RG-1 Regulatory Guidance:
Chapter 3 – Guidance on data requirements for feed approval and registration
3.19 Recycled food products

Recycled food products (RFPs) are materials that remain after, or are produced during, the processing, manufacture, preparation or sale of human food. RFPs may, under certain conditions, be suitable for use as livestock feeds. This section sets out the regulatory requirements for RFPs intended as livestock feeds in Canada. The information contained herein is pertinent to food processing plants, feed mills, RFP manufacturers, distributors, and all other persons involved with the manufacture, importation, sale or distribution of RFPs in Canada.

Although these products are generated as by-products of human food production, it is important to stress that the livestock feed chain is not a means to dispose of degraded or contaminated foodstuffs, and that the product must have a nutritional value to be considered a feed.

RFPs that are currently approved as single ingredients for use in livestock feed are listed in Schedule IV of the Feeds Regulations. Examples include Bakery waste dehydrated (4.6.1), Cereals breakfast process residue (4.6.7), and Wheat distillers grains dehydrated (5.5.21). For a complete and up-to-date listing, please contact the Animal Feed Division of the Canadian Food Inspection Agency (CFIA).

If an RFP meets an existing definition as listed in Schedule IV, Part 1, namely, a substance that has been assessed or evaluated as acceptable for use in feed, and meets the standards, packaging and labelling requirements set out in the Feeds Regulations, it may be manufactured, sold, imported or distributed as a single ingredient feed without registration. If an RFP meets an ingredient definition as set forth under Schedule IV, Part 2, or if it contains 2 or more single ingredient feeds listed in Schedule IV or V, it must be registered with the Animal Feed Division. If an RFP does not meet any approved feed definitions or requires registration, it is not to be manufactured, sold, imported or distributed as a feed without prior approval of the Animal Feed Division. Please refer to Section 1.1, "Application for Feed Registration and Ingredient Approval".

Sale and distribution of RFPs

• If an RFP is manufactured, sold, imported or distributed as a feed by any person, including livestock producers, feed mill operators or food manufacturers, it is subject to the regulatory requirements of the Feeds Act and Regulations, including approval and/or registration by the Animal Feed Division.
• If an RFP is given away to one person it may be exempt from the requirements of the Feeds Act and Regulations, but only if the RFP is for the recipient's own use and it does not contain any drugs or other substances that could adversely affect human health or the environment. Note that the RFP may also be subject to acts and regulations of other jurisdictions (e.g. Health of Animal Regulations). See "Restrictions on Recycled Food Products" below.

Handling and storage of RFPs

RFPs should be handled, transported and stored in a sanitary manner in order to prevent contamination and the growth of pathogenic organisms, or the production of harmful toxins (e.g., mycotoxins). The risk of contamination by microbial or chemical impurities must be minimized for all livestock feeds.

Feed manufacturers and livestock producers are responsible for ensuring that suppliers apply quality control procedures, and that appropriate hygienic practices are followed in the collection, handling, transportation, and storage of the RFPs.

Restrictions on Recycled Food Products

1. Meats and meat products; facilities that handle meat

   Due to the risk of zoonotic and exotic diseases, meat products, meat by-products and products suspected to contain meat are not permitted in RFPs intended for livestock feed unless they:

   1. are in compliance with the Mammalian to Ruminant Feed Ban;
   2. have been processed in a manner which would prevent the introduction of disease (subject to approval by the Animal Health Directorate of the CFIA); and
   3. have been registered as a feed, or are listed in Schedule IV or V of the Feeds Regulations.

   If an RFP contains meat or is sourced from a facility where there is meat present (including sandwich meats, filler, beef patties, plate waste, restaurant preparation waste, etc.), including facilities where products are sorted and separated from products containing meat, it is prohibited from being sold, manufactured, imported or distributed as feed, without prior approval of the Animal Feed Division.

   Note: RFPs that are exempt from the Feeds Act and Regulations are still subject to the Health of Animals Regulations. These RFPs must meet conditions a) and b) above, and RFPs that are to be fed to swine or poultry must also comply with condition c).

2. Spent cooking oils

   Spent cooking oils are fats or oils of animal or vegetable origin that have been used in the manufacture and preparation of human foods. These oils may be considered approved feed ingredients as listed in Schedule IV of the Feeds Regulations, if they meet the prescribed definition, as well as the labelling standards.

3. Imported RFP Ingredients

   RFPs imported into Canada must be approved, and must meet packaging and labelling standards as prescribed in Schedule IV or V of the Feeds Regulations prior to their importation and sale in Canada.

