Pet food within the GMP+ FC scheme

08 września 2016

The GMP+ Feed Certification scheme (GMP+ FC scheme) focuses on the safety of feed intended for food-producing animals as part of food safety. An exception thereto is the standard GMP+ B8 Production of and trade in pet foods. This standard was developed back in 2003, on request of the pet food sector, with the aim to secure the safety and reliability of products intended as food for pets. The link to food safety (foodstuffs) does not exist here.

Recently, the definition of pets has been adjusted within the GMP+ FC scheme. A good reason to pay attention to the requirements that apply to quality assurance of pet food within the GMP+ FC scheme.

What is the definition of pets?

The definition of pets within the GMP+ FC Scheme is broader than the legal definition. Whereas Reg. (EC) No. 767/2009 dictates that only non-food producing animals can be considered pets (dogs, cats, tame rats, guinea pigs, canaries etc), the GMP+ FC scheme also considers food-producing animals kept as a hobby to be pets (in other words, goats, poultry, cattle, sheep, pigs, horses, rabbits etc kept as a hobby). This means that feed intended for animals kept as a hobby is considered to be pet food. This classification has been used since the introduction of the GMP+ B8 standard.

Why is a somewhat broader definition of pets used in the GMP+ scheme?

Indeed, it does seem strange and possibly confusing to deviate somewhat from the legal classification, but this has to do with the extra-statutory requirements the GMP+ FC scheme defines for the production of feed.  For instance: the purchasing requirements. These are purely focused on guaranteeing feed safety (and the food safety by extension). It would go too far to also declare these extra-statutory requirements applicable for feed for animals of which products do not end up in the food chain. GMP+ considers the feed for food-producing animals kept as a hobby to fall in this category. By classifying this feed as pet food, the strict feed safety requirements do not apply.

What does this mean for the daily practice of GMP+ participants?

Legislation

The fact that the GMP+ FC scheme considers food-producing animals kept as a hobby to be pets, obviously doesn’t mean that the legal requirements for food-producing animals no longer apply. These shall remain in full effect! A producer of feed for pet chickens, must meet the Law and regulations for food-producing animals, since a pet chicken, even though considered to be a pet by GMP+ International, is still a food-producing animal, legally speaking.

GMP+ scope

Certification for production of / trade in pet food is not required. GMP+ B1 certified companies that also produce pet food but do not want to be certified for that, can exclude all activities relating to pet food from the scope of the Feed Safety Management System. In this, a strict separation between these two flows is required to guarantee that the GMP+ feed is guaranteed feed safe. Both flows can be produced at the same location, even on the same production line, but must be kept fully separated, physically and / or organizationally, in all stages of processing, production, (internal) transport and storage.

Would you like to distinguish yourself and be awarded the GMP+ B8 certificate? If so, you have several options, depending on the other feed activities of the company and the wishes of the company. The options are listed in the table below.

Certification for

Intended for

Points of attention

GMP+ B8

Companies that only produce pet food.

More gatekeeper options permitted for the purchase of products and services.

GMP+ B1

Producers of pet food that also produce feed for food-producing animals.

All applicable requirements in GMP+ B1 must be met. This means that the purchasing requirements from GMP+ BA10 apply both to feed for food-producing animals and for pet food.

 

No strict separation required between these two flows.

GMP+ B1 and B8

Producers of pet food that also produce feed for food-producing animals.

The requirements from GMP+ B1 (including the purchasing requirements from GMP+ BA10) only apply to feed for food-producing animals.

 

With regard to pet food, the requirements from GMP+ B8 apply and extensive gatekeeper options are permitted for the purchase of products and services.

 

Strict separation required between these two flows.


Purchase of products and services

Requirements for the purchase of ingredients and services for the production of pet food, allow a broad application of the gatekeeper principle, as described in the GMP+ B8 standard.

A producer can purchase pet food ingredients from a non-GMP+ certified supplier, as long as the producer guarantees that the pet food produced meets the GMP+ requirements. Pet food ingredients purchased under this so-called gatekeeper principle, can only be sold as GMP+ feed if it is intended as pet food.

If the participant uses external storage or an external transporter for the storage and transport of pet food, this external storage or transporter does not have to have GMP+ certification or similar certification. Risk assessments must consider all possible hazards and make sure that control effectively eliminates all serious risks of contamination of feed.

Inclusion of feed materials in Feed Support Products (FSP)

Within the GMP+ FSA module, there is a prerequisite that all feed materials used must be included in the FSP product list. Feed materials intended for processing in feed for non-food producing animals (dogs, cats, tame rats, guinea pigs, canaries etc) do not have to be included in FSP. Of feed materials intended for food-producing animals kept as a hobby (goats, poultry, cattle, sheep, pigs, horses, rabbits etc), a generic risk assessment must always be included in FSP.

Positive declaration

Positive declaration is not required for feed assured under GMP+ B8 Production of and trade in pet food. The GMP+ B8 standard does not refer to GMP+ BA6 Minimum requirements Labeling and Delivery. Should a GMP+ certified company want to issue a positive declaration regardless, it is permitted. It is advised to use the formulations from GMP+ BA6 with the clear mention that it concerns a GMP+ B8 product.

EWS

The GMP+ B8 standard does not refer to GMP+ BA5 Minimum requirements EWS. However, in GMP+ A1, art. 8.7 this obligation is imposed on all GMP+ participants. In other words, EWS notification obligation also applies to pet food This is logical, since ingredients used in pet food, can just as well end up in feed for food-producing animals kept for professional purposes.

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