Feed availability: VLOG rules for the exceptional case

- Since the onset of the Ukraine war, the availability of non-GMO animal feed has also been an issue. By now, it has become clear that sufficient feed is available in the short and medium run. Nevertheless, in order to be prepared for all scenarios, VLOG has prepared a set of rules. Feedback from the authorities is still outstanding.

Russia's attack on Ukraine and the ongoing war have also affected agri-commodity trade supply chains. In recent years, raw materials for the production of non-GMO were also sourced from Russia and Ukraine. This situation has created uncertainty about the availability of non-GMO feed.

Despite availability, preparation is important even for unlikely scenarios

However, current figures and information quite clearly suggest continued availability. Nevertheless, it is important to be prepared for unlikely scenarios as well. This is because the markets cannot react flexibly when it comes to product claims on packaging. Lead times for packaging reprints sometimes amount to up to six months.

For this reason, VLOG has worked intensively with representatives of the feed and food industry to develop a detailed set of rules for the eventuality that GM-free feed should not be available in individual cases.

Ensuring supply in all cases

This regulation is intended to cover situations in which, firstly, there is demonstrable non-availability of GM-free feeds and, secondly, it is unavoidable to place packaging bearing the "Ohne GenTechnik" (Non-GMO) seal on the market in order to ensure the security of food supply, even though it cannot be guaranteed that the production criteria have been fully complied with.

In such a case, the inapplicable "Ohne GenTechnik" labeling would have to be corrected through consumer information at the point of sale, on the websites of the distributors and through media publications by VLOG. The aim is to inform all buyers of such "Ohne GenTechnik" products about the exceptional situation in order to avoid misleading. In addition, legal certainty is important for the distributors of the foods concerned.

A draft is available to the authorities for review

The monitoring of food claims is the responsibility of the German Länder and there the respective supreme food monitoring authorities. On 30 April 2022, VLOG therefore submitted the draft of this exemption regulation for evaluation to the Federal/Länder authorities Working Group on Food and Daily-Use Items, Wine and Cosmetics (ALB) of the Länder Working Group on Consumer Protection (LAV). All supreme food supervisory authorities are represented in this working group.

The comments of the supreme food monitoring authorities of the Länder are currently collected by the ALB and are to be sent to VLOG shortly. VLOG will integrate this feedback, use it to finalize the exemption rule, and adopt it through its Board.

Rules will only be put into effect in the event of actual non-availability

However, the exemption rule will only be put into effect if manufacturers in the compound feed industry plausibly report to VLOG the non-availability of relevant straight feeding stuffs for the production of label-free feed.

In order to achieve planning security, the food industry needs clarity on the arrangement of the exemption as soon as possible. Therefore, VLOG will publish the draft exemption in the version also received by the ALB, supplemented by the form for a non-availability certificate for GMO-free feed.

DRAFT: VLOG rules for dealing with availability bottlenecks