Archived - What we heard report – Consultation on maximum nutrient values in rabbit feeds

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Introduction

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, 1983 (the 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 (range of nutrient guarantees for complete feeds for use in the exemption of feeds from registration) 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 that fall within the ranges listed in Table 4, or a supplement has directions for use that would result in a complete feed that provides nutrients that fall within the Table 4 ranges, the feed can be exempted from registration. Feeds that provide nutrients that 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 that are currently set in Table 4 have health and safety implications that must be considered.

The CFIA undertook a consultation from July 10, 2018 to August 17, 2018 on a proposal to identify maximum nutrient values in rabbit 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.

This report consolidates and summarizes the comments received on the maximum nutrient values in rabbit 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.

About the consultation

The primary mode of consultation involved the preparation and posting of the proposal for the maximum nutrient values in rabbit feeds on the CFIA website, and outreach directly to industry stakeholders, government partners, and CFIA staff. 4 sets of written comments were received.

What we heard

Respondent profile

Table 1: Respondent profile
Category of respondent Distribution
Feed industry – individual 2
Feed industry – association 1
Livestock producer – individual 0
Livestock producer – association 0
Other feed inputs 0
Government (Canadian federal/provincial) 1 (provincial)
Total 4

Comments were received from feed industry associations that represent Canadian commercial feed manufacturers and from individuals within the feed industry. The Canadian feed manufacturers associations represent 90% of commercial feeds manufactured in Canada. A response was also received from the Saskatchewan Ministry of Agriculture.

Key respondent messages

While stakeholders provided suggestions for improvement regarding the proposed maximum nutrient values in rabbit feeds, 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:

  • some of the proposed maximum nutrient values were too low
  • the feed industry currently uses micro-premixes formulated for major terrestrial livestock species to manufacture feeds for minor terrestrial livestock species, so nutrient maximum ranges should be aligned wherever possible

A more detailed discussion on these concerns and the CFIA's responses follow.

Feedback on the proposed maximum nutrient values in rabbit feeds

Scope of the proposal

The scope of the proposal to identify maximum nutrient values in rabbit feeds 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

2 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.

  • CFIA response to the scope of this proposal

    Positive feedback and support were provided on the scope of this proposal. 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.

Rabbit classes and average intakes

No comment was provided with regards to the classes of rabbits (bucks, does, and growing) identified in the proposal and no comment was provided with regards to the average intakes (range of dry matter [DM] intake) for each rabbit class and percentage of forages in the total diet for each rabbit class.

Macrominerals

Calcium (Ca) and phosphorus (P)

No comment was provided regarding the proposed maximum nutrient values for calcium and phosphorus in rabbit feeds.

  • CFIA response to the proposed maximum nutrient values for calcium and phosphorus in rabbit feeds

    Calcium

    No comment was received indicating a concern with the maximum nutrient value of 2% of the total diet DM for calcium for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 2% of the total diet DM for calcium as identified in the proposal.

    Phosphorus

    No comment was received indicating a concern with the maximum nutrient value of 1% of the total diet DM for phosphorus for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 1% of the total diet DM for phosphorus as identified in the proposal.

Magnesium, sodium, potassium, and sulfur

3 respondents provided comments regarding the proposed maximum nutrient value for potassium in rabbit feeds. In all instances, respondents felt the proposed maximum potassium value was too low and should be increased. No comment was provided regarding the proposed maximum nutrient values for magnesium, sodium and sulfur in rabbit feeds.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement – Summary of feedback
Magnesium (Mg) 0 0 0
Sodium (Na) 0 0 0
Potassium (K) 3 0 3 respondents commented that the maximum nutrient value for potassium is too low and not high enough to account for forages (timothy and alfalfa) and some oilseed meals and by-products (soybean meal, canola meal, etc.) that contain naturally high levels of potassium. The respondents proposed a maximum nutrient value of 2% for potassium.
Sulfur (S) 0 0 0
  • CFIA response to the proposed maximum nutrient values for magnesium, sodium, potassium, and sulfur in rabbit feeds

    Magnesium

    No comment was received indicating a concern with the maximum nutrient value of 0.6% of the total diet DM for magnesium for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 0.6% of the total diet DM for magnesium as identified in the proposal.

