Animal Vegetable or Mineral.

There are new regulations coming in from 2017 relating to imports of  products derived from animal origin. It is required by the EU that products derived from animal health should be subject to veterinary checks at port of entry by a Port Health veterinary Officer.  See http://www.porthealth.eu/Import-Process-POAO_2007_275.htm

 

In a reciprocal agreement non Eu countries have to show they have competent vet checks in place and that the non EU producer is registered with the EU authorities as an approved producer. This seems quite sensible to protect consumers in the EU from possible diseases that can be passed on through imported animal products.

 

There are new additions to the Eu Regulations and a new sector called highly refined products. Included  are amino acids made from feathers and which are classified as additives. Additives are E numbers to you and me and will affect E920 Cysteine and E641 Leucine . Strangely the new legislation includes Glycine E640.  Glycine in commercial quantities is made from Ammonia and Chloroacetic Acid and is thus totally synthetic . Also included is E620, Glutamic Acid from which springs that old favourite  Monosodium Glutamate ( E621).  MSG was discovered in  1866 from wheat gluten and then isolated from seaweed in 1906 in Japan.  In all its history it has never been derived from an animal product.  So now we have to prove that something known for more than 100 years is not from animal origin and to provide evidence of this.

It makes on wonder just how competent the authorities are if they are unable to discern the difference between and animal and a vegetable> There used to be an old  TV quiz show in the 1950’s called Animal vegetable or Mineral ? In this show there were a panel of distinguished experts including historians and archaeologists and fine art experts who identified objects placed before them. Obviously the panel in the EU who determined the origin of MSG are not as distinguished or so expert and so we would have to consider the well known childrens game of the same name. In this child’s game you determine if the object is animal vegetable or mineral and then with 20 questions the others have to guess what it is . Anyway you I am sure you know the game…well most of you do except those who work out the regulations in our review.

I would ask them to go back and use the criteria in the child’s game and ask a few questions. I could even be fun trying it the children’s game way. For example lets take MSG.

Oh dear at the  first hurdle the EU fall down as they have determined it is animal. No I could forgive a single child of four years old,  making such a mistake but maybe a panel of so called experts  should surely not make such a mistake.  Is it animal derived ? Well yes they must have agreed even though an elementary Google Search would have thrown up doubts at this.  I tried Google for Glutamic acid and all I could find was derived from seaweed or wheat gluten. Yet the combined expertise of the EU has deemed it possible animal origin ?  Could be derived from Trifid I suppose ? No even they are vegetable >

What is worse is that Port health UK, DEFRA and the Food Standards agency have blindly accepted the regulations from the EU. But it will all be better after Brexit you say but unfortunately the same UK “experts” will have to try and figure out if some foods are animal or vegetable or mineral for themselves. The same ones who cannot question an EU decision.

The responsibilities in the UK are as follows and this is from Port Health itself

At central level:

DEFRA, through their agency APHA, have overall responsibility for imports policy concerning products of animal origin which includes food supplements where these contain products of animal origin.

Public health policy concerning food including products of animal origin and public health aspects of food supplements are dealt with by FSA. Their remit also includes novel foods.

At local level:

Day to day enforcement of the import requirements for products of animal origin and food is by Port Health authorities which are part of local councils. Therefore you will be dealing with a different port health authority depending on the port you are importing through.

If you import food supplements, Vitamin tablets, capulses, fish oil softgels then  Port Health can advise but  may refer you to APHA, FSA where import conditions are not clear.

You will see from the above that responsibilities are split over several government departments who each deal with different aspects of food supplements – animal health requirements, public health requirements, composition and labelling. I agree this is not ideal but it is the current situation and there is no one place where you can find all the information. Why not ?

I suggest that if you have enquiries, if the product contains anything derived from animal products you start by contacting APHA. If there is nothing of animal origin then you should contact FSA who will refer you to DH if appropriate. DH have provided some guidance: https://www.gov.uk/government/publications/food-supplements-guidance-and-faqs.

Your local Trading standards department or Environment Health department will also provide advice

 

Now we can approach the new ingredients and additives on the new list. Let’s look at  Cysteine which can be made from a destructive chemical reaction on chicken feathers.  Unfortunately our experts will be faced with a problem on cysteine as those clever people ( not in the UK)have figured out a way to make it from a non animal source using biotechnology.  Now the brains who could not figure out that MSG is plant derived have little chance if figuring out if cysteine will be chicken or biotech derived ! The import HS Codes will be the same but they will rely on statements from the producing factory that it is not chicken derived.  If  it is from Chicken and for human use ,then we will need a  Vet Cretificate signed by a competent authority in the country of origin ( CIQ in the case of China ). The producing factory will have to be registered in the EU and the factory approval number stated on the document. There is one problem here, none of the factories producing amino acids are registered and approved . It will take months to approve a factory and I do not exaggerate if we are looking at 2018 before approval is complete.

Meanwhile what do companies using these amino acids do ? Tyrosine is produced from feathers and is an important nutrient in the animal feed industry. A shortage of supply here could have serious effects on pricing and rearing of animals .  The sports nutrition industry uses  leucine and valine but luckily there are fermentation grades available. Cysteine is used in bread, meat flavours and petfood with major groups such as Nestle and Pedigree petfood using hundreds of tonnes. Again fermentation cysteine is available at more than double the price but not in enough quantity.

 

So if we import fermentation grades  Port Health advise

“The amino acids that do not derive from animal origin are in theory not subject to veterinary checks and they will need only commercial documentation (Bill of Lading, invoice and packing list) however you should be prepared to demonstrate that the products are not of animal origin on request.”

So how do we demonstrate the products are not of animal origin ? Do we engage in a game of Animal Vegetable or Mineral with Port health and Customs Officers ?  It’s more than they did by accepting this legislation . Now I am sure there are tests in place to determine if cysteine is from chickens  or fermentation. DNA would sort this out you may think but the process of making cysteine from feathers is so destructive that perhaps no DNA will be available.  Then I suppose checking the carbon profile where there are no doubt profiles of carbon isotopes that may determine if from a chicken feather. However if we have to go to such lengths then our goods will be sitting at the docks for weeks running up hefty bills for demurrage while testing at this level is done.

No I say Port Health are the ones who will impound your imports at a whim and it is Port Health who should interpret all the advice from the other departments and draw up clear guidelines which will be applied fairly and consistently at all ports and by all officers

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