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What we heard report - Consultation on maximum nutrient values in fish feeds (freshwater and marine) - Respondent comments and CFIA responses

Respondent Comments
and CFIA Responses

February 23 – March 30, 2018

On this page

Purpose

This report consolidates and summarizes the comments received regarding the Canadian Food Inspection Agency's (CFIA) Proposal - Maximum Nutrient Levels in Fish Feeds and the CFIA's response to those comments.

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 the these five priorities:

  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 contribute 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 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 Canadian Food Inspection Agency (CFIA) has embarked on a comprehensive change agenda to strengthen its foundation of legislation, regulatory programs and inspection delivery. These directions set the context for the renewal of the Feeds Regulations (Regulations).

The goal of modernizing the Regulations is to reduce compliance burden and support innovation, while ensuring 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 modernization of the Regulations is being designed to benefit the collective Canadian feed industry, which includes livestock producers, commercial feed manufacturers, retailers, importers, exporters, ingredient manufacturers, and food processors. As well as aligning with other international feed regulatory regimes, modernization also maintains the objective of enhancing animal health and food safety for the Canadian public.

The oversight of maximum nutrient values in feeds is just one aspect of the Regulations that is being reviewed as part of the comprehensive modernization project. 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 registration. Currently, if a complete feed provides nutrients which fall within the ranges listed in Table 4, or a supplement has directions for use which would result in a complete feed that provides nutrients which fall within the Table 4 ranges, the feed can be exempted from registration. 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.

The values in Table 4 no longer have the same nutritional relevancy that they did when the table was first introduced. Stakeholders have also indicated that they feel Table 4 prevents innovation for new feed products, however, many of the maximum nutrient limits which are currently set in Table 4 have health and safety implications that must be considered.

About the consultation

The CFIA undertook a consultation from February 23, 2018 to March 30, 2018 on a proposal to identify maximum nutrient values in fish (freshwater and marine) feeds. It was also proposed that Table 4 be removed from the Regulations and no longer serve as a trigger for registration of feeds based on specified ranges of nutrient content. Finally, the proposal indicated that these maximum nutrient values would be included in a document to be incorporated by reference in the Regulations to allow the flexibility to amend the lists in a timely manner, as necessary.

The primary mode of consultation involved the preparation and posting of the Proposal – Maximum nutrient values in fish feeds (freshwater and marine) – on the CFIA website, and outreach directly to industry stakeholders, government partners and CFIA staff. 6 sets of written comments were received.

This report consolidates and summarizes the comments received on the maximum nutrient values in fish feeds proposal and the CFIA's response to those comments.

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

What we heard

Respondent profile

Table 1: Respondent profile
Category of Respondent Distribution
Feed Industry – Individual 3
Feed Industry – Association 2
Livestock Producer – Individual 0
Livestock Producer – Association 0
Other Feed Inputs 1 (academic institution)
Government (Canadian Federal/Provincial) 0
Total 6

Comments were received from feed industry associations which represent Canadian commercial feed manufacturers, and from individuals within the feed industry. The Canadian feed manufacturers association represents 90 percent of commercial feed manufactured in Canada. The "Other Feed Inputs" listed in the table above included a response from a Canadian University.

Key respondent messages

While stakeholders provided suggestions for improvement regarding the proposed maximum nutrient values for fish feeds (freshwater and marine), the CFIA did not receive any comments indicating an outright disagreement with the proposed regulatory approach.

Respondents indicated they agreed with the concept of discontinuing the use of Table 4 as a means of exempting feeds from registration, however, they also raised some concerns regarding the proposal, including:

More detailed discussion on these concerns and the CFIA's responses follows below.

Feedback on the proposed maximum nutrient values in fish feeds

Scope of the proposal

The scope of the proposal included determining those nutrient values that may impact the health and safety of the respective livestock, humans, and environment; determining those nutrient values that support a nutritional purpose as opposed to a therapeutic purpose; and, determining those nutrient values that may produce residues in the resulting food that could be harmful to those consuming the products. 3 respondents commented on the stated scope of this proposal. All respondents provided positive support for the replacement of, or at least changes to, Table 4 values with scientific-based nutrient values, and understood that changes to Table 4 would increase the number of feeds that would not require registration. One respondent provided a comment that minimum levels of nutrients are a greater concern than proposing maximum nutrient values.

CFIA response

In general, positive feedback and support was provided on the scope of this proposal. One respondent mentioned that minimum levels of nutrients are a greater concern than proposing maximum levels of nutrients. As mentioned previously, feeds will need to be suitable for their intended purpose which includes meeting the minimum nutritional needs and requirements for the intended livestock species. CFIA focussed on setting maximum nutrient values where animal health and food safety impacts were more likely to be observed.