    Sodium

    No comment was received indicating a concern with the maximum nutrient value of 0.5% of the total diet DM for sodium for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 0.5% of the total diet DM for sodium as identified in the proposal.

    Potassium

    After careful review and consideration of responses received and the suggested maximum value of potassium from all respondents, the CFIA intends to amend the maximum potassium value in rabbit feeds to account for high potassium levels in forages (timothy and alfalfa) and other single-feed ingredients (oilseed meals) commonly used in the manufacturing of rabbit feeds. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 2% total diet DM for potassium.

    Respondents provided data that common ingredients like forages (timothy and alfalfa) and protein sources (oilseed meals) used in the manufacturing of rabbit feeds contain inherent high potassium levels and that having a total diet for rabbits containing potassium levels below 1% would be very difficult, if not impossible, to meet.

    The proposed modification is set out in the table below.

    Current (% of complete feed, as fed) Proposed (% of total diet DM) Revised (% of total diet DM)
    2 1 2

    Sulfur

    No comment was received indicating a concern with the maximum nutrient value of 0.5% of the total diet DM for sulfur for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 0.5% of the total diet DM for sulfur as identified in the proposal.

Trace minerals

Cobalt, copper, iodine, and iron

No comment was received regarding the proposed maximum nutrient values for cobalt, copper, iodine, and iron in rabbit feeds.

  • CFIA response to the proposed maximum nutrient values for cobalt, copper, iodine, and iron in rabbit feeds

    Cobalt

    No comment was received indicating a concern with the maximum nutrient value of 1 mg/kg of the total diet DM for cobalt for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 1 mg/kg of the total diet DM for cobalt as identified in the proposal.

    Copper

    No comment was received indicating a concern with the maximum nutrient value of 125 mg/kg of the total diet DM for copper for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 125 mg/kg of the total diet DM for copper as identified in the proposal.

    Iodine

    No comment was received indicating a concern with the maximum nutrient value of 10 mg/kg of the total diet DM for iodine for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 10 mg/kg of the total diet DM for iodine as identified in the proposal.

    Iron

    No comment was received indicating a concern with the maximum nutrient value of 500 mg/kg of the total diet DM for iron for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 500 mg/kg of the total diet DM for iron as identified in the proposal.

Manganese, selenium, and zinc

No comment was provided regarding the proposed maximum nutrient values for manganese and selenium in rabbit feeds. 2 respondents provided comments regarding the proposed maximum nutrient value for zinc, and felt the nutrient zinc value was too low.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement – Summary of feedback
Manganese (Mn) 0 0 0
Selenium (Se) 0 0 0
Zinc (Zn) 2 0

1 respondent commented that the maximum nutrient value for zinc is too low and proposed a maximum nutrient value of 250 mg/kg for zinc. The respondent felt that the proposed maximum zinc value of 150 mg/kg was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

1 respondent commented that the maximum nutrient value for zinc is too low and proposed a maximum nutrient value of 280 mg/kg for zinc. The respondent felt that the proposed maximum zinc value of 150 mg/kg was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.
  • CFIA response to the proposed maximum nutrient value for manganese, selenium, and zinc in rabbit feeds

    Manganese

    No comment was received indicating a concern with the maximum nutrient value of 150 mg/kg of the total diet DM for manganese for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 150 mg/kg of the total diet DM for manganese as identified in the proposal.

    Selenium

    No comment was received indicating a concern with the maximum nutrient value of 1 mg/kg of total diet DM for selenium for rabbits. As such, the CFIA will proceed with a maximum nutrient value of 1 mg/kg of total diet DM for selenium as identified in the proposal.

