Trade Advice Document
Trading advice from several sources is available to help businesses comply with the law.
The Health and Safety Executive website has advice on:
The Chartered Trading Standards Institute provides advice on a number of topics:
Mixing feed on-farm
In the guide
- Definition of additives
- Annexes to EU Regulation (EC) No 183/2005
- Annex I
- Annex II
- Annex III
- Mixing with medicines & specified additives
- Further reading
There are different requirements for the mixing of feeding stuffs on-farm, depending on the use of additives or premixtures
This guidance is for England
EU Regulation (EC) No 183/2005 laying down requirements for feed hygiene requires virtually all businesses that make, market or use animal feeds to be registered with or approved by their local authority.
The requirements for on-farm mixers of feed will vary dependent upon the types of feed being mixed. This can broadly be split into two areas, based on the Regulation's annexes:
- annex I: those farmers mixing feed for the exclusive requirements of their own holdings without using additives or premixtures of additives (with the exception of silage additives)
- annex II: those farmers not falling into the annex I category and those mixing feed with additives or premixtures of additives
Definition of additives
An additive means additives authorised under EU Regulation (EC) No 1831/2003 on additives for use in animal nutrition - for example, vitamins A and D and certain trace elements.
A premixture of additives means mixtures of additives or mixtures of one or more feed additives with feed materials or water used as carriers; premixtures are not intended for direct feeding to animals.
Annexes to EU Regulation (EC) No 183/2005
The annexes to EU Regulation (EC) No 183/2005 (please scroll down the linked web page to see the annexes) set out various standards that feed businesses must comply with.
(requirements when mixing feed for use on farmers' own holdings only, without additives or premixtures of additives)
Farmers who fit into this category are required to comply with the requirements of annex I. In summary, farmers subject to these requirements are required to:
- ensure that food and feed is produced to prevent and minimise hazards and spoilage
- take measures to control any contamination of feed from air, soil, water, fertilisers, pesticides, veterinary medicinal products, etc
- keep clean and disinfect any buildings, vehicles or equipment used for feed mixing, where necessary
- only use clean water
- prevent animals, pests and waste from causing hazardous contamination
- take account of and act upon, where necessary, the results of any analysis carried out
- keep records of measures put in place to control hazards. In particular, records must be kept regarding the following (veterinary surgeons, agronomists and agents can assist in keeping these records):
- any use of plant protection products and biocides
- use of genetically modified seeds
- any occurrence of pests or diseases
- the results of any analyses carried out
- the source and quantity of each input of feed, and the destination and quantity for each output of feed
- follow national guides of good practice and legislation regarding:
- controlling contamination of, for example, mycotoxins and heavy metals
- use of water and fertilisers
- traceability and correct use of pesticides
- traceability and correct use of veterinary medicinal products
- preparation, storage and traceability of feeds
- correct and legal disposal of dead animals, waste and litter
- prevention of the introduction of contagious disease
(requirements when not coming under annex I and/or mixing feed with additives or premixtures of additives)
Farmers who fit into this category are required to comply with the requirements of annex II. This will apply to farmers who buy in feed additives or premixtures (except silage agents) and mix them directly - for example, with forage, cereals, etc. This activity is considered to be higher risk compared to other types of activity. In summary, farmers subject to these requirements are required to apply the following measures:
- apply and document the principles of HACCP (Hazard Analysis and Critical Control Point) to every step of the on-farm feed activities - for example, facilities, equipment, storage, record keeping, etc
- keep feed machinery clean and serviceable by checking on a regular basis. You should record any cleaning and maintenance measures carried out. Ensure all feed mixers and equipment are maintained and operated appropriately to the range of weights, dilutions and homogeneity required. Regular checks should be made to ensure that homogenous mixing is achieved and such checks should be recorded
- any scales or metering devices must be appropriate to the weights or volumes being measured and should be tested for accuracy regularly. Accuracy checks should be recorded
- personnel must have sufficient skills necessary for the mixing of feed containing additives / premixtures. You should ensure staff involved in mixing receive the appropriate training and practice. Any training given should be recorded
- you must have a written procedure or instructions for mixing operations. Follow suppliers' instructions for use for any additives / premixtures. You should record formulations and the date of manufacture and retain a representative sample of each batch of finished feed produced (and of raw materials if you supply to other farmers). Where formulations change, mixing equipment should be thoroughly cleaned and if necessary flushed, especially if mixing for different species, etc
- additives / premixtures must be stored separately from finished feeds and feed materials to avoid cross-contamination
- in addition to the records mentioned above, records must be kept of the names and addresses of additive / premixture suppliers and of the quantities of additives / premixtures used with batch numbers recorded
- document a complaints and product recall system if you supply other farmers
WHAT IS HACCP?