List of fish families

The proposal included a list of the current and proposed fish families. As was noted in the comments received during the consultation process and previous discussions with the aquaculture industry, the list of fish raised commercially for human consumption is expanding and will continue to expand in the future. Currently, the definition of livestock includes "fish". There are only nutrient ranges listed in Table 4 of the Regulations for salmonids, which means feeds for other species of fish require registration. In the proposal, a list of fish families was elaborated with species examples. 1 respondent commented that certain fish species, like catfish and Arctic Char should be included in the proposed list.

CFIA response

Based on the comments received, additional examples of fish species will be included for each fish family. This will provide greater clarification on the fish species for which maximums have been considered based on commercial aquaculture and will allow for expanding the list of fish species as the commercial aquaculture feed industry continues to grow.

It is anticipated that the Regulations will state "fin fish" instead of indicating each fish family and species. This means that feed for all fish continue to be regulated. The list of family families and fish species will be useful information for regulated parties and may be included in regulatory guidance documents and in documents incorporated by reference. This will allow different maximum nutrient values to be set for certain fish families. For example, the CFIA is proposing different maximum vitamin A values for different fish families or species. These are based on the tolerance of certain fish families or species (e.g., salmonids) to higher amounts of vitamin A compared to other fish families and differences in rates of vitamin accumulation.

Fish families
Proposed list of fish families Revised list of fish families
Salmonids (Salmon, Trout, etc.)
Cichlids (Tilapia, etc.)
Anoplopomatids (Sablefish, etc.)
Pleuronectids (Halibut, Sole, etc.)
Percids (Perch, etc.)
Other (remaining commercially raised fish species)
Salmonids (Salmon, Trout, Arctic Char, etc.)
Cichlids (Tilapia, etc.)
Anoplopomatids (Sablefish, etc.)
Pleuronectids (Halibut, Sole, etc.)
Percids (Perch, etc.)
Other (Catfish, remaining commercially raised fish species)

Macro-minerals

Calcium (Ca) and Phosphorus (P)
Nutrient No. of respondents with comments No. in agreement with proposed values No. not in agreement - Summary of feedback
Calcium (Ca) 0 0 0
Phosphorus (P) 2 0 1 – proposed maximum value of 3.5% is too high and rationale to support the higher maximum value was not robust.
1 – phosphorus supplied in excess of dietary needs results in increased levels of phosphorus in the environment and implications to meet federal and provincial aquaculture regulations.

2 respondents provided comments regarding the proposed maximum phosphorus value for fish. Both respondents felt the proposed value was high and should be decreased. No comments were provided regarding the proposed maximum calcium value for fish.

CFIA response
Calcium:

No comments were received indicating a concern with not proposing a maximum value for calcium for fish; as such the CFIA will proceed with not setting a maximum value for calcium at this time.

Phosphorus:

After careful review and consideration of the comments from all respondents, the CFIA will proceed with the maximum value for phosphorus identified in the proposal (i.e., the maximum nutrient value of 3.5 percent). The proposal had stated,

"Increasing total phosphorus to greater than 2.0 percent of the diet results in poor feed conversion ratios, reduced growth, and increased mortalities (Skonberg et al., 1997; Fontagne et al., 2009)"

However, it failed to indicate that these studies were done with semi-purified diets and did not balance the ratio of calcium and phosphorus. Phosphorus is adequately tolerated at the proposed nutrient value of 3.5 percent if appropriately balanced at a 1:1 calcium to phosphorus ratio (Hossain and Yoshimatsu, 2014).

Environmental impacts were considered when the maximum nutrient value for phosphorus of 3.5 percent was proposed. The CFIA recognizes that the environmental aspects of the aquaculture industry are well regulated in Canada with federal and provincial regulations. For example, the Aquaculture Activities Regulations (AAR) outline specific environmental monitoring (water quality and sediment) and sampling requirements that are to be conducted by industry. Authorities in other jurisdictions (for example, provincial/municipal) may overlay requirements that are more stringent than those being proposed. While the management of environmental outputs related to aquaculture activities should take into account feed inputs, limiting the nutrient content in the feed is not the only measure that can be taken to manage environmental releases.

In addition, it is important to note that the maximum nutrient values are not target values. The aquaculture industry should not be aiming for or targeting the maximum values for nutrients. The industry should be formulating diets that are balanced in nutrients, including the correct phosphorus to calcium ratio. The nutrient profile of the ingredients should be known and typical of what is available and used within the industry. This includes ingredients that tend to have elevated levels of certain nutrients (for example, phosphorus). In addition, having a diet that is formulated with the correct phosphorus to calcium ratio is important and tends to mitigate toxicity.

