THE QUICK BROWN FOXJumps over the lazy dog

FEDIAF | Avenue Louise 89 | B-1050 BRUXELLES | Tel: +32 2 536 05 20 | www.fediaf.org

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1. The quick brown fox jumps over the lazy dog……………………………………………………………………………………

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PFAC Fall ConferenceNov. 3rd 2017Niagara-on-theLake

“Self-Regulatory Models – Journey to Self-Regulation”Thomas Meyer

Secretary General of FEDIAF

1. FEDIAF: introduction2. How it started 3. How the EU embraced the concept 4. Where we are 5. Q&A

Summary

Non-profit association since 1970 16 National associations representing 21 countries:

Covering 95% of the EU pet food market 200 pet food plants 50.000 direct employment, up to 500.000 indirects € 15 billion annual turnover

From 1.1.2018 Company membership along side association membership

3 staff at Secretariat in Brussels GAPFA founding member

FEDIAF

To be the credible and responsible voice of theEuropean pet food industry collaborating withauthorities, regulators and academics for achievingfavourable conditions for the supply of safe,nutritious and palatable products.

FEDIAF is fully committed to promotingresponsible pet ownership, to the wellbeing of petanimals, to their important social role and to therespect of sustainable development.

FEDIAF’s mission

General Assembly

Executive Committee

Review Committee with Expert Groups

• Additives & Undesirable Substances

• Feed Safety and Hygiene• Environment-Sustainability• Product Communication • Nutritional & Analytical Science • Feed Materials & Trade • PARNUTS

National Secretaries of National Associations

Communications Committee

Secretariat, Brussels

FEDIAF’s structure

GENERAL ASSEMBLY Min 70% Vote from Trade Associations: 60% of their total votes & 55% of their number

Max 30% Votes from Direct Company Members

Executive Committee Each member has one seat and voting rights.

Min 70% Votes Trade Associations. Max 30% Votes Company members.Guests: Co-Chairs Review, Trade Association representative

and Chair Communications WG

Review CommitteeEach member has one seat and voting rights.

Min 70% Votes Trade Association. Max 30% Votes Company members

Communications Working Group

No Voting

National Secretaries

Action Group (NSAG)No Voting

Technical Working Groups,

Task ForcesNo Voting

CEO ForumNo Voting, Advising

President, 2 Vice Presidents, Treasurer(elected from the Executive Committee Delegates)

FEDIAF SECRETARIAT

Trade Association Members: Austria, Belgium, Czech Republic, France, Germany, Hungary, Ireland, Italy, Netherlands, Nordics, Poland, Romania, Spain, Switzerland, United Kingdom representing all 200 Petfood

companiesCompany Members: Hill’s Pet Nutrition, Mars Petcare, Nestle Purina PetCare; WellPet

EU Pet Food highly regulated

Regulation on the placing on the market and use of feed (767/2009)

Feed Hygiene Regulation (183/2005)

Animal By-Products Regulations (1069/2009 & 142/2011)

General Food Law Regulation (178/2002)

Feed Additives Regulation (1831/2003)

Undesirable Substances Directive (2002/32)

TSE Regulation (999/2001)

EU Catalogue of Feed Materials (68/2013)

Two Regulations on genetically modified organisms (1829/2003 & 1830/2003)

Mycotoxins recommendations (2006/576)

Regulation on official controls (882/2004)

Directive on water quality (98/83)

Directive on materials coming into contact with food (10/2011)

Directive on packaging and packaging waste (94/62)

Regulation on the shipment of waste (1013/2006)

Waste framework directive (2008/98/EC)

Particular nutritional purposes directive (94/39)

Plus Codex Alimentarius, ISO, national rules, OIE …

Regulations/Directives that affect pet food but not specific pet food regulations

How it started: Nutrition

EU directive 79/373 on the marketing of compoundfeedingstuffs of 2 April 1979:

The following definitions shall apply:…(d) Complete feedingstuffs: mixtures of feedingstuffs which,by reason of their composition, are sufficient for a daily ration

