Feed Standard Interpretation

Which Feed Standard Criterion does this apply to?

Criterion 3.1 – The UoC implements an ingredient in-coming and out-going accounting system.

What is the intent of this Criterion?

Compliance with the sustainability Indicators in the Standard requires accurate classification and accounting of ingredients coming into the mill. To produce feed under the Mass Balance Production Model, feed mills need to have an ingredient accounting system in place to ensure volumes of incoming eligible ingredients cover the volumes of outgoing ASC Mass Balance feed produced.

Which RUoC sections need considering?

4.4 Shared Ingredient Accounting System (if applicable)  

Additional supporting information for feed mills relating to the Ingredient Accounting System can be found in the Feed RUoC document. This is to provide additional clarity to ensure consistent implementation by mills of the Production Models. In a future version, this information may be transferred into the standard itself. 

Reference to specific parts of the RUoC requirements are detailed in relevant sections below.

How do I interpret the Requirements?

The Ingredient Accounting System 

The Ingredient Accounting System (IAS) is a tool the mill will use to account for incoming and outgoing volumes of Eligible Ingredients in product produced under the Mass Balance Production Model. 

The ASC does not prescribe what format the IAS takes, it could be as sophisticated as to be incorporated into the mills inventory system (e.g., SAP Software system or ERP Inventory Management System) or as basic as an excel spreadsheet (with restricted access). Each option is acceptable provided it meets the requirements set out in RUoC Section 4.3 and (where applicable) Section 4.4. 

(RUoC 4.3.1.3) The IAS is updated on a continual basis. It is expected that the mill will have robust procedures in place to verify the eligibility status of all incoming volumes prior to entering into the IAS (i.e., ensure it is an eligible ingredient) and to ensure the volume (i.e., quantity) is correct. 

(RUoC 4.3.1.3 a & b) ‘Upon Receipt’ means where there is physical delivery of the ingredient within the accounting period. Payment / invoicing or purchase contract for the ingredient not physically on site or Intention to purchase an eligible volume is not sufficient to enter a volume into the IAS as the mill will verify the ingredient as eligible prior to entering the volume into the IAS and as per requirements in RUoC 4.2 Ingredient Approval Process. 

Recording ingredients received

(Standard 3.1.1 & 3.1.2) Records of each incoming delivery and outgoing product should be carefully maintained. This may be completed manually in paper records or electronically via other software programmes. Either way the information recorded should be accurate, maintained and data easily retrievable by relevant personnel. (See RUoC Section 4.2 – 4.4).

(Standard 3.1.3 & 3.1.4) Please refer to RUoC Section 4.5.4 – 4.6.

Auditing considerations

Sampling the IAS: (See also CAR section 15 & RUoC Section 4.3)

(CAR 15.1) The auditor may use their professional discretion when selecting the 5% sample of Eligible Volume entered into the IAS. The auditor will cross reference this volume against supporting documentation to verify the volume entered correlates to the volume of Eligible Volume supplied (e.g., delivery dockets, supplier invoices, contract & Due Diligence assessments). The same process can be completed against Eligible Volume deducted from the IAS which could be done by reviewing despatch documents, invoices or contracts for ASC product sold under the Mass Balance Production Model. 

This review could be completed either before the audit as part of the desk review and/or during the audit itself. Auditors can use a risk-based approach to sampling, for example by reviewing any unusual or large input volumes, review a broad range of time within the accounting period, including different suppliers & customers. Additional reviews can also be added to the 5% sample at the auditor’s discretion, for example where the auditor sees gaps or has additional queries on records provided. 

The auditor may also ask to follow-up questions to determine who is responsible for entering data into the IAS; Is there more than one person trained? What happens if that person is ill, away, or unavailable? Is the IAS protected from accidental or deliberate altering of data? 

Which Feed Standard Criterion does this apply to?

Criterion 3.2 – The UoC determines eligible ingredients and calculates its mass-balance eligible volume.

What is the intent of this Criterion?

The ASC recognises that it is most unlikely that there are currently sufficient volumes of sustainably certified raw materials to produce ASC feed. Until then, and as a first step, feed mills can use one or both of the two accepted ASC Production Models to produce ASC compliant feed.  

ASC feed may come in two forms: 

  • Product produced under the Segregation Production Model which contains only Eligible Ingredients OR
  • Product produced under the Mass Balance Production Model which may contain both eligible and Non-eligible Ingredients. 

Which RUoC sections need considering?

