Language selection

Government of Canada / Gouvernement du Canada

Search

What We Heard Report: Proposed changes to the Canadian Feed Ingredients Table

Introduction

The Canadian Food Inspection Agency (CFIA) led a 30-day consultation on the proposed changes to the Canadian Feed Ingredients Table (CFIT) from December 13, 2022 to January 14, 2023. The purpose of the consultation was to seek feedback and comments on the changes proposed to the CFIT since the CFIA sought feedback on the proposed Feeds Regulations, 2024, in the Canada Gazette, Part I (CGI). The CGI consultation included the draft regulatory text as well as all 9 proposed incorporated by reference (IBR) documents, which included the CFIT.

As a result of the CGI consultation, the CFIA received valuable feedback on the CFIT. In addition, the CFIA continued to conduct an internal review of the CFIT to ensure better clarity and consistency. This has resulted in a number of changes made to the CFIT since the CGI consultation. This 30-day consultation was an opportunity for stakeholders to provide feedback on the updated CFIT document before publication in Canada Gazette, Part II (CGII).

Background

The CFIT lists and describes all single ingredient feeds (SIFs) approved for use in livestock feed in Canada. The CFIT will replace Schedule IV and Schedule V of the current regulations.

The CFIT contains 7 classes of SIFs, each with a clearly defined purpose.

The CFIT is divided into 2 parts. SIFs listed in part 1 of the CFIT are exempt from registration and may be imported, sold and manufactured in Canada, if they meet the description as listed in the CFIT, are labelled appropriately and meet the standards and other regulatory requirements outlined in the new regulations. SIFs listed in part 2 must be registered before they can be imported, sold and manufactured in Canada.

Summary of changes

The changes made to the CFIT for this consultation included:

In addition, the updated CFIT document reflected any SIFs that had been approved or modified since the CGI consultation (June 2021) until the Fall of 2022, as a result of the regular SIF approval process.

Who we heard from

The CFIA received 13 sets of comments on the proposed changes to the CFIT. 9 sets of comments were received from external stakeholders and 4 sets of comments were received from internal stakeholders.

What we heard

In general, feedback and comments received on the proposed changes to the CFIT were positive. Some respondents identified some minor corrections that need to be made to the CFIT while others requested clarification on certain proposed changes to the CFIT. See the Appendix for more details on the comments received. In addition, respondents requested clarification on the consultation process for new SIF descriptions or amendments to existing SIF descriptions when transitioning from the Schedules to the CFIT.

Next steps

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

We continue to consider all input as we work to update the Feeds Regulations. Based on the comments and feedback received from this consultation, some amendments were made to the CFIT. The updated version of the CFIT will be published as part of the CGII publication of the proposed Feeds Regulations, 2024. At that time, the CFIT will come into effect for all stakeholders, and additional guidance and information sessions will be held to support stakeholders as the new regulations are implemented.

Appendix

The following provides a summary of the comments received and any changes made to the CFIT resulting from this consultation.

Clarification on the format and placement of SIFs in the CFIT

A respondent asked if an index of the CFIT would be included, similar to the index found in Schedules IV and V. The CFIA does not plan to include an index in the CFIT, however the ingredient numbers in the CFIT will provide information on whether the SIF is in part 1 or part 2 and what class(es) or subclass(es) the SIF is found in. The first number in the ingredient number indicates if the SIF is placed into part 1 or part 2. For example, 1-201-012 or 2-604-002. The second set of numbers after the first dash, indicates which class and subclass the SIF is listed in. Using the examples above, the ingredient number with 1-201-012 would indicate it is found in Subclass 2.1 (Cereal grains) of Class 2 (Energy feeds), and the ingredient number with 2-604-002 would indicate it is found in Subclass 6.4 (Pelleting aids) of Class 6 (non-nutritive ingredients). The numbers after the second dash are assigned consecutively and indicate the number of SIFs found in that particular Subclass.

Some respondents required clarification on the movement of the SIFs from Schedules IV and V into the CFIT. All SIFs that are found in Schedules IV and V were moved to the CFIT, however, at the time of the CGI consultation any SIFs that were only approved for use in mink and fox feeds were removed. No other SIFs were removed from the CFIT that were originally found in the Schedules. Note that some of the SIFs were reclassified when they were moved into the CFIT based on their approved purpose(s).

In addition, no SIFs were moved between the 2 parts of the CFIT when moved from the Schedules and placed into the CFIT. In other words, if a SIF was found in part 1 of the Schedules, it was placed into part 1 of the CFIT. The decision to move a SIF from part 1 to part 2 or part 2 to part 1 was not part of these proposed changes to the CFIT. The decision to place a SIF into either part 1 or part 2 is made by the CFIA following the evaluation of a SIF for approval. Any future changes to where the SIF is placed in the CFIT, part 1 or part 2, will be consulted on.

CFIT glossary

Some respondents provided comments on certain definitions within the CFIT glossary. Based on the comments received during the consultation, the definition for approved grains was revised and the definitions for cereal grains and pulse grains were removed from the glossary. These changes will be reflected in the CFIT at the time of CGII publication.