How it started: Nutrition

Legislation does not define the nutrients required for a« complete » claim in diet for pets

Company knowledge, NRC, AAFCO

Level playing field, quality concernsand reputation of industry

Bring the experts together, also to helpsmaller companies to provide quality petfood

How it started: Nutrition

Experts from companies NRC 1985 & 1986AAFCOLiterature For practical diets Internal document

How it started: Nutrition

Since 2010: External experts from Universities and vet schools

“Scientific Advisory Board” More credibilityNew designGoing public with Guidelines

Self-regulation or co-regulation?

Self-regulation: The possibility for economic operators, the social partners, non-government organisations or associations to adopt amongst themselves and for themselves common guidelines at European level (particularly codes of practice or sectorial agreements). FEDIAF Nutritional Guidelines clear example for “self-regulation”

EU Feed Hygiene Regulation 183/2005

BSE, dioxin … scandals in EU: White paper on food safety Over 80 new legislative initiatives announced Some potentially very detailed EU associations raised the concept of Industry Codes

and Guides for sector-specific rules with EUCommission

Concept first in EU Feed Hygiene rules

Self-regulation or co-regulation? Co-regulation: The mechanism whereby a European legislative act entrusts the attainment of the objectives defined by the legislative authority to parties, which are recognised in the field (such as economic operators, social partners, non-government organisations or associations). Thus a legal basis to develop co-regulation by sectors

Feed Hygiene Regulation 183/2005:

The European Commission shall encourage the development of European guides to good practice in the feed sector

The dissemination and use of guides shall be encouraged by the competent authorities

FEDIAF Safety Guide

FEDIAF Guide of Good Practice for the Manufacture of safe Pet Foods86 pages with details and examples: Pet food safety management system Pre-requisite programmes HACCP system ANNEX I. - European legislation ANNEX II. – practical examples of CCPs and OPRPS ANNEX III. – assessment of suppliers

FEDIAF Safety Guide

Endorsed by the EU, references published in EU Official Journal, referenced on EU relevant website and applied by national control authorities

Same rules for all operators – level playing field

FEDIAF Labelling Code

65 pages of 4 years hard negotiations (that makes roughly 3 weeks per page)

Same procedure as for Safety Guide: Legal basis (co-regulation) Developed by industry Endorsed by the EU References published in the EU Official Journal Link on EU website

FEDIAF Labelling Code Where to be careful: when operating in the EU: Firstly: Claims, secondly: Claims, thirdly: Claims ! Have substantiation for claims ready! Which additives to label and how (check which have maximum legal limits)! “E-numbers” for additives are being phased out! Rules apply also to the internet, flyers, folders…! Careful use of the term “meat” (only skeletal muscle meat)! Read Code in conjunction with the law!

‘Another important advantage concerns the fact that the code assures a harmonised approach: instead of having 27 different national interpretations of the labelling rules, the code gives clear guidance on how the provisions should be applied throughout the EU’ (from the European Commission Midday Express on the FEDIAF Labelling Code of 8 December 2011)

FEDIAF Labelling Code

FEDIAF Labelling Code

Some internal industry criticism and some from control authorities: Not all operators follow the FEDIAF Labelling Code Unilateral interpretations by operators sometimes not in line with FEDIAF Code Competitive advantages, mainly when using “fancy”, unsubstantiated claims Some European countries consider stricter national rules (e.g. closed list of

permitted functional claims) End of harmonisation in the EU Impact on commercial freedom Impact on innovation

Applying the set of rules laid down in the FEDIAF Code is essential: For level playing field For industry reputation To avoid backfiring, i.e. having more restrictive EU or national rules

Benefits

FEDIAF is recognized as a professional trade association by authorities

Authorities trust FEDIAF to self- and co-regulate

Continuous improvement of these documents

Rules adapted to industry realities

Helps the dialogue with authorities and other interested parties

Excellent tools for reputation building

Questions & Answers