By Liesl Breytenbach
Feed labels in South Africa are regulated by the Fertilisers, Farm Feed, Agricultural Remedies and Stock Remedies Act (Act 36 of 1947) and provides for a label of uniform format and composition which further encourages a level playing field for both the user and distributor.
All compound, supplementary and complementary feeds, concentrates and feed ingredients sold or imported into South Africa must contain a label that conforms to the requirements as set out in regulation 20 to 22 of the legislation. If the feed product is sold in bulk, the label should either be attached to the invoice or the exact particulars thereof be printed on the invoice.
In addition to the label requirements of Act 36 of 1947, feed manufacturers and distributors must also comply with the product labelling requirements as per Section 24 of the Consumer Protection Act (Act 68 of 2008), which stipulates that all products should be labelled in a manner that is in comprehensible language, clearly indicating the purpose and use of the product.
Any products (goods) that are manufactured or produced by using ingredients containing at least 5% genetically modified organisms (GMOs) should be labelled as ‘Contains genetically modified organisms’. The wording may not be altered and the notice must be displayed in an obvious and easily legible manner and size.
The specific requirements for label contents vary among the different classes of feed, but ultimately all animal feed labels should display the following information in the prescribed order:
• Trade and product names.
• Type of animal feed / purpose statement.
• Registration number and reference to Act 36 of 1947.
• Guaranteed analysis statement.
• Quantity or nett weight statement.
• Ingredient statement.
• Feeding directions for safe and efficient use, including warning statements where applicable.
• Name and address of the manufacturer or distributor (registration holder).
• Batch number and manufacturing, expired or best-before dates.
The trade name is the name under which the business trades for commercial purposes and the product name should be appropriate for the intended use of the feed and may not be misleading in any way. A purpose statement provides information on the specific species and animal class for which the feed is intended. For instance, ‘Concentrate feed for dry dairy cows’ is a purpose statement. The various classes of animal feed are available in Table 4 of the Regulations relating to farm feeds (R1087, 3 November 2006).
The registration number is a five-digit V-number issued by the registrar of feeds upon successful registration of a feed product, and it should be expressed as ‘Reg. no. V… Act No. 36 of 1947’ on the label. The guaranteed analysis lists the quantities of nutrients that must be present in the feed product, in a particular order, with the required unit of measurement and on an ‘as is’ basis as shown in Table 1.
The percentage of non-protein nitrogen sources should also be indicated in the case of protein. The required guarantees will vary according to the species and intended use of the feed.
It is essential to also indicate the feed container’s nett weight on the label. If the feed is sold in more than one kind of packaging, all available weights must be declared in the registration application and concept labels must be submitted for each nett weight to be offered for sale.
Uncontrolled repackaging of animal feeds in smaller, unmarked bags presents a major concern for the registrar and responsible animal feed manufacturers. This practice is, however, steadily increasing, especially with regards to poultry feed and pet food in informal settlements. The risk of contamination or adulteration during unlawful repackaging cannot be ignored and it further handicaps the traceability chain of the animal feed manufactured and sold.
Registration holders are required to list on the label the ingredients used in the manufacture of the feed in order of predominance by weight. The ingredient names used for the statement are defined in the official definitions of farm feed regulations (Table 1), but collective terms such as plant protein products, animal protein products, grain products, forage products, roughage products, processed grain by-products etc. can also be used.
All the ingredients included in the product must be accounted for, including supplemented vitamins, minerals and preservatives or additives.
Medicated feeds, as well as feeds containing non-protein nitrogen, high copper or animal proteins which are prohibited in ruminant feed must all include appropriate warning statements that are visible on the principle display panel of the label. Additional directions for the safe and efficient use of the feed may be printed on the back of the label and the reader directed towards it with ‘See back of label for feeding instructions’.
Directions for medicated feed should provide the user with specific information regarding the intended dosage, weight restriction, mixing instructions and withdrawal periods if and when required. This information may also be indicated on a separate stock remedy label which is affixed to the registered feed product label.
If a product contains medicinal residue, the label shall contain the following statement in bold typeface: ‘Warning: This product contains drug residue. Do not use within 15 days of slaughter and do not use 15 days prior to or during the food production period of dairy animals and laying hens.’ If a feed product contains more than 25ppm copper, there has to be a clear warning in bold typeface: ‘Warning: Contains high levels of copper. Do not feed to sheep.’
Products containing animal proteins prohibited in ruminant feed must contain the statement: ‘Do not feed to cattle or other ruminants.’ Animal feeds containing non-protein nitrogen (NPN) should include information on the safe and effective use of the product, and the label should bear the appropriate warning according to the respective type of animal feed. For a complete table summarising the various NPN warnings as listed in Table 12 of the regulations.
Lastly, the registration holder of a particular feed (feed manufacturer or distributer) must provide his name, address and telephone number on the label. A batch number should appear on the label for traceability purposes and the product’s shelf life indicated by means of an expiry date. Claims used in animal feed can be divided into health claims, nutrient content claims and structure/function claims, and it is the registration holder’s responsibility to ensure the validity of these by providing sufficient and substantiating evidence thereof.
The registration holder accepts responsibility for the production of safe, efficient and compliant feed products and that they are used as intended. In turn, the user is responsible for ensuring that he purchases only registered animal feed products and closely following the feeding and warning instructions on the label.
Where custom mixes are manufactured and sold according to client specifications, the feed products are not registered under Act 36 of 1947. The labelling of custom mix containers are, however, subject to specific requirements of the act as per Regulation 15 of the farm feed regulations.
The label or invoice of a custom mix should include the following:
• Name and address of the person who placed the order.
• The words ‘not for public sale’.
• The name of the product or for which purpose the product is intended.
• The nett weight of the product.
• The name and address of the manufacturer.
• All warnings as required in the regulations.
As an industry self-regulating measure, all registered and custom-mix feed product labels of AFMA members are verified as part of a compulsory code of conduct audit.
Contact Liesl Breytenbach at email email@example.com for more information.