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Changes in ABP-R and TSE-R: Economic Consequences and Irrational Fear in EU Meat Industry

This article discusses the economic consequences and irrational fear surrounding the changes in Animal By-Products - Ruminant (ABP-R) and Transmissible Spongiform Encephalopathies - Ruminant (TSE-R) regulations in the European Union. It explores the importance of ruminant protein in the EU protein consumption and the sustainability of animal and plant proteins. The article also questions the inconsistency in the EU's export ban on ruminant protein and its impact on the meat industry. Overall, it highlights the need for an effective and efficient risk-based control system.

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Changes in ABP-R and TSE-R: Economic Consequences and Irrational Fear in EU Meat Industry

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  1. EFPRA – Commission Meeting, 12.11.2015 Changes in the ABP-R and TSE-R Niels Leth Nielsen European Fat Processors and Renderers Association

  2. Overview • Introduction • Importance of ruminant PAP • TSE Road map • Irrational fear • OIE rules • Export / Import rules • Economic view / consequences of the export & feed ban • Conclusions

  3. Protein consumption EU27 (ca. 23 Mio to in total)

  4. EU protein production 6,5 Mio to (30% of the consumption) Raw protein of oil seedsand legumes

  5. Importance of animal proteins (2014) • 2,5 Mio to PAP • Ca. 30% from Non Ruminants / NR (= 775.000 t) • EFPRA represents ca. 78% of the cat 3 plants (volume) (=1 Mio t) • Protein content of NR-PAP ca. 65% (=650.000 t raw protein XP) • Compared to ca. 6,5 Mio to plant protein NR-PAP corresponds to 10% of the EU self production • Ca. 70% of 2,5 Mio to PAP contain ruminant Protein (= 1,75 Mio. t) • EFPRA represents ca. 78% of the cat 3 plants (volume) (= 2,25 Mio t) • Protein content of rum. PAP ca. 53 % (= 1,2 Mio. t raw protein XP) • Ruminant PAP corresponds to ca. 20% of the EU self production

  6. Sustainability: CFP of animal and plant proteins Source: Hans Blonk, EFPRA Congress 2010

  7. Cornerstones of fighting BSE Feed ban SRM Removal Monitoring

  8. Cornerstones of fighting BSE (Situation today) Feed ban Non-rum. PAP to Aquafeed only SRM Removal Reduced list only Monitoring Fallen Stock only No EFSA No OIE For rum PAP EFSA OIE EFSA Under very strong implementation rules Measure affects Consumer (indirect) Cattle (direct) Measure affects Consumer (direct) Cattle (indirect) Measure affects Consumer (direct) Cattle (indirect)

  9. Irrational fear • Ruminant PAP is stigmatised as the infective agent for BSE • Obvious prejudices: • PAP 2015 = MBM 1985 • Pressure sterilised ruminant PAP is infective at all times (meanwhile ruminant casings and medium-rare T-Bone steaks are safe) • Farmers and feed mills haven‘t learnt anything and will feed cattle with ruminant PAP • Cross contamination will immediately infect all sort of farmed animals BUT with ongoing SRM removal, pressure sterilisation, declining BSE cases, disease awareness at farm and feed mill level: ruminant PAP is as safe as any other PAP

  10. Control situation in 2000 Renderer Only ruminant to ruminant was controlled FAILED Export Feed mill Poultry Pork Cattle Fish

  11. Control situation in today Registration of all Chain partners, Speciestest, Transport control, Traceability, Non ruminants Bilateral agreements Slaughterhouse C 1 & 2 Renderer Registration of all Chain partners, Species test, Transport control, Traceability, Non ruminants C 3 Renderer Whereisthe personal tocontrol all this? Export Feed mill Total ban Poultry Pork Cattle Fish

  12. Effective & efficient risk based control Slaughterhouse C 1 & 2 Renderer C 3 Renderer Export Feed mill Poultry Pork Cattle Fish

  13. Comparison OIE / Non-EU-Countries

  14. Comparison OIE / EU (Changes required for green parts) • SRM fat is not the same as cat 1 fat! • Only for Countries with negligible risk

  15. Unbalanced import / export situation Export of living SRM Cattle Import Export Import Meat Export Export of bones isExport of edible Cat 3 Import SBP Export Where is the EFSA Opinion on that? PAP Import Export Import Proc. Petfood Export Import Proc. Fertiliser Export Import Fish meal Export No PCR test required Cat 1 & 2 fat Import Export