Additional supporting information for feed mills relating to Eligible Ingredients and Production Models can be found in the Feed RUoC document. The reason for this is to provide additional clarity to ensure consistent implementation of the Production Model requirements. In a future version this information may be transferred into the standard itself. 

Reference to specific parts of the RUoC requirements are detailed in relevant sections below.

How do I interpret the Requirements?

The ASC Production Models. (RUoC Section 4.5)

Take note:

It is important to make the distinction that the ASC Production Models summarised below are not to be confused with other Chain of Custody models that are commonly seen within other industry Standards e.g., RSPO and RTRS Chain of Custody. The scope of the ASC Production Models does not extend into the supply chain and only applies to ingredients and feed product while they are within the control of the mill. The mill is however required to have appropriate traceability records in place to demonstrate the Due Diligence outcome of low risk. (See RUoC 4.2.1).

Mass Balance Production Model (RUoC Section 4.5.3)

The Mass Balance Production Model is a system for administratively accounting for the inputs of Eligible Ingredients and outputs of ASC complaint feed. It is not linked to the physical product and there is no physical traceability requirement. 

When using the Mass Balance Production Model, unlike the Segregation Production Model, the physical product is not necessarily made up exclusively of Eligible Ingredients, instead the mill will have an Ingredient Accounting System (IAS).  The purpose of the IAS is to record input volume of incoming Eligible Ingredients and deduction (or output) of ASC compliant feed. 

The Mass Balance Production Model allows the physical mixing of Eligible Ingredients and Non-eligible Ingredients at any stage in the feed production process, provided overall quantities are monitored via the IAS. This results in a claim on a part of the output volume (ASC Product), proportional to the input volume of Eligible Ingredients purchased. 

There is no minimum quantity of Eligible Ingredients required under the Mass Balance Production Model. So, in effect a bag / batch of ASC feed produced under the Mass Balance Production Model could physically contain no Eligible Ingredients in that bag / batch of feed, conversely it could also contain 100% Eligible Ingredients. 

In simple terms, the mill can only make an ASC claim on a volume of finished product, based on the same volume of Eligible Ingredients purchased within the Accounting Period. The Accounting Period for the Mass Balance Production Model is 12 calendar months and runs from January to December. Think of the IAS as a bank account for Eligible Ingredients, it means that the mill can ‘over-draw’ from their bank account within the 12-month accounting period, however, by the end of the accounting period (i.e., December 30th of that year) the bank account (IAS) must be balanced. 

This will require some forward planning by the mill to ensure the account can be balanced by the end of the Accounting Period and also requires communication between departments to ensure there is a sufficient volume of purchased Eligible Ingredients in the IAS to cover production needs. 

To reduce the risk of the accounting system being overdrawn at the end of the accounting period, the mill may wish to review their account balance on a more regular basis, for example every month or every quarter, this way if there is a potential short fall in eligible volume, there is sufficient time to arrange purchase of additional Eligible Ingredients. 

(RUoC 4.5.3.3) The mill may overdraw volume during the 12-month accounting period as long as overall quantities are monitored (via the IAS) and the volume is balanced by the end of the accounting period. 

In any production environment there will be production yields. These yields will have been considered under RUoC Requirement 4.3.1.4. When conducting the end of year balancing calculation, it is unlikely the account inputs and outputs will be 100% balanced. With this in mind, it is suggested that there should be a compliance window of up to a maximum of 5% tolerance. This means the mill accounting system can be overdrawn by a maximum of 5% before a non-conformance may be considered.  

In the example below (figure 6) there are ten ton of feed ingredients purchased by the feed mill, of the ten-ton, six ton are determined by the mill to be from Eligible Ingredients and four ton are from non-eligible ingredients. The Mass Balance Production Model allows for eligible and non-eligible ingredients to be mixed within the production process; however, the feed mill is only permitted to produce and make a claim on six ton of ASC product (based on the purchase volume of eligible ingredients).

Figure 6: The Mass Balance Production Model

Standard 3.2.1 Calculation of Eligible Volume.

The calculation of the balancing summary occurs within the same 12-month Accounting Period i.e., the calculation for incoming eligible volume fully overlaps timewise with the calculation for outgoing volume. ASC acknowledges there is commonly a delay between receiving and production. However, comparing the same time periods as well as working with volumes actually received increases the auditability & consistency between feed mills and simplifies balance calculations. 

The goal is to calculate eligible volume, So for incoming eligible ingredient volumes to match outgoing ingredient volumes. However, where a mill does not have the technology in place to calculate outgoing volume by ingredient, the outgoing volume can also be calculated by product (feed). In both cases, the total overall volume is compared rather than the volume of (for example) incoming pea meal versus the volume of outgoing pea meal. 