The current, proposed and revised nutrient phosphorus values are set out in the table below.

Calcium and Phosphorus
Current
(% of complete feed, as fed)
Proposed
(% of diet at 88% dry matter)
Revised
(% of diet at 88% dry matter)
2.5 3.5 3.5
Magnesium, Sodium, Potassium and Sulfur

No comments or feedback were received with regards to the proposed maximum values of magnesium, sodium, potassium and sulfur for fish.

CFIA response
Magnesium:

No comments were received indicating a concern with the proposed maximum magnesium value of 0.3 percent of diet at 88 percent dry matter for fish; as such the CFIA will proceed with the maximum values for magnesium identified in the proposal.

Sodium:

No comments were received indicating a concern with not proposing a maximum value for sodium for fish; as such the CFIA will proceed with not setting a maximum value for sodium at this time.

Potassium:

No comments were received indicating a concern with not proposing a maximum value for potassium for fish; as such the CFIA will proceed with not setting a maximum value for potassium at this time.

Sulfur:

No comments were received indicating a concern with not proposing a maximum value for sulfur for fish; as such the CFIA will proceed with not setting a maximum value for sulfur at this time.

Trace minerals

Cobalt, Copper, Iodine and Iron
Nutrient No. of respondents with comments No. in agreement with proposed values No. not in agreement - Summary of feedback
Cobalt (Co) 0 0 0
Copper (Cu) 2 0 1 – proposed maximum value is too low and value should be maintained at 75 mg/kg.
1 – question the scientific references reporting copper toxicity and its use in establishing the proposed maximum value and rationale of copper levels in fish feed and impact on AMR.
Iodine (I) 1 0 1 – rationale for increasing the value of iodine in fish feeds considering concerns related to iodine in milk and the use of fish meal in dairy production.
Iron (Fe) 1 0 1 – rationale for increasing the value of iron in fish feeds was not robust.

No comments were provided regarding the proposed maximum cobalt value for fish. 2 respondents provided comments regarding the proposed maximum copper value for fish. Both respondents felt the proposed value was too low and should be increased, and one respondent had concerns with regards to the level at which adverse effects were observed and had concerns on the impact of copper levels on antimicrobial resistance (AMR). 1 respondent commented that they felt that the justification for the proposed maximum iodine value was not robust. Another respondent had a similar comment regarding the proposed maximum iron value.

CFIA response
Cobalt:

No comments were received indicating a concern with maximum nutrient value of 3 mg/kg for cobalt for fish; as such the CFIA will proceed with a maximum nutrient value of 3 mg/kg for cobalt as identified in the proposal.

Copper:

References indicated within the considerations of the proposal did not constitute the complete body of literature reviewed; additional references are available upon request. Generally:

  • NRC (2005) set the maximum tolerable levels of diet-borne copper at 100 and 500 mg Cu/kg diet for Atlantic salmon and rainbow trout, respectively, further stating that for fish tolerances are affected by species, fish size, and life stage.
  • Clearwater et al. (2002) comprehensively reviewed the literature and defined toxicity thresholds as daily doses of
    • 1 mg Cu/kg body weight/d for channel catfish (fed 40 mg Cu/kg of feed),
    • 1–15 mg Cu/ kg body weight/d for Atlantic salmon, depending on the life stage, (parr fed 34 mg Cu/kg of feed ; fry fed 467 mg Cu/kg of feed)
    • 44 mg Cu/kg body weight/d for rainbow trout (fed 730 mg Cu/kg of feed)
  • EFSA Panel on Additives and Products or Substances used in Animal Feed (FEEDAP) (2016) reviewed copper as a feed additive including its use in fish feeds maintaining the currently authorized maximum in the EU is 25 mg/kg (Com. No. 1334/2003) with the following observations:
    • overloading of copper in fish can be deleterious and triggers growth retardation, histological alterations and oxidative stress
    • responses to chronic copper exposure via feed or water include increased oxygen consumption, reduced average swimming speed, increased ion regulation, decreased number of lymphocytes and increased neutrophils, effects on the immune system, altered activity of Cu-dependent and -independent enzymes, and proliferation of epithelial cells in gills or intestine
      • a threshold level of dietary copper toxicity in Atlantic salmon parr could be as low as 1 mg Cu/kg bw per day (34 mg Cu/kg complete feed)
      • dietary toxicity of copper measured as growth inhibition in rainbow trout occurs at approximately 664–730 mg Cu/kg feed corresponding to 44 mg Cu/kg bw/day
      • reduced specific growth rate was observed in juvenile rockfish, Sebastes schlegeli exposed to copper concentrations above 50 mg/kg
      • growth performance was significantly impaired in Nile tilapia (Oreochromis niloticus) fed the diets with 1,095 or 1,609 Cu/kg DM, and fish in these groups had significantly reduced red blood cell counts, haemoglobin, haematocrit and total plasma protein levels compared to the control (17.2 Cu/kg DM)
  • Included in EFSA 2016 report is a review of the influence of copper in animal nutrition on the development of antimicrobial resistance of bacteria in the environment. Additional references (Baker-Austin et al 2006, Seiler and Berendonk 2012, Singer et al 2016) were also consulted.

