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Q Do feedingstuffs have to be classified, labelled and packaged in accordance with the CLP Regulation, and their substances notified to the Classification and Labelling Inventory?

According to Article 1(5)(e) of CLP, the CLP Regulation does not apply to feedingstuffs within the scope of Regulation (EC) No 178/2002 (Food Safety Regulation), which are in the finished state, intended for the final user, including when they are used: 

  • as an additive in feedingstuffs within the scope of Regulation (EC) No 1831/2003;
  • in animal nutrition within the scope of Directive 82/471/EEC.

It is important to note that the conditions 'in the finished state' and 'intended for the final user' must both be fulfilled at the same time, otherwise CLP applies. 

The terms 'finished state' and 'intended for final user' are not defined in CLP. The CLP definition of 'use' includes 'consumption', which would mean that a consumer qualifies as a user. Drawing a parallel between the term 'final user' in CLP and the definition 'final consumer of foodstuff'* in Regulation (EC) No 178/2002, feedingstuff  can only be considered to be 'intended for the final user', if it is ready for direct oral feeding to animals. 

In accordance with Article 2(a) and Article 2(e) of Regulation (EC) No 1831/2003 (Regulation on additives for use in animal nutrition), neither feed additives nor premixtures can be used directly to feed animals. They do not fulfil the condition of 'intended for the final user', since they require the additional activity of mixing/processing before being used by the ultimate consumer (animals). Therefore, CLP applies to all additives and premixtures, including those authorised, labelled and packaged in accordance with Regulation 1831/2003. 

Feeding stuffs 'intended to be used by the final users' (animals), i.e. to be fed directly to animals, such as feed material or compound feedingstuffs are exempted from the scope of CLP, provided they are in the finished state. This includes both complete and complementary feedingstuffs - where the latter (although not sufficient for a daily ration) could be directly fed to animals and would thus also be exempted from CLP. 

*Intended for the final user should be read as intended for the 'ultimate consumer of a foodstuff who will not use the food as part of any food business operation or activity'.

Muokkauspäivä: 08/08/2019
Topic: CLP
Scope: Scope and exemptions under CLP
ID: 1535
Versio: 1.0
This answer has been agreed with national helpdesks.

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