Comments by Organisation

Action Required (if any) by AFD

British Association of Feed Supplement & Additive Manufacturers

Likely to be affected only by new EC regulations on additives, but no quantification of possible costs.

None.

British Society of Animal Science

"Fully supports the proposed measures for traceability" but "would resist the proposal to categorise fish meal as animal waste"

None. The classification of fishmeal as waste is not part of the Amendment Regulations.

Grain and Feed Trade Association

Concerned about difficulty of cross-referencing amending legislation back to the original instrument. Would prefer to see original legislation directly revised so users are presented with one complete text.

Express sympathy with difficulty of cross-referencing, but addressing this in the manner suggested is difficult at this time because of significant redrafting it would entail. The general issue will be taken up separately.

International Fishmeal & Oil Manufacturers Association

Would like consultation documents to include URLs for websites from where relevant Directives, Decisions and Regulations can be downloaded as required.

Can agree that this would be a useful part of consultation exercises, and will include URLs in future where such links exist.

Local Authorities Co-Ordinating Body on Food and Trading Standards

Advised unable to offer detailed comments due to involvement of feedingstuffs advisers in foot and mout hdisease, but commented with respect to para 5(ii) of the draft RIA, concerning labelling of pet food with registration and approval numbers, that a light enforcement approach would be adopted in first few months of implementation.

None, although LACOTS comment about light enforcement approach has been been included in final version of RIA. Will respond formally acknowledging this commitment, copied to PFMA. (See also action in response to PFMA comments below.)

National Cattle Association (Dairy)

Broad welcome for measures "to strengthen controls in the animal feed chain", although some concern about absence of compliance costs from draft RIA and potential barriers to trade if legislative position not harmonised.

None. Reference to potential barriers appears to be a misreading of the RIA, which suggests these may arise if measures are not implemented in UK legislation.

Pet Food Manufacturers Association

Serious concerns about cost implications of labelling pet food to include registration and approval numbers due to need to write off existing stock of labels and print supplies of new stock, plus the need to print unique labels for each establishment rather than (as now) have one covering a number. Asks that LACOTS be requested to operate light touch enforcement in first few months of implementation, and that LACOTS guidance on enforcement include reference to forthcoming amendment to permit number to be printed outside label (e.g., on can).

Can advise PFMA that LACOTS have independently given a commitment to operate light touch enforcement in first few months of implementation, to grant pet food industry transitional period to make necessary changes. (Could also draw LACOTS attention to forthcoming amendment to labelling of numbers, and request this be included in any guidance to enforcement officers.)

Roche Products

Returned questionnaire only, stating satisfaction with consultation.

None.

Royal Society for Prevention of Cruelty to Animals

"Welcome any tightening of Regulations which may reduce the risk of animal welfare being compormised", and reiterates previous comments about non-feed uses of additives made in response to consultation on Feeding Stuffs Regulations 2000.

None. Non-feed uses of additives not part of Amendment Regulations.

Trading Standards Officer, Hampshire County Council

Suggests that Amendment Regulations should take opportunity to "marry up" the differing requirements of the Feeding Stuffs Regulations 2000 and the Weights & Measures Act 1985 "by allowing certain pet foods to be sold by number".

TSO appears to be referring to Part XIII, para 38(d) of Schedule 6 – titled "Miscellaneous Goods to be Marked when Pre-Packed with Quantity by Number" – to the Weights & Measures Act 1985, concerning "manufactured animal feed in biscuit or cake form pre-packed in a quantity by number of sixteen or less". However, not clear how this conflicts with Feeding Stuffs Regulations, since it relates to pre-packaging of goods when "the container is marked with an indication of quantity by number" – which in the case of (e.g.) a bag of dog chews, it presumably would be. Could ask TSO to provide further information to help us address his concerns.

United Kingdom Agricultural Supply Trade Association

Advise both no comments to make and that, because measures in question are either minor or already implemented in UK, there are unlikely to be any compliance cost implications.

None (although reference to no cost implications has been included in final version of RIA).