Fish dietary requirements for copper range from 1.5 to 10 mg/kg. The apparent range in copper tolerance between species of fish could allow for species specific maximum tolerances. However, considering environmental and co-selection of antimicrobial resistance concerns associated with excessive Cu (and Zn) setting a maximum based on the least tolerant species is warranted. Based on the information reviewed Atlantic Salmon and Channel Catfish appear to be less tolerant to excessive levels of dietary copper compared to other fish species with adverse effects being noted between 30 and 40 mg Cu/kg feed.

Based on the scientific literature and the comments received from the respondents, the CFIA intends to maintain the proposed maximum of 30 mg/kg copper for fish.

The proposed modification is set out in the table below.

Copper
Current
(% of complete feed, as fed)
Proposed
(% of diet at 88% dry matter)
Revised
(% of diet at 88% dry matter)
75 30 30
Iodine:

Feedback was received that the rationale for increasing the maximum iodine value from 20 mg/kg to 70 mg/kg was not well explained failing to address concerns related to iodine levels in milk and what the impact could be of using fish meal in dairy production. In the previous proposal and consultation summary for maximum nutrient values of beef and dairy cattle feeds, maximum values for iodine were proposed that considered issues related to iodine content in milk. The proposed maximum content of iodine in feeds for dairy cattle was reduced from 10 mg/kg to 2.5 mg/kg of diet on a dry matter basis and must consider iodine whether intentionally or purportedly present.

The current, proposed and revised nutrient iodine values are set out in the table below.

Iodine
Current
(% of complete feed, as fed)
Proposed
(% of diet at 88% dry matter)
Revised
(% of diet at 88% dry matter)
20 70 70
Iron:

Feedback was received that the rationale for increasing the maximum iron value from 500 mg/kg to 750 mg/kg was not well explained. The scientific literature was revisited. Based on the available scientific literature, fish appear to tolerate elevated levels of iron in their diets. No adverse effects were reported in fish fed diets containing hundreds of mg/kg of iron and no adverse effects were observed when fish were fed below 750 mg/kg of iron. EFSA concluded the maximum authorized iron content in feeds of 750 mg/kg for other species is safe. EFSA also stated that as a provisional measure, the current value for other animal species (750 mg iron/kg) could be maintained. Additional data could be provided in the future to modify the maximum iron value in feed for fish.

The current, proposed and revised nutrient iron values are set out in the table below.

Iron
Current
(% of complete feed, as fed)
Proposed
(% of diet at 88% dry matter)
Revised
(% of diet at 88% dry matter)
500 750 750
Manganese, Selenium and Zinc
Nutrient No. of respondents with comments No. in agreement with proposed values No. not in agreement - Summary of feedback
Manganese (Mn) 0 0 0
Selenium (Se) 3 1 2 – proposed maximum value is too low and should be increased to 4 mg/kg.
1 – question the scientific references reporting selenium toxicity and levels of selenium in fish-based feed ingredients.
Zinc (Zn) 2 0 1 – proposed maximum value is too low and value should be maintained at 300 mg/kg.
1 – understanding the rationale of zinc levels in fish feed and impact on AMR.

No comments were provided regarding the proposed maximum manganese value for fish. Respondents provided comments regarding the proposed maximum nutrient values for selenium and zinc, indicating the proposed values were too low. Respondents also had concerns with regards to the level at which adverse effects were observed for selenium and the levels of selenium found in feed ingredients. 1 respondent had concerns on the impact of zinc levels on antimicrobial resistance (AMR).

CFIA response
Manganese:

No comments were received indicating a concern with maximum nutrient value of 150 mg/kg for manganese for fish; as such the CFIA will proceed with a maximum nutrient value of 150 mg/kg for manganese as identified in the proposal.

Selenium:

After careful review of the scientific literature and consideration of the suggested values from all respondents, the CFIA intends to maintain the proposed maximum selenium value in fish feed of 2.0 (total) mg/kg.