4. Degraded material

   Degraded materials are prohibited from use in livestock feed. Degraded materials consist of:

   • decomposing products - product that is visibly mouldy, rotting or decayed;
   • products that have been stored and have been visibly affected by pests, such as insects or rodents, or animal feces;
   • products that have been kept uncovered outdoors; and
   • products that have been damaged by heat, such as in a fire.
5. Contaminated recycled food sources

   Contaminated materials are prohibited from use in livestock feed. Examples of contaminated materials include:

   • foods that are contaminated on the production line (e.g., by a spill of hydraulic oil);
   • production floor wastes that have been in contact with contaminants, cleaners, or wastes that are not part of the food production line;
   • foods contaminated with foreign material (e.g., paper, wood, glass, plastic, metal or soot); and
   • foods rejected due to microbial contamination.
6. RFPs with high moisture considerations

   Due to the potential for concentrated bacterial growth, high moisture RFPs are not acceptable unless the RFP is further heat treated, has been registered as a feed, or is listed in Schedule IV. A safety evaluation will be required prior to approval of RFPs containing high moisture ingredients, or uncooked materials such as raw dough (for breads, cookies, pastries, etc.), or fillings (e.g., apple pie filling, jams, jellies).

Feed Registration and Ingredient Approval Requirements

The following identifies the registration and approval requirements for RFPs ingredients per the Feeds Act and Regulations. Please note that additional information beyond what is listed in this section may be requested, on a case-by-case basis, after review of the submitted information. In order to facilitate the evaluation process, it is recommended that applicants contact the Animal Feed Division prior to submitting an application for ingredient approval or registration.

A) Registration and Ingredient Approval Information

Information on registration and ingredient approval requirements can be found in Chapter 1.

Please see the "Registration Checklist for Recycled Food Products (RFPs) to be Used as Livestock Feed Sources" below, which summarizes the basic requirements for all RFPs submissions.

B) Composition and Manufacturing Conditions

A detailed description of the manufacturing process for the submitted RFPs must be provided, including the source and description of all individual ingredients that enter into the manufacture of the RFPs. This information includes, but is not limited to:

• A complete list of all food ingredients or products that make up each RFP (e.g., vegetables, crackers, cheese, milk, flavours, chocolate, fruits, nuts, candy, preservatives or specific products).
• The source of each ingredient used to manufacture the RFPs, including the names and contact information of each supplier.
• The product formulation as sold, stating the food ingredients/products percentage composition (note that a range may be used).
• A list of products added to facilitate the manufacture of each RFP, such as antifoaming agents or flocculants, and a list of cleaners, disinfectants, etc., associated with the manufacture and storage of the RFPs. Please note that the database of products approved for use in food production facilities is available on the CFIA web site.
• A detailed explanation of the manufacturing process used to generate the final product, including all processing steps (i.e. blending, crushing, mixing, filtering, dehydration, heating, sorting or separation) at each facility, and the method for removing extraneous materials (e.g., glass, plastic, metal, wood).
• A precise description of the storage of the products before processing, storage and transportation of the finished product, and storage on farm, including the times, temperatures and amounts for each.

If, following approval/registration, there are changes in the composition of the RFPs (e.g., a new ingredient or source), the manufacturing process, or other conditions, the Animal Feed Division must be notified.

C) Quality Control Procedures

Since RFPs are exposed to multiple handling, storage, and transportation conditions, temperature variations, etc., a detailed description of the quality control procedures is required. This includes, but is not limited to:

• Written records (from each supplier) maintained at the manufacturing facility, detailing the origin of the food product ingredients;
• The reasons for rejection. Please note that if a food product has been returned to the supplier or rejected due to contamination it may not be considered acceptable as livestock feed, prior to receiving approval from the Animal Feed Division;
• Written procedures used to screen incoming ingredients for contaminants; and
• Records demonstrating that written procedures were followed.

D) Safety Data

Data demonstrating the safety of the RFPs must be provided, including the following information:

Identification of potential chemical contaminants and sources of contamination

• A detailed description of any contaminants inherent to the RFPs (i.e. chemical agents), or introduced through handling, storage or transportation (e.g., metals, pesticides, dioxins, fungal toxins), or other ingredients that may be of concern to humans, livestock or the environment.
• Signed Certificates of Analysis for relevant contaminants for 3 different production lots of the RFP ingredient.
• A detailed description of the sampling protocols used for obtaining representative samples for analysis.
• A detailed description of the methods of analysis used to assess contaminants, including detection limits and recovery rates.

It may be necessary to submit additional safety data for any contaminants present in the RFPs. Based on the data submitted, a scientific rationale may be required to demonstrate that the levels present in complete feed do not result in adverse effects on the intended species of livestock or to human health. The toxicity data may be obtained from complete scientific articles in refereed journals, information from toxicity databases, or unpublished toxicity studies with all the data provided. Abstracts and testimonials are not acceptable.