    Zinc

    Both respondents expressed concerns that the proposed maximum zinc value of 150 mg/kg of total diet DM was too restrictive considering that feeds for rabbits are commonly formulated using micro-premixes formulated for major livestock species and contain higher concentrations of zinc.1 respondent mentioned that the suggested maximum value of 280 mg/kg of total diet DM for zinc would align with the maximum zinc values for beef and dairy cattle (as per the maximum nutrient consultation summary), while the other respondent indicated that swine and poultry micro-premixes are commonly used to formulate rabbit feeds. The CFIA appreciates the need for flexibility when formulating feeds for minor terrestrial livestock species and recognizes the practicality concerns presented by stakeholders.

    No direct risk to animal health or food safety would be expected with a revised maximum zinc value of 280 mg/kg of the total diet DM for rabbit diets. Rabbit diets containing a maximum of 280 mg/kg of the total diet DM of zinc are about 4 to 10 times greater than the dietary nutrient requirements for rabbits (30 mg/kg to 70 mg/kg), and still below the National Research Council (NRC 2005) maximum tolerable level (MTL) of 500 mg/kg for poultry, cattle, and horses. This overall reduction in the maximum level of zinc in diets for rabbits balances practical formulating concerns and considers antimicrobial resistance concerns. Therefore, CFIA intends to revise the proposed maximum zinc value in rabbit diets to 280 mg/kg of the total diet DM.

    The proposed modification is set out in the table below.

    Current (mg/kg of complete feed, as fed) Proposed (mg/kg of total diet DM) Revised (mg/kg of total diet DM)
    500 150 280

Vitamins

Vitamin A, vitamin D, and vitamin E

Respondents provided comments regarding the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E, and expressed concerns that the proposed maximum vitamin values were too low.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement – Summary of feedback
Vitamin A (Vit A) 2 0

1 respondent commented that the maximum nutrient value for vitamin A is too low and proposed a maximum nutrient value of 35,000 IU/kg for vitamin A. The respondent felt that the proposed maximum vitamin A value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

1 respondent commented that the maximum nutrient value for vitamin A is too low and proposed a maximum nutrient value of 40,000 IU/kg for vitamin A. The respondent felt that the proposed maximum vitamin A value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.
Vitamin D (Vit D) 2 0 2 respondents commented that the maximum nutrient value for vitamin D is too low and proposed a maximum nutrient value of 2,200 IU/kg for vitamin D. They felt that the proposed maximum vitamin D value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.
Vitamin E (Vit E) 2 0

2 respondents commented that the maximum nutrient value for vitamin E is too low and proposed a maximum nutrient value of 2,000 IU/kg for vitamin E. They felt that the proposed maximum vitamin E value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.
  • CFIA response to the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E in rabbit feeds

    Vitamin A

    The limited information available suggests that the nutritional requirement for vitamin A for rabbits ranges from 6,000 IU/kg to 12,000 IU/kg, depending on the class and production phase.

    Respondents proposed maximum vitamin A values of 35,000 IU/kg and 40,000 IU/kg on a total diet basis. They expressed concerns that the proposed maximum vitamin A value of 16,000 IU/kg of total diet DM was too restrictive considering that feeds for rabbits are commonly formulated using micro-premixes containing higher levels of vitamin A, formulated for major terrestrial livestock species.

    After additional review of the scientific literature and in consideration of the complete feed to total diet adjustment, the CFIA intends to revise its proposed total diet maximum for vitamin A in rabbit feed to 35,000 IU/kg of total diet DM, aligning with the recommendations from the respondents.

    Current (IU/kg) Proposed (IU/kg of total diet DM) Revised (IU/kg of total diet DM)
    50,000 16,000 35,000

    Vitamin D

    After additional review of the scientific literature and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum vitamin D value in rabbit diets to 2,200 IU/kg of the total diet DM.