A total selenium value of 2 mg/kg should be achievable in feeds for fish, based on the levels of selenium in most fish meal and fish oil ingredients. CFIA recognizes that some fish-based feed ingredients contain very high levels of selenium and therefore these will need to be used sparingly in the manufacturing of complete fish feeds. However, as most fish-based ingredients are not found to contain high levels of selenium, the impact on the availability of these ingredients with acceptable levels of selenium should be minimal.

While respondents requested a maximum selenium value of 4 mg/kg, the safety data available does not support that level. Hilton et al. 1980 reported that dietary selenium levels in excess of 3.67 mg/kg (nominal concentration of 3 mg/kg) may be toxic to rainbow trout over long periods of time. The authors also reported higher levels of selenium in tissues of fish fed diets containing 3.67 mg/kg and 13.06 mg/kg of selenium. This may indicate the inability of trout to effectively regulate excess dietary selenium levels in the diets they were fed. Since no signs of selenium toxicity were observed in the fish fed the 3.67 mg/kg of selenium, there is a possibility that trout may be able to regulate excess dietary selenium levels during the short-term.

NRC 2005 reports that the minimum requirement of selenium in rainbow trout was 0.15 to 0.38 mg/kg of dry feed, the definite toxic level was 13 mg selenium/kg diet and the possible toxic level with prolonged exposure was 3 mg selenium/kg. In most cases, reduced growth rate or survival occurred at dietary selenium levels close to 3 mg/kg or at whole-body selenium results close to 4 mg/kg.

Feedback from stakeholders indicated that a total selenium maximum of 1 mg/kg was achievable in feeds for terrestrial livestock species, and therefore proposing the total selenium of 2 mg/kg for fish feeds would be achievable taking into account elevated levels of selenium in raw ingredients used in the manufacturing of fish feeds and the potential for selenium to accumulate in fish. The European Union has set a level of 0.5 mg total Se/kg of compete feed with a moisture content of 12 percent for all animal species. The EU maximum level limits the content of organic forms of selenium to 0.2 mg/kg. CFIA is proposing a maximum selenium value for fish feeds that is significantly higher than the current maximum level set by the European Union and CFIA's proposed maximum selenium value of 1.0 (total) for terrestrial livestock species.

Recent work by Environment and Climate Change Canada under the Chemical Management Plan highlights the need for risk management measures to reduce selenium releases caused or influenced by humans into water. This would include releases from agriculture and aquaculture practices, including releases from feed. A standard based on total selenium rather than added selenium limits inputs in feeds, thereby reducing agricultural and aquaculture releases. It also addresses the need to limit selenium transfer to foods of animal origin.

The current, proposed and revised nutrient selenium values are set out in the table below.

Selenium
Current
(% of complete feed, as fed)
Proposed
(% of diet at 88% dry matter)
Revised
(% of diet at 88% dry matter)
0.1 (total) 2.0 (total) 2.0 (total)
Zinc:

After review of the scientific literature and consideration of the suggested values from all respondents, the CFIA intends to maintain current maximum zinc value in fish feed of 300 mg/kg.

  • This value exceeds the maximum noted in NRC (2005) recommendation of 250 mg/kg however no rationale could be found to support 250 mg/kg.
  • EFSA FEEDAP, 2014 suggests a reduction in the allowable zinc in fish feed from 200 mg/kg feed to 150mg/kg for salmonids and 100mg/kg for other fish species in order to reduce environmental impacts.
    • It was derived from the zinc requirement (not the tolerance) accounting for inter- and intra-species variation, source bioavailability, interactions with other nutrients and anti-nutrients (iron, copper, calcium, phytate), and allowing for additional zinc content equivalent to background.
  • Reduction of zinc levels may be beneficial to help reduce the emergence and spread of antimicrobial resistance (AMR).
    • Concentrations of zinc in water ranging from 19.6 to 98.07 µg/L and in sediment of 46.1 to 800 mg/kg have been found to be co-selective for AMR (Seiler et al. 2012; Stepanauskas et al. 2005; Graham et al. 2011).
    • Information on the impact of zinc supplementation in aquaculture and the concentrations in water and sediment is lacking at this time.
    • Environmental monitoring of these impacts could be considered in the future.
Zinc
Current
(% of complete feed, as fed)
Proposed
(% of diet at 88% dry matter)
Revised
(% of diet at 88% dry matter)
300 250 300

Vitamins

Vitamin A, Vitamin C, Vitamin D and Vitamin E
Nutrient No. of respondents with comments No. in agreement with proposed values No. not in agreement - Summary of feedback
Vitamin A
(Vit A)
1 0 1 – maximum vitamin A value is too low for tilapia to meet their nutritional needs in certain aquaculture environments (i.e., recirculation aquaculture system) and proposed a minimum vitamin A value of 12,000 IU/kg.
Vitamin C
(Vit C)
0 0 0
Vitamin D
(Vit D)
2 0 1 – maximum vitamin D value is too low and proposed a maximum value of 60,000 IU/kg (or 1.5 mg/kg).
1 – concerns with vitamin D fortification of fish flesh/fillets being a consideration.
Vitamin E
(Vit E)
0 0 0

No comments were provided regarding the proposed maximum values vitamin C and vitamin E for fish. Respondents provided comments indicating the proposed maximum nutrient values for vitamin A and vitamin D were too low.

