Vol.36 | Vol. 36 (2) - 2025 | COLUMN: Regulation

What’s up with feed innovation in the EU?

by

Katia Merten-Lentz
Partner & Founder – Food Law Science & Partners

While in the EU, food has always accounted for a central matter of health and culture, the last decade has accompanied a growing interest in animal nutrition, whether farmed or domestic.

Animal (food-producing or pet) feed is ruled by Regulations (EC) No 178/2002 (1), (EC) No 767/2009 (2) and (EC) No 1831/2003 (3), the latter mainly discriminating between feed materials and feed additives. A feed material corresponds to a product intended to constitute the main nutritional core for animal feed and must comply with related regulatory provisions and be approved following notification prior placement on the market.
More strictly framed, feed additives are substances supplemented in animal feed driving intentional effects on the feed product, the targeted animals, the environment and on the foods derived from the fed animals. They are commonly classified according to their effects: nutritional, sensory, zootechnical, technological, and antiparasitic. Their use and placement on the EU market are conditioned by positive efficacy and safety assessment resulting in authorization.

To date, the feed materials Register references about 2766 products efficiently notified/authorized as feeds in the EU. The average number of validated feed material notifications published since 2010 is 178 feed products/year. It could have been expected that after such a wave of product notifications, concomitant with the newly adopted legislation, the rate would have then slowed down. However, the next trend tended to maintain around a hundred notifications a year.

In parallel, the EU feed additives catalogue follows a constant progression since the application of its related Feed Additives Regulation (EC) No 1831/2003, in terms of quantity and variety (4), as witnessed by the increasing number of the European Food Safety Authority (EFSA) scientific evaluations. Indeed, if EFSA published few opinions during the primary years of the Regulation, 111 evaluations were released in 2024, a number that has gradually risen over the last two decades. Interestingly, it counts for one of the major categories of EFSA’s scientific assessments.

Multiple aspects may unveil this expanding interest for feed perspectives.

Firstly, it certainly proves the mere improvement of animal health and their productions that is pushed using specifically designated feeds. The commitment of many to ensure decent animal welfare along farming practices deserves to be highlighted, together with the growing attention of pet owners for the nutrition of their four-legged friends.

But secondly comes undoubtedly circular economic approach which encourages operators to recycle their resources, to prevent waste.
This legal push explains a recent origin for extending feed materials and additives requests. The scope of initiatives is broad and – among others – the concern for climate alterations raised many novel approaches to attempt to reduce CO2 emissions.

More prosaically, the burst of interest in the feed area could also be explained by the regulatory barriers encountered by Food Business Operators (FBOs) in placing on the market some – too – innovative food products. Strategically, a proportion of such FBOs primarily turn to the feed sector to make their activity profitable prior/along a simultaneous food regulatory pathway. Indeed, the feed market appears more accessible from a regulatory point of view. This was notably highlighted by the markets of insect proteins, fermentation biomasses as well as cultivated proteins/meat (in the UK) that are initially placed on the market for animal feed.

The multiple reasons cited above currently stand as opportunities that supported the development of feed innovation encountered nowadays in the EU.

As a new precept, why not say good for feed and for food?

References and notes

  1. Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety.
  2. Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 1831/2003 and repealing Council Directive 79/373/EEC, Commission Directive 80/511/EEC, Council Directives 82/471/EEC, 83/228/EEC, 93/74/EEC, 93/113/EC and 96/25/EC and Commission Decision 2004/217/EC.
  3. Regulation (EC) No 1831/2003 of the European Parliament and of the Council of 22 September 2003 on additives for use in animal nutrition.
  4. Amino acids, vitamins, minerals, flavourings, colorants, antioxidants, emulsifiers, preservatives, pre/probiotics, anti-methanogenics, enzymes, phytogenics etc.

ABOUT THE AUTHOR

Katia Merten-Lentz, partner resident and founder/manager of the law firm “Food Law Science & Partners”, has been for more than 25 years, a leading practitioner in European food and feed law. Her practice also extends to Biotechnologies, Environmental Law and Cosmetics Law.
She is one of the few lawyers assisting clients from A to Z in the food and feed area obtaining European authorization for new additives, enzymes, novel foods and accompanying them with issues ranging from marketing to innovation.

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