Some respondents suggested definitions for specific terms to be drafted or certain definitions to be revised, and included in the CFIT. 1 of the definitions which respondents required clarification on was the definition of approved processing aids/additives and what is meant by approved as food additives, which is used in this definition. There is a separate project that will be looking at the new Incidental Feed Additives policy, how processing aids/additives are defined and as a result how these terms are being used in the SIF descriptions of the CFIT. Any changes to the definition, SIF descriptions that use this term or subclasses where SIFs are placed as an outcome of this project, will be consulted on.

Another definition which respondents required clarification on was the definition of carrier. This definition is found in the CFIT glossary, but it is also found in the regulatory text of the proposed Feeds Regulations, 2024, and therefore will not be removed from the CFIT glossary. The definition of carrier will hopefully provide clarification on what is an acceptable carrier. It is unlikely that there will be subclass for carriers in the CFIT, as having an exhaustive list of SIFs in which 1 of their intended purposes is a carrier would be challenging. However, defining the term provides some guidance or criteria on what is an acceptable carrier (or could be used as a carrier).

At this time and at the time CGII publication, no additional definitions or revised definitions will be included in the CFIT glossary.

Changes to the SIF descriptions

There were some respondents who proposed changes to specific SIF descriptions (for example, changing the current manufacturing process or adding different manufacturing processes, moving SIFs from part 2 to part 1, adding a SIF that is not currently approved for use in livestock feeds, or adding another purpose that is not currently approved, etc.). This consultation was intended to focus on changes that:

Significant changes to current SIF descriptions or adding new SIF descriptions to the CFIT were outside of the scope of this consultation. If regulated parties want to make significant changes to an existing SIF description or want a new SIF be to approved, they need to submit an application for approval and any supporting data for evaluation. Refer to Chapter 1 of RG-1 Feed Registration Procedures and Labelling Standards for additional information.

Specific changes to SIF descriptions

Sodium citrate

1 respondent questioned whether this SIF could be placed under Subclass 6.3 (pH adjusters) as an intended purpose in addition to this SIF being approved as a chelating ingredient in livestock feeds in Subclass 6.7 of the CFIT. Based on information provided, which supported an additional purpose and a history of safe use for that purpose, as well as an internal review, sodium citrate will be placed into 2 Subclasses (6.3 and 6.7) in the CFIT for CGII.

Sorbitol

A respondent questioned whether this SIF could be placed (and therefore approved) under other subclasses in the CFIT. Currently, sorbitol is only approved for use as a sweetener (Subclass 6.22) in the updated CFIT. If stakeholders would like sorbitol to be added to another class or subclass in the CFIT, they will need to submit an application package with data/information to support its intended purpose(s).

Formaldehyde

Since formaldehyde was originally approved for other purposes besides as a mould inhibitor, formaldehyde was added to Subclass 6.1 (as a preservative) as well as Class 7 (treatment for rapeseed meal to aid it to bypass the rumen). These changes were made as a result of the CFIA's internal review of the CFIT.

Whey-based SIF descriptions

A respondent had specific questions with regards to the label guarantees for lactose and asked for clarification for why certain whey-based SIF descriptions had a maximum percent guarantee for lactose while other descriptions had a minimum percent guarantee for lactose.

The requirements for minimum percent or maximum percent guarantee for lactose, depends on the manufacturing process and the purpose of the SIFs. These SIFs are either approved for use as a source of energy, source of protein or for both as a source of protein and energy. When the SIF is intended as a source of energy, a minimum percent guarantee for lactose (the primary disaccharide in whey products) is required. When the SIF is intended as a source of protein, a minimum percent guarantee for protein is required and a maximum percent guarantee for lactose is required. If the SIF is intended as a source of energy and protein, then a minimum percent guarantee for lactose is required and a minimum percent guarantee for protein is required.

As a result of the comments received during this consultation, the CFIA will amend these SIF descriptions. The CFIA will be consulting on these amended SIF descriptions, and it is anticipated that these final amended descriptions will be added to the CFIT post CGII publication.

Rendered product descriptions

Some respondents requested 1 of the rendered fat/oil descriptions to be revised, while other respondents questioned what raw materials are allowed in the manufacturing of some animal protein products and by-products. As a separate project, some of the rendered product descriptions have been revised and updated based on discussions with the rendering industry, the feed industry, and U.S. colleagues in recent years. An informal consultation was conducted with all Canadian renderers, and members of the feed industry in the Fall of 2022. These revised descriptions were included in the proposed changes to the CFIT for consultation. The revisions included better alignment between the English and French, including the SIF names, clarification of what raw materials can be used in the manufacturing of these SIFs, and allowing certain rendered products to include animal tissues that are of multiple species origin.

The CFIA continues to have ongoing discussions with the rendering industry on what raw materials can be used in the manufacturing of some rendered products. The new and revised rendered product descriptions will be included in the CFIT at the time of CGII publication to add some flexibility that the rendering industry has been looking for in recent years. Since there is a 12-month transition period post CGII publication in which one can follow Schedules IV and V or the CFIT, this will give additional time for the industry and the CFIA to continue discussions on these descriptions and determine if any changes are needed before the transition period ends.