Initial audits

During the Initial audit, the auditor verifies by sampling, that volumes entered into the IAS since the start of the calendar year (i.e., January) are eligible.  

For a feed mills initial audit, the accounting period is from the date of initial certification (for example June) until December of that year. 

For all initial audits, the mill will not be required to demonstrate the IAS is balanced. This is because the full duration of the accounting period has not yet been completed. Verification of the Balancing Summary of the IAS will be competed at the next (i.e., surveillance) audit. See also the RUoC section 4.5.2.1 & 4.5.3.1 for more detail. 

However, as part of the prerequisites for an initial audit, the feed mill is required to have conducted at least one Ingredient Accounting System balancing exercise resulting in accurate calculation prior to the initial audit with records maintained for review. (See RUoC 6.2). This exercise should be able to demonstrate that the Ingredient Accounting System is functioning effectively and accurately. 

Eligible volume can only be deducted from the IAS once the mill has received notification from their CAB with a positive certification decision. (e.g., Certificate issue date / Certification Decision date. 

(Standard 3.2.2) Mass Balance Calculation

Please refer to RUoC Section 4.5.2 & 4.5.3 

(Standard 3.2.4) Annual reporting

The mill is required to report annually to ASC the total volume of product sold under the Mass Balance Production Model. The volume reported will be verified through sampling of records during the audit by the ASC auditor. 

The following are some examples to help demonstrate how the IAS will develop over the audit cycle.

Animal Feed Inc. (AFI) a feed mill is interested in seeking ASC Feed certification. Due to space limitations within the feed mill, AFI’s Management Team have decided to operate under the Mass Balance Production Model. They will implement an Ingredients Accounting System (IAS) to record intake of eligible ingredient volume as well as the volume of ASC compliant product sold under the Mass Balance Production Model.

In collaboration with their chosen CAB, the initial audit date is agreed for March 2023. 

Initial Audit March 2023:

Overview of the IAS at the initial audit in March 2023

At Initial audit, the auditor verified, by sampling, that eligible volumes received at the UoC and entered into the IAS since the start of the calendar year (i.e., January 2023) were eligible.  

This can be done by 

  • reviewing Due Diligence reports to verify the eligible ingredients in question meet the ASC Standard requirements to demonstrate low risk. 
  • cross refence with associated invoices and incoming records to verify the ingredient assessed is the same ingredient received. 

The auditor will also review the last IAS balancing exercise conducted by the UoC to demonstrate that that the mill is confident the IAS is operating effectively and accurately. 

Remember at initial audit, the mill will not be required to demonstrate the IAS is balanced (RUoC 4.5.3.1). This is because the full duration of the Accounting Period 2023 has not yet been completed. Verification of the Balancing Summary of the Accounting Period 2023 will be competed at the next (surveillance) audit in 2024. 

Table 31: Example IAS balancing at initial audit

Accounting Period  2023 (January to December)Received Eligible Ingredients 2023 (MT)Sold ASC Product 2023 (MT)Carryover to next Accounting Period
100
210000
300
42000
Feed mill Certified May 2023
5N/AN/A
6N/AN/A
7N/AN/A
8N/AN/A
9N/AN/A
10N/AN/A
11N/AN/A
12N/AN/A
TotalN/AN/AN/A

1st Surveillance audit 2024:

At surveillance audit in March 2024, the auditor will verify, by sampling, that volumes entered into the IAS during the previous year accounting period (i.e., January – December 2023) were eligible.  

Table 32: Example IAS balancing at 1st surveillance audit

Accounting Period  2023 (January to December)Received Eligible Ingredients 2023 (MT)Sold ASC Product 2023 (MT)Carryover to next Accounting Period 
100
210000
300
42000
Feed mill Certified May 2023 
5500500
6300300
70500
81,200300
9600500
10500300
11700500
120700
Total5,0003,600 
Carryover:1,400MT

Question: Is the IAS at the end of the Accounting Period 2023 Compliant?

Answer: Yes, 

Reason: because the mill has received a higher volume of eligible ingredients (5,000MT) than ASC Mass Balance Production Model product sold (3,600MT) within the accounting period 2023. 

In addition, 1,400MT of Eligible Volume can be carried over into the next Accounting Period (RUoC 4.5.3.4).