CFIA response
Vitamin A:

After careful review of additional scientific literature and consideration of the suggested maximum values from respondents for vitamin A levels in fish feed, the CFIA intends to increase the proposed maximum vitamin A value in feed for cichlids (including tilapia) to 25,000 IU/kg.

No risk to animal health or food safety would be anticipated with the maximum vitamin A value being increased to 25,000 IU/kg in feeds for cichlids.

The proposed modification is set out in the table below.

Vitamin A
Class Current
(IU/kg)
Proposed
(IU/kg of diet at 88% dry matter)
Revised
(IU/kg of diet at 88% dry matter)
Salmonids 25,000 100,000 100,000
Cichlids N/A
(not applicable)
10,000 25,000
Anoplopomatids N/A
(not applicable)
25,000 25,000
Pleuronectids N/A
(not applicable)
25,000 25,000
Percids N/A
(not applicable)
25,000 25,000
Other N/A
(not applicable)
25,000 25,000
Vitamin C:

No comments were received indicating a concern with not proposing a maximum value for vitamin C for fish; as such the CFIA will proceed with not setting a maximum value for vitamin C at this time.

Vitamin D:

After review of additional scientific literature and consideration of the suggested values from all respondents for vitamin D levels in fish feed, the CFIA intends to maintain the proposed maximum vitamin D value in fish feed at 10,000 IU/kg, including for salmonid fish feeds.

In the EFSA 2017 report, it was concluded that safety was demonstrated at 60,000 IU vitamin D3/kg (1.5 mg/kg) in compound feed for salmonids with a margin of safety of at least 10. Salmonids are highly tolerant to vitamin D3 compared to other fish species. This report also concluded that there were insufficient data to establish a level of vitamin D3 for other fish species. The Expert Panel could not conclude on the safety of a level of 1.5 mg Vitamin D3/kg in fish species other than salmonids. It should be noted that data related to ergocalciferol (Vitamin D2) were not considered since there are no approved sources of vitamin D2 in livestock feeds, including fish feeds.

The study by Andrews et al. 1980 and Brown et al. 1992, provided data to support that channel catfish may be able to tolerate higher levels of vitamin D (20,000 IU/kg diet or 1,000,000 IU/kg diet) in their diets. The levels are higher than the dietary requirements of vitamin D3 for these fish and data for transfer to foods has not been provided.

The major sources of vitamin D for humans are fortified foods. The main natural sources of vitamin D in the Canadian food supply are fatty fish and egg yolks. The levels of vitamin D reported in fish products as per Health Canada's Canadian Nutrient File (CNF) is reported below.

Raw fish
Food Code Food Name Vitamin D (µg/100g) Vitamin D (IU/100g)
3013 Fish, halibut, Greenland (turbot), raw 27.4 1097
5840 Fish, arctic char, native, meat and skin, raw 13.3 530
2993 Fish, catfish, channel (bullhead), wild, raw 12.5 500
3205 Fish, trout, rainbow, wild, raw 6.6 265
3049 Fish, salmon, Atlantic, wild, raw 6.4 255
3182 Fish, salmon, Atlantic, farmed, raw 6 241
3186 Fish, trout, rainbow, farmed, raw 5.4 215
3200 Fish, halibut, Atlantic or Pacific, raw 3.8 150
5966 Fish, tilapia, raw 3.1 124
3021 Fish, mackerel, Atlantic, raw 2 81
3091 Fish, catfish (wolffish), Atlantic, raw 1.3 52
3180 Fish, catfish, channel (bullhead), farmed, raw 0.2 9
Fish oils
Food Code Food Name Vitamin D (µg/100g) Vitamin D (IU/100g)
457 Fish oil, cod liver 232 9280
462 Fish oil, sardine 8.3 332
461 Fish oil, salmon 4.4 177

The EFSA 2017 report also looked at the transfer of vitamin D from fish feeds to fish flesh/fillet. The transfer of vitamin D3 from feed to salmonid flesh is variable and likely due to a number of factors. When uncertainty is taken into account, for high supplementation levels the transfer ratio is estimated to be in the range of 0.1 to 0.15. When the proposed increase of vitamin D3 in feed for salmonids is 60,000 IU/kg (1.5 mg/kg), the vitamin D3 content in the fish flesh would be expected to range from (600 to 900 IU/100g (15.0 to 22.5 μg/100g) an increase of 2.4 to 3.7 times the amounts reported in the CNF for raw farmed or wild Atlantic salmon.

