A
11. Vitamin E Any IU/kg N/A
12. Vitamin C Any mg/kg N/A
13. Calcium Any % May be expressed as Ca in the guaranteed analysis.
14. Phosphorus Any % May be expressed as P in the guaranteed analysis.
15. Magnesium Any % May be expressed as Mg in the guaranteed analysis.
16. Sulphur Any % May be expressed as S in the guaranteed analysis.
17. Sodium Any % May be expressed as Na in the guaranteed analysis.
18. Potassium Any % May be expressed as K in the guaranteed analysis.
19. Iodine Any mg/kg May be expressed as I in the guaranteed analysis.
20. Iron Any mg/kg May be expressed as Fe in the guaranteed analysis.
21. Copper Any mg/kg May be expressed as Cu in the guaranteed analysis.
22. Manganese Any mg/kg May be expressed as Mn in the guaranteed analysis.
23. Zinc Any mg/kg May be expressed as Zn in the guaranteed analysis.
24. Cobalt Any mg/kg May be expressed as Co in the guaranteed analysis.
25. Selenium Any mg/kg May be expressed as Se in the guaranteed analysis.
26. Fluorine Min
Max
mg/kg May be expressed as F in the guaranteed analysis.
27. Chromium Any mg/kg May be expressed as Cr in the guaranteed analysis.
28. Beta-carotene Min mg/kg Label must also guarantee Vitamin A. The Vitamin A guarantee must indicate that it includes Vitamin A activity from beta carotene.
29. B12 Any ug/kg May be expressed as cobalamin in the guaranteed analysis
30. Biotin Any ug/kg N/A
31. Thiamine Any mg/kg May be expressed as Vitamin B1 in the guaranteed analysis.
32. Riboflavin Any mg/kg May be expressed as Vitamin B2 in the guaranteed analysis.
33. Niacin Any mg/kg May be expressed as Vitamin B3 in the guaranteed analysis.
34. Pantothenic Acid Any mg/kg May be expressed as Vitamin B5 in the guaranteed analysis.
35. Pyridoxine Any mg/kg May be expressed as Vitamin B6 in the guaranteed analysis.
36. Folic Acid Any mg/kg May be expressed as Vitamin B9 in the guaranteed analysis.
37. Menadione Any mg/kg May be expressed as Vitamin K3
38. Menadiole diacetate Any mg/kg May be expressed as Vitamin K4
39. Choline Any mg/kg N/A
40. Inositol Any mg/kg N/A
41. Betaine Any mg/kg N/A
42. Grit Any % For poultry feeds only
43. Sugars Any % May not guarantee "sugars", must specify the sugar being guaranteed (e.g., sucrose, glucose, etc.)
44. Starch Any % N/A
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