    No risk to animal health or food safety would be anticipated with the maximum vitamin D value being amended to 2,200 IU/kg of the total diet DM for rabbits.

    The proposed modification is set out in the table below.

    Current (IU/kg) Proposed (IU/kg of total diet DM) Revised (IU/kg of total diet DM)
    4,000 2,000 2,200

    Vitamin E

    After careful review of the scientific literature and consideration of the suggested values from all respondents, the CFIA intends to amend the proposed maximum vitamin E value in rabbit diets to 2,000 IU/kg of the total diet DM.

    No risk to animal health or food safety would be anticipated with the maximum vitamin E value being amended to 2,000 IU/kg of the total diet DM for rabbits.

    The proposed modification is set out in the table below.

    Current (IU/kg) Proposed (IU/kg of total diet DM) Revised (IU/kg of total diet DM)
    NRS (No requirement specified) 1,875 2,000

Additional respondent feedback

2 respondents provided comments on using micro-premixes intended for major livestock species for use in the manufacturing of feeds for minor species. They added that the maximum nutrient values for certain minerals and vitamins should try to align between feeds for major terrestrial livestock species and minor terrestrial livestock species to help with the manufacturing of feeds for minor species.

1 respondent provided a comment with regards to considerations to be taken for the seasonal and regional variability in nutrient values of commodities, in particular the range of nutrients in forages and the need to obtain data on the nutrient values in forages across various areas in Canada.

  • CFIA response to micro-premixes and range of nutrients in forages

    The CFIA recognizes that feed establishments, in practice, manufacture feeds for minor livestock species (for example, horses, rabbits, small ruminants) using micro-premixes formulated for major terrestrial livestock species. The CFIA has taken this consideration into account when responding to the maximum nutrient values suggested by industry. The CFIA has made revisions to some proposed nutrient values to align with the maximum nutrient values for major terrestrial livestock species to provide flexibility for minor species formulation if this poses no risk to animal health, food safety, and the environment.

    It is important to note that maximum nutrient values are not target values when formulating livestock feeds. The regional and seasonal variation in forages is recognized. When it comes to evaluating the nutrient content of mixed feeds, the CFIA will use the guaranteed analysis and the labelled directions for use (for example, percentage of the diet). The feed itself should not provide nutrients in excess of the maximum nutrient values based on total diet. Users of the feed are responsible for ensuring that if they are using multiple sources of feeds, including forages, they are not exceeding the maximum nutrient values.

Next steps

The CFIA is preparing a formal regulatory proposal for publication in the Canada Gazette, Part I, that 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 Rabbit Feeds will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I – Proposed maximum nutrient values in rabbit feeds

Rabbit classes and average dry matter (DM) intakes

Class Range of DM intake (% body weight) Forages
Bucks 3 to 3.5 70%
Does 3.5 to 10 40% to 70%
Growing 4 to 6.7 50%

Macrominerals

Calcium (Ca)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 2 2
Phosphorus (P)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 1 1
Magnesium (Mg)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 0.6 0.6
Sodium (Na)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 0.5 0.5
Potassium (K)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 1 2
Sulfur (S)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 0.5 0.5

Trace minerals

Cobalt (Co)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 1 1
Copper (Cu)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 125 125
Iodine (I)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 10 10
Iron (Fe)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 500 500
Manganese (Mn)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 150 150
Selenium (Se)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 1 1
Zinc (Zn)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 150 280

Vitamins

Vitamin A
Class Proposed (IU/kg of the total diet DM) Revised (IU/kg of the total diet DM)
Rabbits (All) 16,000 35,000
Vitamin D
Class Proposed (IU/kg of the total diet DM) Revised (IU/kg of the total diet DM)
Rabbits (All) 2,000 2,200
Vitamin E
Class Proposed (IU/kg of the total diet DM) Revised (IU/kg of the total diet DM)
Rabbits (All) 1,875 2,000
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