  16. Why is there an export ban on ruminant PAP? • Ruminant PAP is still infective! • Why exporting then edible bones and live cattle? What happens with the bones and the SRM in these countries? Is ruminant protein only infective when it is pressure sterilised? • Third countries do not fulfil EU-rules and can not controll R2R ban! • But they fulfil OIE rules to import ruminants and beef meat? They are able to fulfil R2R ban for MBM of all kinds but not for EU-PAP? • This is inconsistency in the protection measure to the disadvantage of farmers, meat industry and renderers! • Who gives the EU the right to judge the effectiveness of third countries control instruments?

  17. Economical view if export markets are closed • Drop in prices for mixed PAP up to 200 €/t • With a yield of 25% PAP from 1 t of raw material price will drop to 50€ / to mixed raw material • All big slaughterhouses / Cutting plants can either separate species (benefit for pork), have the necessary capacity to export slaughter-by-products or can deliver especially ruminant bones to the gelatine industry • Promoting new grey markets i.e. loss of value in the chain

  18. Impact of price drop

  19. Consequence of the export ban With the export ban of ruminant PAP the European Commission clearly disadvantages little butchers as well as small and medium sized slaughterhouses / cutting plants and promotes and speeds up via this backdoor the consilidation of the meat market in favour of big meat companies. This Union of developed EU countries also disadvantages developing countries in their food safety because they have to fulfil their protein needs with imported MBM produced from dead stock, pets, SRM, etc., unsustainably caught fish meal or not EU approved GMO soy. Exporting ruminant PAP is not a waste export! EU ruminant PAP is safer than any other MBM available in the world.

  20. US approach • In line with FAO • Use of PAP as fertiliser (without energy production)is as bad as composting • EU downgrades unnecessarily PAP to 2nd worse option

  21. Pet food: Trade barrier / Indirect subsidies • A surplus of PAP in the EU market allows the pet food industry to buy PAP close to a fertiliser price • Non EU pet food producer do not have this opportunity, they compete with feed prices • Non EU pet food producer do not have the guarantee of safe PAP, only MBM, i.e. produced from diseased animals, dead stocks, pets etc. • The present situation in fact creates a monopoly for the EU pet food sector and due to this trade barrier the EU pet food sector are indirectly subsidized, which is not conform with WTO rules • The big market dominating international pet food producer don’t bother because they can benefit, but the small and medium size producers in third countries are penalised

  22. NON EU pet food markets • Increasing pet food markets worldwide • Full support of the EU

  23. Conclusions • Stop inconsistency with other TSE measures • Accept safety of ruminant PAP • OIE - reclassification to negligible risk status confirms  : • absence of any risk • takes away any argument for having in place any further stricter measures than worldwide applied and agreed • requirement for a worldwide level playing field for ABP – regulation ( processing and use ) for all countries similarly ranked • Promote sustainability of ruminant PAP • Stop food waste • Acknowledge ruminant PAP as extremely sustainable protein

  24. Conclusions • Increase valorisation • becomes more prominent now due to revised SRM definition which will lead to more ruminant / mixed cat 3 PAP’s • valorization opportunities are much lower than in the rest of the world • total loss of value creation throughout chain is 350 mio. € (calculation without loss of farmers not able to use price attractive PAP, buying more expensive plant protein instead with lower protein content and lower P digestibility) • equal use opportunities and lifting export ban would contribute to fundamental strengthening of the agricultural and meat sector

  25. Conclusions • Guarantee level playing field • Stricter EU – rules would : • only prevent level playing field • lead to improper inconsistencies in use throughout the world • and lead to false sense of safety as third country import is not restricted (of fish, meat, fertiliser and PAP) • create “grey zones” only and lead to semi –scandals    

  26. Necessary requirements ASAP • Stop fear of and promote safe EU ruminant PAP • Ruminant PAP must be acknowledged as a safe source to feed farmed animals EFSA opinion • Focus official controls on real risks (Cattle & SRM) • Export of ruminant PAP must be allowed • Method 1 only for ruminant material required (not mammalian) • Export of cat 1 and 2 products for safe uses • Tools to distinguish pig and poultry must be approved

  27. Thank you very much for your attention!

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