Third country representation for animal feed businesses
The measures that must be taken by animal feed businesses to legally trade feed between GB, NI, the EU, and non-EU countries from 1 January 2021.
Under retained European Union (EU) law, manufacturers of feed products that are exported to GB must have a representative established in GB.
This includes EU Member States as well as non-EU countries known as ‘third countries’.
Manufacturers in GB of feed products that are exported to EU Member States, or moved from GB to NI are required to have a representative based in an EU Member State or NI.
Exporting or moving animal feed from GB to the EU or NI
Previously, the requirement for a non-EU country feed manufacturer to have a representative in the EU depended on the activity being carried out. However, in February 2018, the European Commission communicated a revised interpretation of Article 24 of Regulation (EC) 183/2005 that all feed products exported to the EU from a non-EU country required representation and not only for certain feed manufacturers carrying out specific activities. It is therefore advised that GB manufacturers of feed products that are exported to the EU or moved to NI assume that third country representation is needed for all feed.
Some EU member states have specific rules on the requirements of having a representative for importing feed into the EU. You could seek clarification with your EU third country representative who could approach the relevant competent authority in the member state to ensure they are compliant with any national rules.
Further details of competent authorities in member states can be found via the European Commission’s website.
Importing or moving animal feed into GB from the EU and non-EU countries
Imports into GB will continue to follow the original interpretation that limits the requirement to have a representative to certain higher risk feeds including:
- manufacturers of certain feed additives
- manufacturers of certain novel protein source products
- manufacturers of premixtures containing certain feed additives
- compound feed manufacturers that incorporate the products mentioned above
Feed additives typically requiring a GB representative include:
- trace elements
- carotenoids and xanthophylls
- micro-organisms and enzymes
- antioxidants with a maximum permitted level
- other additives with a maximum permitted level, not included in the above categories
- coccidiostats and histomonostats
Certain novel protein sources include:
- proteins obtained from micro-organisms belonging to the group of bacteria, yeasts (except yeasts cultivated on substrates of animal or vegetable origin), algae and lower fungi
- co-products of the manufacture of amino acids by fermentation
- amino acids and their salts
- hydroxy analogues of amino acids
Moving animal feed from NI to GB
There will be no new requirements to move animal feed from NI to GB. No representative will be required.
Exporting or importing animal feed between NI and the EU
There will be no new requirements to export or import animal feed between NI and the EU. No representative will be required for either imports or exports.
Summary chart of representatives required
The table below provides a summary of the representatives required for different trade routes.
England, Northern Ireland and Wales
GB Representative Requirements
The GB representative must:
- be a feed business operator located in GB and approved or registered (or in the process of being approved or registered) with their local authority
- keep a register of all products made by the manufacturer (for which they act as GB representative) that have been exported to GB
- make a declaration that the manufacturer of feed products being exported to GB complies with requirements, at least equivalent to those laid down in retained EU law, relevant to the activity. These requirements include certain conditions relating to hygiene and quality standards in relation to:
- record keeping
The requirements for a representative based in Northern Ireland will be the same as those set out above for a GB Representative in Great Britain; other than registration will be with DAERA rather than the local authority. An alternative form is provided to do this, which should be submitted to the same email address.
For feed additives, compound feeds and premixtures not consisting of, or not containing coccidiostats or histomonostats you should complete the appropriate declaration form below and email to email@example.com.
For feed additives that are coccidiostats or histomonostats, or compound feeds and premixtures that contain coccidiostats or histomonostats, feed businesses should contact the Veterinary Medicines Directorate (VMD)
Upon submitting a declaration, the FSA will provide the declarant with an acknowledgement confirming that the declaration has been received.
The information provided in the declaration will be shared with the local authority of the GB representative, and/or the appropriate devolved authority (Food Standards Scotland/FSA Wales/FSA Northern Ireland/DAERA).
Your name and details, along with those of the business you are representing, will be included on a list published on the FSA website.
Great Britain (England, Wales and Scotland)
England, Scotland and Wales
Lists of GB and NI Representatives
Great Britain (England, Wales and Scotland)