HACCP (Hazard Analysis and Critical Control Point) in relation to annex II is a documented systematic approach to safety management.
A full HACCP study and system will analyse every step of the feed activities on-farm to identify hazards that may occur and implement controls (critical control points). The seven steps to HACCP can briefly be described as follows:
- conduct a hazard analysis to find any potential hazards that could occur during production. A hazard is something that might be harmful and may involve either microbiological, chemical or physical contamination. Determine what controls you can put in place to eliminate the hazards or reduce them to a safe, acceptable level
- determine the critical control points (CCP). Decide which of these controls are critical to ensuring feed safety. A control is critical if the hazard will not be removed at any later stage of production
- establish critical limits applicable to the CCPs - that is, establish crtiteria to separate acceptability from unacceptability
- establish a system to monitor controls of the CCPs. Once controls have been put in place they should be monitored on a regular basis to ensure they work effectively. It is not necessary to check controls on every occasion a particular process is carried out provided that you are sure the frequency of checks will enable any problems to be identified before there is a risk to feed safety
- establish the corrective action to be taken when monitoring identifies that a particular CCP is not under control. You and your staff must be clear on what action should be taken when monitoring shows that there may be a problem
- review your system and verify its effectiveness. Once established, the system must be reviewed with procedures in place to ensure that the HACCP system is working and is verified as effective. Reviews and verification should take place on a regular basis when any operations of the business change or when problems are identified
- establish documentation in the form of records and procedures in accordance with these principles
The Agricultural Industries Confederation has produced The Application of HACCP Principles: A Practical Guide for the Agri-Food Supply Chain, which is designed for use both by businesses for whom HACCP may be a completely new concept and also for those with prior experience of it.
(farmers feeding food-producing animals)
All farmers are required, in addition to the annex I or annex II requirements, to comply with the requirements of annex III of EU Regulation (EC) No 183/2005. In summary, all farmers are required to:
- manage grazing to prevent the contamination of foods of animal origin by physical, biological or chemical hazards
- observe appropriate rest periods before grazing livestock on pasture treated with manure or chemicals
- design and maintain clean stabling and feeding equipment
- implement a pest control system
- maintain feed and bedding so that it is clean and free from mould
- store feed separately from chemicals and other products prohibited in animal feed
- store medicated feed so as to avoid the risk of cross-contamination
- handle feeds so that contamination and cross-contamination do not occur
- clean watering systems regularly
- ensure that anybody with responsibility for feeding and handling of animals possesses the required ability, knowledge and competence
Mixing with medicines & specified additives
This guidance does not apply to the mixing and use of specified feed additives - for example, coccidiostats and histomonostats; nor does it apply to the mixing of feed to include veterinary medicines.
Further information can be found in the Veterinary Medicines Directorate guidance notes on the GOV.UK website.
Failure to comply with these requirements is a criminal offence. The maximum penalty is a fine and two years' imprisonment.
For more information on feed please see 'Feed hygiene for farmers & growers'.
- EU Regulation (EC) No 1831/2003 on additives for use in animal nutrition
- EU Regulation (EC) No 183/2005 laying down requirements for feed hygiene
- Animal Feed (Composition, Marketing and Use) (England) Regulations 2015
- Animal Feed (Hygiene, Sampling etc and Enforcement) (England) Regulations 2015
Last reviewed / updated: September 2018
This information is intended for guidance; only the courts can give an authoritative interpretation of the law.
The guide's 'Key legislation' links may only show the original version of the legislation, although some amending legislation is linked to separately where it is directly related to the content of a guide. Information on amendments to UK legislation can be found on each link's 'More Resources' tab; amendments to EU legislation are usually incorporated into the text.
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