2nd Surveillance audit 2025:

(Assume all purchased eligible ingredients are in fact eligible ingredients)

Table 33: Example IAS balancing at 2nd surveillance audit

Accounting Period  2024 (January to December)Received Eligible Ingredients 2024 (MT)Sold ASC Product 2024 (MT)Accounting Period  2024 (January to December)
102001400
21200300
301500
41,000300
5500500
6300300
70500
81,2001300
96001500
10500700
11700500
120700
Total6,0008,300
Total inc. Carryover7,400

Question: Is the IAS at the end of the Accounting Period 2024 Compliant?

Answer: No

Reason: Within the Accounting Period of 2024, the feed mill has sold more ASC Mass Balance Production Model product (8,300MT) than Eligible Volume purchased plus Eligible Volume carried over from the previous year which is 7,400 MT in total. (RUoC 4.5.3.2 / 4.5.3.3).

This equates to the IAS being overdrawn by 900MT (or 12%) and in this example the auditor would raise a major non-conformity as per CAR requirement 21.5.2.3 (c) 

Segregation Production Model. (RUoC Section 4.5.4)

Within the Segregation Production Model, all Eligible Ingredients are kept physically segregated from all Non-eligible Ingredients while under the control of the mill. 

This model allows those taking ownership of product (ASC feed) to be assured that Eligible Ingredients contained within have been kept physically segregated through all stages under the control of the mill from Non-eligible Ingredients of the same type.

Figure 7: The Segregation Production Model

When using the Segregation Production Model, the outgoing product, (or feed), is made up exclusively of Eligible Ingredients (excluding feed additives), for this reason a segregation and traceability system within the facility is needed to identify and keep Eligible Ingredients segregated from ingredients which are not classified as Eligible Ingredients but may also be brought on site by the feed mill. 

The mill is required to report annually to ASC the total volume of product sold under the Segregation Production Model. The volume reported will be verified through sampling of records during the audit by the ASC auditor. 

In the example above (figure 7), a feed mill has purchased ten ton of feed ingredients. Following the Due Diligence process, six of those ten ton were determined to be Eligible Ingredients (upper part of the diagram). Four ton of those ingredients were determined to be Non-eligible Ingredients (lower part of the diagram). This means that six ton of ASC compliant product can be produced under the Segregation Production Model.

Under the Segregation Production Model, all Eligible Ingredients are kept physically segregated from all non-eligible ingredients throughout all processes under the control of the feed mill and are traceable throughout production and back to their receiving. 

The feed mill will be required to have sufficient capacity (e.g., separate silos / containers) and processes and procedures in place to always ensure physical segregation of the eligible ingredients and subsequent feed product while under their control.

Production scheduling guidance when producing product under the Segregation Production Model: 

There are a number of different methods that could be employed at the mill to ensure segregation of eligible ingredients from non-eligible ingredients. The size and capacity of the mill will have an impact on which method would work best. 

The mill may conduct a risk assessment (RUoC 4.5.4.2) to develop controls and procedures for handling raw material ingredients, intermediate material and finished product to reduce (and, where possible, remove) the risk of substitution or uncontrolled mixing between Eligible Ingredients and Non-eligible Ingredients. 

Below are some examples of controls that could be implemented:

Physical segregation:

Eligible Ingredients will be physically segregated from non-eligible ingredients. In addition, subsequent ASC product produced under the Segregation Production Model is physically segregated from product produced under the Mass Balance Production Model or non-ASC products. This could involve, for example, dedicated silos, dedicated storage areas, dedicated (e.g., colour-coded) production equipment, and the use of dedicated production lines. 

Time segregation:

Where products must be handled in the same factory areas or on the same production lines, consideration can be given to the use of time segregation. This may be used in mill settings that do not have sufficient space or capacity for a dedicated production line. Production planning can be used to schedule production in order of risk. This can also minimise the frequency of changeovers by scheduling, for example, ASC Segregation Production Model products first, followed by ASC Mass Balance Production Model product and then non-ASC aquaculture products could be scheduled to the end of a day/shift or before cleaning operations.

Purging / Flushing the system:

If there is a closed production system with only minimal dry-cleaning process, flushing or purging the feed processing equipment can prevent contamination between feed batches. The transfer of residues from one batch to the subsequent batch is sometimes referred to as carryover.  Flushing the equipment is one method used to remove any potential carryover from the previously produced product in the system.