Microbial Contamination, Shelf-life, and Stability

• Certificates of Analysis are required to demonstrate the safety and stability of the product for a minimum of 3 representative production lots of the final product prior to sale. RFPs are divided into categories on the basis of their physical characteristics, for example; liquid, dry, or vegetable-based. The minimum recommended microbial parameters and physical criteria required to be analyzed for these categories of RFPs are listed in Table 1 (below). Additional microbial analyses may also be required, depending on the type of RFPs being manufactured and the storage and handling conditions.
• When the product may be stored for a period of time before it is fed to livestock, Certificates of Analysis are required for microbial parameters and physical criteria from each of the production lots at the beginning and end of the proposed shelf-life (i.e. sample from the production lot and store the sample; and then resample same production lot sample at the end of the time period). The product samples should be stored under representative conditions, reflecting the storage conditions used in the field. Please refer to Section 6.1, "Sampling Protocol for Feed Products", for sampling information.
• A typical shelf life encompassing on-farm use for the RFPs should be provided and stated on the proposed label. An expiration date may be required depending on the stability of the product.

These analyses must be provided with the application for approval or registration. In some cases, analyses may be omitted when justified by a scientific rationale, supported by peer-reviewed literature.

It is recommended that applicants contact the Animal Feed Division well in advance of submitting an application for approval or registration to determine the types of analyses that may be required.

E) Efficacy Data

RFPs must have a nutritional purpose to be acceptable as livestock feeds. Product labels and supporting information must indicate the target species, the typical and maximum feeding or usage rate, and nutritional guarantees. Supporting Certificates of Analysis (signed originals) for 3 production lots of the finished RFPs are required to characterize the nutrition of the product and to support the proposed label guarantees. The certificates must include analysis of percent moisture content. The certificates must include analysis of added or inherent sources of nutrients (e.g. protein, fat, fibre, sugars, vitamins, minerals) to determine if these nutrients are present at significant levels. Note that scientific studies may be required to support the usefulness of the ingredient.

Certificates may be required for nutritional analysis at the end of the proposed shelf life period, depending upon the type of product being manufactured. In these cases the laboratory should analyze the same lots over the time period specified (i.e. sample from the production lot and store the sample; and then resample same production lot sample at the end of the time period). The product samples should be stored under conditions representative of the storage conditions used in the field.

F) Facility Inspections

Before approval or registration, an inspection of the facilities that manufacture, collect, or process RFPs destined for livestock feed may be conducted. These facilities, like other feed producing facilities, will be subject to periodic monitoring inspections and random sampling by CFIA inspection staff to verify that the feeds comply with regulatory requirements.

Registration Checklist for Recycled Food Products (RFPs) to be used as Livestock Feed Sources

Administrative Registration Requirements

• Completed application package per Chapter 1

Proposed Label

• Brand name (optional)
• Product name reflecting purpose of the product and the intended species
• Guaranteed analysis
• Directions for use to permit safe and effective use of feed (including feeding rate)
• Caution and/or warning statements (if applicable)
• Name and address of registrant
• Net amount (metric measure)
• Date of Manufacture
• Expiration date
• Registration number (to be added)

Product Composition

• List of all food ingredients/products that may be mixed into each product
• Source of each ingredient, including the name and contact information of each supplier
• The product formulation (note that a range may be used)
• List of products added during the manufacture, processing and storage of the RFPs

Manufacturing Conditions

• Detailed explanation of the manufacturing process used to generate the final product
• Description of the storage of the products

Quality Control Procedures

• Records (from each supplier) detailing the origin of the food product ingredients and the reasons for rejection
• Written procedures used to screen ingredients for contaminants
• Records demonstrating that written procedures were followed

Safety Review

• Identification of potential chemical contaminants and sources of contamination
• Signed Certificates of Analysis for relevant contaminants for 3 different lots of the RFPs ingredient
• Proposed shelf life
• Certificates of Analysis for a minimum 3 different lots of finished product for the specified indicators
• Matching Certificates of Analysis of the same 3 lots from the end of the proposed shelf life. Note: this requirement is dependent upon on the proposed shelf life and the type of product being manufactured

Efficacy Data

• Supporting Certificates of Analysis (signed originals) for 3 production lots for the nutrient content of the finished RFPs, including added nutrients and moisture.
  
• Certificates may be required for the same lots at the end of the proposed shelf life period depending upon the type or product being manufactured.

Facility Inspections

• The RFPs supplier/manufacturer may be subject to a pre-approval plant inspection to verify the information submitted.
• The RFPs supplier/manufacturer may be subject to monitoring inspections to confirm continued compliance.

Note: Further information may be required after a review of the preliminary submission.

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