Data gathering and impact assessment for a possible technical review

of the IPPC Directive Part 2

Fact sheet A4 Production of Food products

Potential amendment A4: Possible changes to the current provisions of Annex I of the IPPC Directive on the production of food products

Status: Final 12/09/2007

Aim of the study: The present work intends to evaluate the possible changes to the provisions of the Article 6.4(b) of the IPPC Directive Annex I on the production of food products, in order to clarify two specific interpretation issues and hence harmonise the permitting practice in the EU-27.

The work is based on a background literature survey, meetings and discussions with relevant industry and on the responses of the Member States to the questionnaire. It also takes into account the comments of the Advisory Group members on the draft final report.

Background: Activities concerning production of food products covered under the IPPC Directive are listed in Annex I Section 6.4(b), as

Treatment and processing intended for the production of food products from:

animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day.

vegetable raw materials with a finished product production capacity greater than 300 tonnes per day (average value on a quarterly basis).

Some interpretation problems, regarding this section were already pointed out by Member States and sector organisations during the first round of Food, Drink and Milk (FDM) BREF-writing. Further, other interpretation issues were identified by Member States in the context of the IPPC Guidance Subgroup. At the start of the current project, a list of nine potential issues was provided, including: meaning of treatment and processing, finished product, animal/vegetable based materials and average value on a quarterly basis; treatment of concentrated products; position of animal food; and threshold(s) for installations with vegetable and animal based production lines.

Based on the preliminary analysis of current practices in Member States, discussion with DG ENV, DG ENTR and sector organisations, the issues were narrowed down to two, which will be further clarified in this fact sheet.

Issue summary:

Two issues were identified to require detailed analysis and they will be the focus of this fact sheet:

animal feed (does food also cover animal feed: pet food, agricultural feed)

separate production lines for animal and vegetable based products in one installation; and products based on combinations of animal and vegetable raw materials (mixed installations)

In addition, some further points in 6.4 (b) (and also an issue related to 6.4 (c) regarding milk products) could be amended to improve the clarity of Annex I. These will be shortly outlined and discussed in Annex A.

The two main issues of this fact sheet, animal feed and mixed installations, will be described and assessed in sections 2 and 3, respectively. In both sections the sub-section x.1 describes the current practice; sub-section x.2 describes options for clarifying the issue; and the impacts of these options are analysed in section x.3.

A questionnaire covering both the issues was sent to the Advisory Group members. In addition, a questionnaire on feed issue was distributed to the national associations of the feed and pet food sector, with the help of the European federations FEFAC and FEDIAF. On the mixed installations issue, CIAAand its member organisations were consulted. Issues were also discussed with DG Environment and DG Enterprise.

1. Animal feed

2.1.Current practice

a. Current interpretation(s)

It has been unclear whether food in 6.4(b) also covers (or should cover) animal feed e.g. pet food and agricultural (compound) feed.

Food in English language has a wide meaning, hence the use in words like pet food, plant food, fish food etc. On the contrary, in some languages there is a specific word for human food, e.g. levensmiddelen and nahrungsmiteelerzeugnissen used in the Dutch and German language versions of the Directive. At least in Germany and the Flemish region in Belgium animal/pet food are currently exclude from the scope of the directive due to the national transposition based on the different language versions of the Directive.

The Food, Drink and Milk (FDM) BREF [EC 2006] covers the production of food for human consumption as well as the production of both pet food and compound feed. In most of the MS, for which information was available, both types of animal feed are permitted under IPPC (see Annex B).

The spirit of the Directive could support the broader interpretation, i.e. animal feed being included [IEG 2006a]. According to the FAQ 14 issued by the Commission [EC 2004] there is no reason to restrict the scope of food products to human food. Animal foods are often manufactured from poorer quality raw materials and hence the potential for pollution arising from their manufacture may be greater than in the case of human food. However, the FAQ has not been used as the basis for published guidance while this issue is being considered in the IPPC review.

The key European federations, CIAA, FEFAC and FEDIAF, all support the inclusion of animal food (both pet and compound) under the IPPC as part of the section 6.4(b). The feed industry does not want to be classified with slaughter houses or other such activities, and prefers to be considered a part of the food industry.

b. Size and structure of feed industry

The feed industry consists of two distinct sub-sectors, i.e. compound (livestock) feed and pet food [EC 2006]. Livestock feeds are predominantly dry, while pet food may have significant moisture content (e.g. canned food for cats and dogs). However, dry pet food also exists (e.g. for cats and dogs as well as for rodents and birds). The compound feed (for livestock) manufacturers may also produce dry feeds for pets. Thus, there are linkages between the two sub-sectors. Nevertheless, they are presented by different federations, FEFAC and FEDIAF.