Based on comments received during this consultation, the animal fat (feeding fat) description has been revised to provide clarification and flexibility on how it can be described of its kind or origin. A standardized statement was also added to the description to allow for a preservative to be added to this SIF. This change aligns with what has been done for some of the other rendered product descriptions.

Viable microorganism descriptions

1 respondent provided a comment on how certain viable microbial strains are described at the genus level in the updated CFIT (for example, Lactobacillus culture dehydrated) while other viable microbial strains are described at the species level (for example, Lactiplantibacillus plantarum culture dehydrated). Currently, the CFIA is working on updating the SIF names of these viable microbial strains from listing and describing them at the genus level to the species level. Within the last year, the CFIA has reached out to stakeholders to discuss the idea of updating the viable microbial strain descriptions to include the species level. In general, there has been positive support from stakeholders on transitioning from the genus level to the species level. In addition, including the species provides additional information on the viable microbial strain that is approved for use in livestock feeds as well as providing support on the intended purpose(s) of these SIFs (for example, a component of gut modifier products or as a component of a silage additive or forage additive). The CFIA will consult on all new viable microorganism descriptions and any changes to existing viable microorganism descriptions. This work is separate project and is an on-going process to create new descriptions and update existing descriptions to align with this approach.

Administrative and editorial changes

A comprehensive internal review was conducted again on the updated CFIT document after the consultation period had closed. As a result, minor editorial changes were made to some SIF descriptions to provide better consistency in some of the standardized wording, and better alignment between the English and French terms and descriptions.

In addition, some subclass names were changed. For example, Subclass 3.2.2 (Cereals and pulses) was changed to Subclass 3.2.2 (Cereals, pulses and legumes) to include the peanut-based descriptions and lupine-based descriptions as they were previously under the Subclass 3.2.1 (Oil seeds). A new Subclass 3.2.5 (Other plants) was created to include the coconut-based descriptions as well as the palm meal description. These descriptions were previously in Subclass 3.2.2. The cotton-based descriptions were also moved from Subclass 3.2.2 to Subclass 3.2.1 to better reflect that the cotton plant is considered an oil seed.  In addition, a new Subclass 5.5 (Essential fatty acids) was created in Class 5.

The CFIA also made changes to certain SIF names to better align with the regulatory text as well as better alignment between the English and French names. For example, the SIF names in Subclass 2.3 (Seed and mill screenings) of Class 2 (Energy feeds) were changed to reflect the names used in the regulatory text as well as other legislation. In addition, SIF names that include the method of extraction (for example, mechanical extracted, solvent extracted) were standardized and better alignment and consistency of the method of extraction terms were considered.

These changes were part of the final internal review of the CFIT once all comments from stakeholders received during this consultation were addressed.

In addition, some corrections were made to certain information within a few SIF descriptions (for example, including the correct Chemical Abstracts Service (CAS) number, removing certain standardized statements that did not apply to that particular SIF, etc.) based on comments received during this consultation and an internal review of the CFIT.

Consultation process/approach for new or amended SIF descriptions

Some respondents provided comments or requested clarification on how new SIF descriptions or changes to existing SIF descriptions would be consulted on as we transition from Schedules IV and V to the CFIT. A notice to industry was posted on May 17, 2023 which summarizes the consultation approach for SIF descriptions. The CFIA will continue to evaluate applications for new SIFs, or modifications to existing SIFs between now and when the proposed Feeds Regulations, 2024 come into effect. Once the evaluation to verify that a SIF is safe and effective for its intended purpose is complete, a consultation on the new or modified SIF description will be conducted before it can be added to the CFIT. The consultation process is a 2-step process in which the CFIA will post a document for public consultation (30 day consultation period) on the proposed changes to the CFIT for new SIF descriptions or changes to existing SIF descriptions. The CFIA will then post a summary of the comments received and CFIA's responses to the comments from the consultation. The consultation summary document will include any changes to the SIF description as well as the final SIF description that will be added to the CFIT post CGII publication. Once the proposed Feeds Regulations, 2024 come into force, the regular process for consulting on SIF descriptions and updating the CFIT will be followed. More information on updating IBR documents will be made available at the time of CGII publication of the proposed Feeds Regulations, 2024.

Until the new regulations and the CFIT come into effect, stakeholders must continue to follow the current Feeds Regulations. If you would like to request a copy of the current Schedules IV and V please send an email with the subject line "Schedule IV and Schedule V" to the Animal Feed and Veterinary Biologics Division.

Please note that there will be a 12-month transition period following CGII publication during which stakeholders can follow Schedules IV and V or the CFIT. Between now and CGII publication, the new SIF descriptions and amendments to existing SIF descriptions that have been consulted on (and therefore finalized and approved) can be found in the consultation summary documents on the external website until they are added to the CFIT shortly after CGII publication.

Date modified: