Animal feed legislation: EU 183/2005 and GMP+
Regulation (EC) No 183/2005 is the European law on animal feed hygiene. That law says that animal feed businesses must register or be approved with the competent authority. In the Netherlands this is the Nederlandse Voedsel- en Warenautoriteit (NVWA, Netherlands Food and Consumer Product Safety Authority) . GMP+ is a voluntary scheme that is not in the law, but does put the legal requirements into practice.
This is the legislation behind the question of whether GMP+ is mandatory. In short: the law requires you to register, while GMP+ is a choice the sector made itself.
GMP+ does not replace the law. Even with a GMP+ certificate, you must be registered or approved with the NVWA if the law requires that for your activity.
What does Regulation 183/2005 cover?
Regulation 183/2005 covers animal feed, not food for people. The law applies to businesses that produce, store, transport, trade or distribute animal feed. It sets requirements for the hygiene and safety of that feed.
Take Mengvoeder Van Dijk BV (a fictional company) as an example. It makes complete compound feed for dairy farmers in the region. The company falls under the law because it produces and sells animal feed. It must therefore be registered with the NVWA, even though it holds a GMP+ certificate.
Registration or approval: which route applies?
The regulation has two routes. Article 9 covers registration: this is the basic obligation for businesses in the chain. Article 10 covers approval. This applies to products, processes or activities with a higher risk. An approval is more demanding than a registration.
| Route | For whom | Example |
|---|---|---|
| Registration (Article 9) | Basic obligation for businesses that produce, store, transport or trade animal feed | A trader that buys feed and resells it |
| Approval (Article 10) | Activities with higher risk, such as fat blending and the processing of crude vegetable oil | A company that blends fats for animal feed |
Which route applies to your company is set out per business type in the NVWA information sheet . Read that information sheet before you make a choice.
Are you moving, expanding or stopping an activity? Then you must update your registration or approval with the NVWA.
How do you register with the NVWA?
The NVWA is the competent authority. It receives registrations and approvals, keeps the registers and inspects businesses. The process is short, but you must do it yourself.
Determine your route
Check the NVWA information sheet for the activity that applies to your company. This tells you whether you need a registration or an approval.
Register your company
Submit the registration form to the NVWA. List all locations where you produce, store or transport animal feed.
Keep your details up to date
Report changes to the NVWA straight away. Think of a new location, a new activity or a stopped production line.
What happens without registration?
Without registration or approval, you may not carry out the activity. The NVWA enforces this and can use various interventions, ranging from a warning to other measures. Which intervention applies is set out in the NVWA’s intervention policy on nvwa.nl .
How does GMP+ relate to the law?
GMP+ is a voluntary scheme of GMP+ International. Certification is therefore not legally required. The sector chose to cover the risks itself. The legal requirements therefore still apply.
GMP+ translates those requirements into practical rules. The GMP+ requirements include, for example, rules on maximum levels for undesirable substances, a list of prohibited products and rules for sampling. An auditor checks whether you follow those rules.
| Regulation 183/2005 | GMP+ FSA | |
|---|---|---|
| Status | European regulation, legally mandatory | Voluntary scheme of GMP+ International |
| What it requires | Registration or approval and safe production | Practical requirements per link, such as purchasing, transport and production |
| Who checks | The NVWA | A certification body accepted by GMP+ International |
| Consequence of a shortfall | Intervention by the NVWA | Deviations at audit, see the audit page |
Livestock farmers working under quality systems such as PVE/IKB and KKM often ask for GMP feed. Their suppliers in the feed chain therefore often need to meet GMP+ FSA. In this way, a scheme that is not in the law can still become mandatory through a contract. Read more on who GMP+ is for.
Where do you find the current legal texts?
Legal texts change. Read the current text of the regulation on EUR-Lex before you make a decision. The Dutch implementation is on wetten.overheid.nl . Unsure about your own situation? Then ask the NVWA.
Frequently asked questions about animal feed legislation
Do I need a GMP+ certificate if I am already registered with the NVWA?
Not necessarily. GMP+ is not legally mandatory. But if you supply livestock farmers who work under PVE/IKB or KKM, your customer often asks for it. Read more on is GMP+ mandatory?.
Does GMP+ replace inspection by the NVWA?
No. The NVWA inspects on the basis of the law. A GMP+ audit checks on the basis of the scheme. Both can apply at the same time, and one does not replace the other.
Which route fits a company that only transports?
Transport of animal feed falls under the registration obligation. Whether you also need an approval is set out per business type in the NVWA information sheet. The transport part of GMP+ is covered on transport and storage.