The American Feed Industry Association (AFIA) urges the Food and Drug Administration’s Center for Veterinary Medicine (CVM) to keep pace with advances in animal nutrition by modernizing its regulatory policy that currently limits feed ingredients with environmental or production claims from making it to market in a timely way.
The AFIA submitted formal comments to the agency in response to its federal docket (FDA-2022-N-2015), stating that these products should be regulated as feeds, not drugs and that the agency has the authority to make that change.
“The FDA is long overdue in allowing US farmers, ranchers, and pet owners to access novel animal food products with environmental, production, animal well-being and pre-harvest food safety benefits claims, which is central to improving the health of animals, incentivizing innovation and competing in a global marketplace,” said Constance Cullman, AFIA’s president, and CEO. “If we are serious about helping the United States meet its ambitious 2030 methane reduction goal of 30% below 2020 levels, then these products need to be in the CVM’s review process by 2024 so that they can be approved and make a difference on farms by that deadline. The clock is ticking, and the time to fix this issue is now.”
AFIA’s letter outlines several points for the CVM to consider, including those feed ingredients with known environmental benefits, such as those reducing enteric methane emissions in cattle, which are a key component in addressing global climate change thus they should be sold with proper labeling to give US farmers competitive advantages. In addition, the European Food Safety Authority recognizes that feed ingredients constitute an important group of pre-harvest food safety measures. Many administration officials, including secretary of agriculture Tom Vilsack, congressional leaders, and animal industry stakeholders have called for the CVM to modernize its outdated approach so that these products can come to market with accurate label claims.
AFIA members are regularly developing new ingredients that go beyond the typical taste, aroma, and nutritive value historically associated with feed, and they are developing game-changing solutions that act solely on or in the digestive tract of animals. However, current CVM policy requires that these products be regulated as animal drugs instead of feed ingredients, a costly and cumbersome process when these products are feed ingredients and should be regulated as such. AFIA members have products approved in dozens of other countries that they cannot or are unwilling to submit for review at the FDA because of its narrow policy interpretations.
The AFIA is urging the CVM to adopt a modernized, science-based policy that utilizes the food additive petition, the generally recognized as safe (GRAS) process, and the Association of American Feed Control Officials’ ingredient definition pathways to support industry innovation in safe animal food ingredients that will address existing and emerging issues in the production, use and legally compliant labeling of animal feed.
The AFIA believes this can be accomplished using these existing regulatory pathways and that the CVM has the existing statutory authority to properly regulate feed ingredients that provide both environmental and health benefits as well as promote animal growth and feed efficiency.
For more information, read AFIA’s full letter here.