Given the magnitude of transfer and its increase relative to vitamin D levels found in the CNF for fish flesh, and considerations for the impact of concentration of vitamin D in salmon fish oil, the Animal Feed Division is consulting with Health Canada's Food Directorate. Guidance and clarification are being sought regarding rules on voluntary and mandatory nutrient fortification of foods and the impact of defining a maximum in feeds that significantly increases the vitamin D content in salmon flesh and oil.

The proposed modification is set out in the table below.

Vitamin D
Class Current
(IU/kg)
Proposed
(IU/kg of diet at 88% dry matter)
Revised
(IU/kg of diet at 88% dry matter)
Salmonids 10,000 10,000 10,000
Cichlids N/A
(not applicable)
10,000 10,000
Anoplopomatids N/A
(not applicable)
10,000 10,000
Pleuronectids N/A
(not applicable)
10,000 10,000
Percids N/A
(not applicable)
10,000 10,000
Other N/A
(not applicable)
10,000 10,000
Vitamin E:

No comments were received indicating a concern with not proposing a maximum value for vitamin E for fish; as such the CFIA will proceed with not setting a maximum value for vitamin E at this time.

Additional respondent feedback

1 respondent inquired whether feeds for lobster and shrimp, which are commercially raised for human consumption, would be regulated by CFIA. 2 respondents identified that the composition of fish feeds are changing from traditional fish feeds containing fish meal and fish oil to fish feeds containing predominantly plant-based and algae-based feed ingredients. 3 respondents provided comments on the environmental impacts of certain nutrients entering the aquatic environment when used in fish feeds. This included concerns about excess nutrients entering the aquatic environment, the susceptibility of the aquatic environment to contaminants and the complications when this industry is regulated by multiple federal and provincial governments that may focus on environmental concerns.

CFIA response
Regulation of feeds for crustaceans:

In the future, CFIA intends to regulate feeds for crustaceans (for example, lobster, shrimp, etc.) and molluscs as these industries are growing and are being commercially raised for human consumption in Canada. The intent of CFIA is to include and define crustaceans and molluscs as livestock in the new Feeds Regulations, in addition to fin fish.

It is anticipated that maximum nutrient values will be established for crustacean feeds in the future and may be similar to the nutrient values proposed for fish.

Composition of fish feeds:

CFIA recognizes and is aware of the changes in the raw ingredients being used in aquaculture feeds. Traditionally, fish meal and fish oil were predominantly used in the manufacturing of commercial fish feeds. Recently, alternatives (such as, plant-based and algae-based feed ingredients) are being used to replace fish oil and fish meal. There are likely a number of reasons why alternative feed ingredients are being used in the production of commercial fish feed. In order to ensure a well-balanced and nutritionally efficient diet for fish, the nutritional profile of these alternative feed ingredients need to be considered. Both the nutritional and contaminant profile of a feed will change when fish meal and fish oil are removed or when the content of fish meal and fish oil in fish feeds are reduced. These changes in the composition of fish feeds should not have an impact of the maximum nutrient values, as fish feeds are still required to be safe and effective for their intended purpose, regardless of changes to the composition of the feed.

Environmental impacts and sustainability:

CFIA recognizes that the impacts of the aquaculture industry on the aquatic environment are already well managed by different levels of government. The aquaculture industry needs to comply with a number of regulations at the federal government level as well as the provincial and territorial level. The provincial and territorial governments are the primary regulators and leasing authorities for aquaculture for most provinces. The federal government has responsibility for navigation, disease prevention affecting international trade, and the environment. The Aquaculture Activities Regulations (AAR) were specifically designed to address concerns regarding environmental risk impacts (water quality, wild fish, fish habitat, etc.) associated with the deposit of substances (e.g. drugs, pest control products, feed, feces, etc.) into water. The AAR also provides clarification to operators on the installation, operation, maintenance, or removal of a facility and measures to treat diseases and parasites as well as the deposition of organic matter.In addition, the AAR outlines specific environmental monitoring and sampling requirements, which includes sediment and water quality monitoring.

