EFFOP replies to the Food and feed safety – simplification omnibus proposal

EFFOP – Marine Nutrients Europe contributed to the public consultation launched by the European Commission on the omnibus proposal for simplification relating to feed and food safety.

This initiative aims to boost the competitiveness of the food and feed industry and reduce the administrative burden associated with certain regulatory requirements. While the Commission has targeted specific requirements in food and feed safety legislation, we saw this initiative as an opportunity to raise several changes to the TSE and ABP regulations and the food hygiene rules for producing fish oil once again with the Commission.

European producers of marine ingredients transform responsibly managed marine resources into high quality proteins and nutrients, including essential omega-3 fatty acids, and therefore contribute to food security, sustainable nutrition and the EU’s circular economy.

In our feedback, we welcomed the European Commission’s initiative to simplify food and feed safety legislation and suggest the following key measures.

Regarding Bovine Spongiform Encephalopathy (BSE), the current ban on fishmeal in ruminant feed is disproportionate given EFSA’s conclusion that TSE risks are negligible and modern HACCP standards ensure safety, which supports a science-based review. With an updated EFSA opinion, lifting the ban could allow the sustainable use of 10,000-20,000 tons of blue protein per year.

We strongly support the inclusion of the Animal By-Products (ABP) Regulations within the scope of this initiative.

The current transport requirements for ABP materials are inconsistent across Member States, creating operational barriers in addition to the lack of transport availability in many areas. A revision of the requirements in consultation with national authorities and stakeholders, similar to the process that led to the adoption of adaptations for the transport of edible oils and fats in seagoing vessels, would facilitate logistics without compromising safety.

In addition, changing the definitions of fishmeal and fish oil to include low-trophic aquatic invertebrates (tunicates, echinoderms, annelids) would unlock up to 100,000-200,000 tons of sustainable raw material per year.

With regard to food hygiene rules, the current requirements for the production of fish oil for human consumption (e.g. TVBN limits, storage temperatures) are not adapted to the realities of the industry and are not scientifically sound. Revising these provisions in consultation with Member States and stakeholders would ensure harmonized EU rules and facilitate the production of safe, high-quality omega-3s for European consumers.

You can read the detailed feedback and see EFFOP’s reply on the consultation portal.