PET Food Processing - December 2022 - 29

cently shared this position during a listening session
held by the CVM on Oct. 18 and subsequently in written
comments submitted in November. AFIA's legal opinion
is that such a change can be implemented without
amending the Federal Food Drug and Cosmetic Act or
FDA regulations and these products can be reviewed
through the existing review pathways - food additive
petition, GRAS and AAFCO.
Without this policy change, our country will continue
to lag behind most of the world, including the European
Union, Canada, Brazil, Australia and others, in approving
safe, effective feed ingredients with animal production,
environmental and other benefits. This delay is not
only preventing farmers and pet owners from accessing
these technologies but is limiting the United States in
making progress on its climate and food security goals.
The industry is not alone in this request. Over 1,000
people registered for the listening session, and 18 of the
20 speakers agreed for the need for the agency to modernize
its policy. Secretary of Agriculture Tom Vilsack
has spoken many times about the role feed ingredients
can play in reducing greenhouse gas emissions and
has urged the FDA to modernize its approach. Even
Congress, in its fiscal 2022 appropriations bill, directed
the CVM to study this old policy on animal food claims
and make this change.
By modifying its policy, the agency will strengthen its
mandate of ensuring public health by giving these products
a regulatory review pathway for safety to the animal,
human food safety and efficacy that will be utilized
by our industry. This policy change has the potential to
remove some of the industry's challenges in completing
submission packages and which the CVM staff face
while trying to review these ingredients under the guise
of a food providing taste, nutrition or aroma.
The AFIA anticipates that the CVM will make progress
in modernizing its policy interpretation and is collaborating
with state feed control officials, Congress and
the administration to ensure that the regulatory agency
has the necessary resources to handle this new workload
and for policies to be in place to allow farmers and consumers
to get access to these ingredients.
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PET Food Processing - December 2022

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