The proposed nutrient values for fish feeds were not set based on environmental impacts. As the aquaculture industry is responsible for complying with provincial and federal rules with respect to environmental impacts, the impact of the feed they use must also be considered. Leaving the nutrient maximums within the food safety and animal health ranges allows flexibility for the aquaculture industry to use other measures to meet their environmental protection obligations.

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 Maximum Nutrient Values in Fish Feeds (freshwater and marine) will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I – Proposed maximum nutrient values for fish feeds (freshwater and marine)

List of fish families

Proposed list of fish families Revised list of fish families
Salmonids (Salmon, Trout, etc.)
Cichlids (Tilapia, etc.)
Anoplopomatids (Sablefish, etc.)
Pleuronectids (Halibut, Sole, etc.)
Percids (Perch, etc.)
Other (remaining commercially raised fish species)
Salmonids (Salmon, Trout, Arctic Char, etc.)
Cichlids (Tilapia, etc.)
Anoplopomatids (Sablefish, etc.)
Pleuronectids (Halibut, Sole, etc.)
Percids (Perch, etc.)
Other (catfish, remaining commercially raised fish species)

Macro-minerals

Phosphorus (P)
Class Proposed
(%, at 88% dry matter [DM] Table Note 1)
Revised
(%, at 88% dry matter [DM] Table Note 1)
Fish (All) 3.5 3.5

Table Notes

Table note 1

88 percent dry matter basis (or 12% moisture content)

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Magnesium (Mg)
Class Proposed
(%, at 88% dry matter [DM] Table Note 2)
Revised
(%, at 88% dry matter [DM] Table Note 2)
Fish (All) 0.3 0.3

Table Notes

Table note 2

88 percent dry matter basis (or 12% moisture content)

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Trace minerals

Cobalt (Co)
Class Proposed
(%, at 88% dry matter [DM] Table Note 3)
Revised
(%, at 88% dry matter [DM] Table Note 3)
Fish (All) 3 3

Table Notes

Table note 3

88 percent dry matter basis (or 12% moisture content)

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Copper (Cu)
Class Proposed
(%, at 88% dry matter [DM] Table Note 4)
Revised
(%, at 88% dry matter [DM] Table Note 4)
Fish (All) 30 30

Table Notes

Table note 4

88 percent dry matter basis (or 12% moisture content)

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Iodine (I)
Class Proposed
(%, at 88% dry matter [DM] Table Note 5)
Revised
(%, at 88% dry matter [DM] Table Note 5)
Fish (All) 70 70

Table Notes

Table note 5

88 percent dry matter basis (or 12% moisture content)

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Iron (Fe)
Class Proposed
(%, at 88% dry matter [DM] Table Note 6)
Revised
(%, at 88% dry matter [DM] Table Note 6)
Fish (All) 750 750

Table Notes

Table note 6

88 percent dry matter basis (or 12% moisture content)

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Manganese (Mn)
Class Proposed
(%, at 88% dry matter [DM] Table Note 7)
Revised
(%, at 88% dry matter [DM] Table Note 7)
Fish (All) 150 150

Table Notes

Table note 7

88 percent dry matter basis (or 12% moisture content)

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Selenium (Se)
Class Proposed
(%, at 88% dry matter [DM] Table Note 8)
Revised
(%, at 88% dry matter [DM] Table Note 8)
Fish (All) 2.0 (total) 2.0 (total)

Table Notes

Table note 8

88 percent dry matter basis (or 12% moisture content)

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Zinc (Zn)
Class Proposed
(%, at 88% dry matter [DM] Table Note 9)
Revised
(%, at 88% dry matter [DM] Table Note 9)
Fish (All) 250 250

Table Notes

Table note 9

88 percent dry matter basis (or 12% moisture content)

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Vitamins

Vitamin A
Class Proposed
(IU/kg of diet at 88% dry matter [DM] Table Note 10)
Revised
(IU/kg of diet at 88% dry matter [DM] Table Note 10)
Salmonids 100,000 100,000
Cichlids 10,000 25,000
Anoplopomatids 25,000 25,000
Pleuronectids 25,000 25,000
Percids 25,000 25,000
Other 25,000 25,000

Table Notes

Table note 10

88 percent dry matter basis (or 12% moisture content)

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Vitamin D
Class Proposed
(IU/kg of diet at 88% dry matter [DM] Table Note 11)
Revised
(IU/kg of diet at 88% dry matter [DM] Table Note 11)
Salmonids 10,000 10,000
Cichlids 10,000 10,000
Anoplopomatids 10,000 10,000
Pleuronectids 10,000 10,000
Percids 10,000 10,000
Other 10,000 10,000

Table Notes

Table note 11

88 percent dry matter basis (or 12% moisture content)

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