The mill could purge or flush the production line between (for example) a batch of non-ASC product, changing over to a batch of ASC Segregation Production Model Product. The line can be flushed with product containing only Eligible Ingredient. This flushed product is then designated as ‘non-eligible’ (because it will contain a mix of eligible and non-eligible product). It can be stored separately and could later be used in a product produced under the ASC Mass Balance Production Model or a non-ASC product. 

The mill could conduct a volume calculation to determine an appropriate volume of product needed to flush the system. The calculation may consider several factors e.g., length and diameter of the pipes, run rate/line speed. If the mill decides to do this calculation, they may wish to add an additional volume as a buffer, such as 5% more than needed to flush the system to ensure no carryover or mixing between eligible and non-eligible ingredients. The mill may retain details of the calculation as evidence to verify the flush volumes based on their production line and equipment.

Take note:

Flushing / purging the processing equipment between flows of eligible ingredients and non- eligible ingredients can be used as a control measure, but physical cleaning between batches / products is not required for the ASC Feed Standard.

Take note:

For detail on action to take in the event of accidental / unintentional mixing of Segregation Production Model Product with non-eligible ingredients, please refer to the non-conforming product procedure detailed in Section 17 of the RUoC.

How to conduct a verification test of the traceability system

(RUoC 4.5.4.3 & 4.5.4.4) As per the RUoC, the mill is required to perform a traceability verification test. This is similar to a vertical traceability audit performed by the ASC auditor, but it places the responsibility of demonstrating an established traceability & segregation system on the mill. 

The mills traceability system will provide traceability ‘forwards’ and ‘backwards’; therefore, the system should be tested in both directions. For example, a specific batch (and known volume) of an eligible ingredient could be selected and traced forward through the production process to despatch to determine in which final products it was used. 

The ability to trace forward would be required for example, when a mill discovers that an employee has used the wrong ingredient when formulating a batch. It could also occur if the mill changes an ingredient supplier and fails conduct Due Diligence to determine the ingredient is an Eligible Ingredient. The mill will be able to identify their immediate customer who received the product and the location of any affected product within its own facility. 

An ASC product produced under the Segregation Production Model can also be selected and traced backwards to demonstrate all the eligible ingredients (and batch codes) that were used to produce it. 

The tests should include identifying which customers received the finished products and which suppliers provided the Eligible Ingredients.

The mill will need to demonstrate that it can account for the whereabouts (location and volume) of a particular ingredient (or ingredients) through a traceability test. The tests could also include a quantity check. Depending on the complexity of the product, it is not expected that the quantity check exercise would always be achievable within 4 hours. The objective is to be able to account for the usage of a full batch of an eligible ingredient. This helps to ensure that the traceability systems are capable of operating effectively should an issue or product withdrawal be required based on that particular ingredient. 

The forward traceability and quantity check is usually undertaken as follows: 

  • Select a batch code of a particular specific Eligible Ingredient.
  • Identify the Ingredient Manufacturer and quantity of the Eligible Ingredient supplied under that batch code. 
  • Identify the feed formulations in which the eligible ingredient under that batch code were used. 
  • Use production schedules and production / batch records to calculate the quantity of the selected batch of ingredient used in each product. 
  • Calculate the quantity of any unused part of the batch in the warehouse. 
  • Finished product lot/batch identification and quantity produced and despatched to each identified customer under the Segregation Production Model
  • Quantity of waste produced
  • Location and quantities of final product still within the mills control 
  • Reconcile the quantity delivered against the amounts used plus any unused stock. 
  • Start and finish time of the exercise.

In some instances, quantity checks may take a great deal of time and resource to complete successfully. It is unlikely that the traceability test will be able to account for all materials to 100% accuracy. However, the mill needs to justify any discrepancies and demonstrate understanding of the nature of the variance. This may be inherent in the product characteristics (e.g., extraction or addition of water), or be attributed to typical wastage on equipment.  In addition to this, the mill may also be able to produce documentation for products (or associated ingredients) that don’t end up in normal distribution channels. This could include ingredients or finished products removed for testing of ingredients, work in progress or finished products, and promotional samples. The purpose of including volumes and accounting for these losses in volume is to demonstrate that the mill can account for all of a specific lot of product or ingredient which is especially important in the event that a lot has been determined to be mislabelled or contain non-eligible ingredients in error.  Quantity verification within the traceability test is a useful measure of the traceability effectiveness and highlights areas for improvement. 

