EU Footnote 1 discussions – we discussed this issue at the last GTPC call. The importance of keeping Footnote 1 is paramount for the trade. Given the intentions of the Commission to possibly delete it and move ahead to set MRLs for feed only products in EU – Coceral are preparing a paper focusing on the following elements.

Any comments on below approach welcome until 28^th January 2026.
Elements for Commission’s consideration within the context of drafting the mandate to EFSA / Pilot project / Setting MRLs for feed-only products. 

• Scope:
  • Need to use case studies that are relevant and representative of the current situation in terms of combination feed/substance, in particular on availability of data (see below the limitations) to conduct a conclusive risk assessment.
  • Feed-only products: following-up on previous communications regarding the types of products to be regarded as “feed-only”, we think that, within the context of the upcoming pilot project, the Commission’s mandate to EFSA, and the consequent work of the Authority, would need to consider at least one product for each of the following categories:

• Crops exclusively meant for feed use (e.g. alfalfa).
• Varieties of crops listed in other chapters but meant for feed use only (e.g. varieties of sorghum)
• Part of plants used as feed only (e.g. maize silage)
• Feed-use only co-products from the processing of crops listed in chapters 1 to 9 (e.g. sunflower meal)
• Need to define the nature of the risk to be assessed: risk for animal health, risk for the environment (manure), risk for consumers of products of animal origin
• Need to consider the status of the substance, in particular whether authorised also as feed additive (example of copper compounds) 

• Risk assessment methodology
  • Aspects to reflect upon:
    • How to take into account the diversity of animal species, physiologies, production stages and inclusion rates of feed ingredients? How to deal with pets (no risk for consumers and environment for pets, shorter life for food producing animals)?

• Limitations:
  • Availability of data on process-related concentration/dilution for the assessment of MRLs for co-products for feed only
  • Availability of data on carry-over from feed to products of animal origin
  • Availability of analytical methods and sensitivity/ applicability in complex feed matrices
  • Availability on information regarding the nature of metabolites rejected in environment through manure

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