Compound feed sector

According to FEFAC [FEFAC 2006], 142.1 million tonnes of compound feed were produced by EU manufacturers in 2005. There are roughly 4000 production units in the EU-25, the number being the highest in Italy, followed by UK, Germany and Slovakia (see Annex C). In terms of production volume, leading countries are France, Spain, and Germany (Figure 1).

Figure 1: EU-25 compound feed production across MS in 2005 (tonnes) [FEFAC 2006]

The average size of a compound feed production unit is around 36000 tonnes per year, which of course does not reveal the size distribution of the units. The size of an average production installation varies between MS: for example, Italy has the highest number of installations, but is only fourth by the amount of production. This shows that its production units on average are smaller than for example in France which is the leader in the production in tonnes but only fifth by the number of production units.

Since the occurrence of BSE, i.e. the mad cow disease, most of the compound feed manufacturers use exclusively vegetable based raw materials and thus the relevant threshold in 6.4(b) would be the 300 tonnes/day. According to FEFAC, the number of compound feed production installations in EU-25 having a capacity above this threshold about 1000, i.e. about 25% of all the installations.

Pet food sector

FEDIAF represents currently around 450 pet food companies in Europe (in 18 MS, Norway, and Switzerland), which are estimated to make up roughly 95% of all the pet food companies in Europe. The production of FEDIAF members is around 5 million tonnes per year and the value of production is 8.5 billion euros. The direct employment is around 21000. [FEDIAF] No details were available on the number of production installations.

Product composition and production techniques

In both sectors, the manufacturing process involves the blending of a range of ingredients such as cereals, animal/vegetable protein sources, vitamins, minerals, fats and oils, and other additives to produce nutritionally balanced foods. Some of the ingredients are co-products and by-products of the FDM sector. The composition varies depending on the type and age of the animal to be fed. Currently, much of the livestock compound feed is vegetable based, while animal raw materials are still important in pet foods. [EC 2006, FEDIAF, FEFAC 2006]

The feed and pet food industry makes use of a very high level of technology. Advanced methods are used to formulate feeds according to the demands of the livestock farmers and pet owners. Control of the raw materials used in manufacturing process and quality of the finished feeds is important. Production process typically includes weighting, mixing, cooking/extrusion/sterilisation, and packing operations. See Annex D for details.

c. Environmental impacts

Production processes and raw materials used in feed production are similar to those in FDM sector in general. Consequently, the resulting environmental impacts are considered to be similar between comparative processes. [CIAA, FEDIAF, FEFAC] Water consumption, effluent discharges, energy use and waste generation are the most common environmental impacts across the food and drink sectors.[EC 2006]

According to the European Pollutant Emission Register (EPER), FDM industry in general contributes significantly to the direct emission to water, especially for phosphorus and polycyclic aromatic hydrocarbons (PAH) (50% of the total industrial emission of EU-25 in 2004), nitrogen (20-50%), and Total organic carbon (TOC) (5-20%) [EPER 2004]. Based on the EU-15 production quantities of 1999 [EC 2006], the production of prepared feed for farm animals (excluding home-mixers) amounted to 24% of the total production of major FDM sectors, while pet food only represented 1%. So, the role of the feed industry could potentially be significant.

However, such a rough estimation ignores largely the specific characteristic of compound feed manufacturing (which, as shown above is in terms of quantity much more significant than pet food manufacturing). In compound feed production, water is mostly added as an ingredient to the feed, and some of it is evaporated when the feed is dried, but no or very little effluents are created (some possibly from e.g. odour scrubber, air compressors cooling water and cleaning). Rather than effluents, dust and odour are the main concerns in feed manufacturing without proper abatement technologies. Energy use may also be an issue, although there is mostly less need for refrigeration than in FDM production in general. Often, process steam/heat is produced on site which leads to air emissions.

Effluents with high organic content may arise from accidental releases of vegetable oils (often sprayed onto the feed pellets), molasses, formic acid (used as ingredient), etc.

d. Techniques for prevention or reduction of environmental impacts

The techniques for prevention and reduction of environmental impacts are extensively covered by the FDM BREF and the provided general BATs apply to feed manufacturing [EC 2006]. For example, to prevent air emissions from FDM/feed installations, BAT is to apply and maintain an air emissions control strategy and collect waste gases, odours and dusts at source and duct them to the treatment or abatement equipment. Unless specified otherwise, where process-integrated BAT which minimise air emissions by the selection and use of substances and the application of techniques do not achieve emission levels of 5 20 mg/Nm3 for dry dust, 35 60 mg/Nm3 for wet/sticky dust and