Receiving records such as bills of landing with lot codes or another unique identifiers will establish the identity of ingredients received. Ingredient warehouse storage records with the same unique identifier will establish the location of ingredients within the warehouse. Warehouse ‘pick’ records will document the removal from the warehouse and delivery to the batching and/or production areas. Batch records, if properly created, will document the use (and volume) of ingredients in each lot of finished product. Each of these records establishes a traceable link to the previous production step. The mill could also create a stronger record of the label or code used by saving a physical sample of the label or by taking a picture of the label or code used.

Bulk ingredients such as fishmeal or fish oil also present a traceability challenge for feed manufacturers. In large facilities, these ingredients are often received into storage silos or tanks without a clear designation of (or break between) lots. Using gravity, they are filled from the top and emptied from the bottom. These storage facilities may be emptied and cleaned infrequently, making it impossible to have a clear break between lot/batches of raw material. Mills who use bulk ingredients may have larger amounts of product at risk of being withdrawn and may have more difficulty in tracing a product or ingredient. However, this can be common practice in a large feed mill and the mill may establish a process for identifying verifiable breaks between lots and keep a record of dates silos or tanks are topped up to establish a timeline for new lots / batches. 

During the ASC audit, the auditor may ask the mill to complete a full ‘vertical’ audit. This will include the traceability of a specific batch of product produced under the Segregation Production Model through the mills production processes, and a review of the site records related to the product or ingredients. Records can include, for example, supplier approval, Due Diligence records demonstrating eligibility status of the ingredients, goods-in receipts, process records, and dispatch records. However, the traceability audit is not expected to include records that would only be held at other points in the supply chain (e.g., the ingredient supplier’s processing records). 

(RUoC 4.5.4.5 & 4.5.4.6). The RUoC requires mills to conduct a test of their traceability systems at a least once per year. 

It is expected that the traceability exercises can be conducted in four hours. This is to ensure that potentially non-conforming product can be identified in a timely manner. 

Having a robust, documented system to ensure traceability will assist the mills in meeting the ASC Requirements for producing product under the Segregation Production Model and help to quickly identify affected products in the event of detection of non-conforming product (e.g., the mixing of eligible and non-eligible ingredients during the production process). 

Which Feed Standard Criterion does this apply to?

Criterion 3.3 – The UoC labels products correctly.

What is the intent of this Criterion?

The aim of this Criterion and associated RUoC Requirements is for ASC product to be easily identifiable, in a constant way, whether it is in a sealed feed bag or in bulk format e.g., Silo or tanker.

Which RUoC sections need considering?

RUoC Section 4.6 – Identification 

RUoC Section 21 Use of the ASC Logo, trademarks and claims.

How do I interpret the Requirements?

(3.3.1)

The mill is required to physically identify sealed bagged product produced under the Mass Balance Production Model. Where the product is not identified physically (e.g., bulk tankers or silos), the batch/lot number on product should also link to the accompanying sales documentation such as the invoice, which clearly includes the allowable feed claim on the relevant line item.  

See the ASC Feed Logo claims use guidance for further information.

(3.3.2 & RUoC 4.6)

The mill is required to physically identify product produced under the Segregation Production Model. Where the product cannot be labelled physically (e.g., bulk tankers / silos), the batch/lot number on product should link to the line item in the accompanying sales documentation such as the invoice, which clearly includes the allowable feed claim.  

See the ASC Feed Logo claims use guidance for further information.In addition to this, the mill will provide the distinct feed names of all products produced under the Segregation Production Model to the CAB. The CAB will then include a list with each feed name on a schedule or annex to the certificate.

Which Feed Standard Criterion does this apply to?

Criterion 3.4 – The UoC is transparent on product characteristics.

What is the intent of this Criterion?

The aim of this Criterion is to assist buyers of ASC product in calculating their downstream impacts in the supply chain.

How do I interpret the Requirements?

(3.4.1)

The nitrogen (N) content can also be calculated by dividing the protein content by 6.25.

(3.4.3)

This Indicator relates to situations where the mill specifically adds medication rather than ingredients sourced by the mill potentially containing or being contaminated with medication. 

Medicinal feed additives could be a range of antibiotics or parasiticides amongst others. This follows the definition of the EU on what a medicament is and does not relate to other functional ingredients such as antioxidants, vitamins, vitamin pre-cursors, pro-biotics etc. 

Useful resources

Regulation (EU) 2019/4 of the European Parliament and of the Council of 11 December 2018 on the manufacture, placing on the market and use of medicated feed, amending Regulation (EC) No 183/2005 of the European Parliament and of the Council and repealing Council Directive 90/167/EEC https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R0004

REGULATION (EC) No 1830/2003 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 22 September 2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003R1830&qid=1548346684302&from=EN