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Re: May 26 ~ EU Animal by-products regulations of 2003 are being interpreted by DEFRA to mean that butchers may no longer give a dog a bone.

Please find below an extract from EC1774/2002 - the EC Directive which is brought into force in the UK through four (!) Statutory Instruments (SIs):
a. The Animal By-Products (England) Regulations 2003. S.I.2003/1482
b. The Animal By-Products (Wales) Regulations 2003. S.I.2003/2756
c. The Animal By-Products (Scotland) Regulations 2003. SSI 2003/411
d. The Animal By-Products (Northern Ireland) Regulations 2003. SR No 2003/495

There are 4 very significant points your readers may be interested in:

(i) Paragraph 8 in the introductory text - this appears to prohibit the use of waste food being turned into swill for pigs.
(ii) Article 1 - Paragraph 2 which specifically excludes petfood from these regulations
(iii) Annex VIII - Chapter II - A(1) which allows for raw petfood to be sold using material that was fit for human consumption
(iv) Annex VIII - Chapter II - B(5) which addresses the packaging of raw petfood.

I am not a lawyer, but from my reading of this Directive (as a dog owner), it would appear that the Directive was not intended to cover a butcher selling or giving me raw bones as raw petfood - providing that the bones were from an animal that was fit and destined for human consumption. It would appear that the instruction by Ceredigion County Council to butchers not to provide their customers with raw bones is yet another example of UK authorities over complicating the UK implementation of an EC Directive. Worst case all the butcher appears to be required to do - if you ignore the exemption in Article 1 - is to approriately wrap the bones (e.g. using the same sort of polythene wrappers/bags that they are already using for the meat to be consumed by the human customer)

Perhaps this is a case where dog owners and other interested parties should write to their MPs/MEPs and question the UK interpretation of EC Directive 1774/2002.

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Extract from EC 1774/2002

(Source: http://europa.eu.int/eur-lex/pri/en/oj/dat/2002/l_273/l_27320021010en00010095.pdf
 - Note this is a 95 page document)

EN 10.10.2002 Official Journal of the European Communities L 273/7

REGULATION (EC) No 1774/2002 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 3 October 2002 laying down health rules concerning animal by-products not intended for human consumption

Introductory Text
(8) Catering waste containing products of animal origin can also be a vector for the spread of disease. All catering waste generated from means of transport operating internationally should be disposed of safely. Catering waste produced within the Community should not be used for the feeding of farmed animals other than fur animals.

Article 1 - Scope

2. This Regulation shall not apply to:
(a) raw petfood originating from retail shops or in premises adjacent to sale points, where the cutting and storage are performed solely for the purpose of supplying the consumer directly on the spot;

Article 2 - Definitions
1. For the purpose of this Regulation, the following definitions shall apply:
(a) animal by-products: entire bodies or parts of animals or products of animal origin referred to in Articles 4, 5 and 6 not intended for human consumption, including ova, embryos and semen;

Article 4 - Category 1 material
1. Category 1 material shall comprise animal by-products of the following description, or any material containing such by-products:
(e) catering waste from means of transport operating internationally;

Article 6 - Category 3 material

1. Category 3 material shall comprise animal by-products of the following description, or any material containing such by-products:
(a) parts of slaughtered animals, which are fit for human consumption in accordance with Community legislation, but are not intended for human consumption for commercial reasons;
(b) parts of slaughtered animals, which are rejected as unfit for human consumption but are not affected by any signs of diseases communicable to humans or animals and derive from carcases that are fit for human consumption in accordance with Community legislation;
(c) hides and skins, hooves and horns, pig bristles and feathers originating from animals that are slaughtered in a slaughterhouse, after undergoing ante-mortem inspection, and were fit, as a result of such inspection, for slaughter for human consumption in accordance with Community legislation;
(d) blood obtained from animals other than ruminants that are slaughtered in a slaughterhouse, after undergoing antemortem inspection, and were fit, as a result of such inspection, for slaughter for human consumption in accordance with Community legislation;
(e) animal by-products derived from the production of products intended for human consumption, including degreased bones and greaves;
(f) former foodstuffs of animal origin, or former foodstuffs containing products of animal origin, other than catering waste, which are no longer intended for human consumption for commercial reasons or due to problems of manufacturing or packaging defects or other defects which do not present any risk to humans or animals;
(g) raw milk originating from animals that do not show clinical signs of any disease communicable through that product to humans or animals;
(h) fish or other sea animals, except sea mammals, caught in the open sea for the purposes of fishmeal production;
(i) fresh by-products from fish from plants manufacturing fish products for human consumption;
(j) shells, hatchery by-products and cracked egg by-products originating from animals which did not show clinical signs
of any disease communicable through that product to humans or animals;
(k) blood, hides and skins, hooves, feathers, wool, horns, hair and fur originating from animals that did not show clinical signs of any disease communicable through that product to humans or animals; and
(l) catering waste other than as referred to in Article 4(1)(e).

ANNEX VIII - REQUIREMENTS FOR THE PLACING ON THE MARKET OF PETFOOD, DOGCHEWS AND TECHNICAL PRODUCTS

CHAPTER II - Requirements for petfood and dogchews

A. Raw material
1. The only animal by-products that may be used to produce petfood and dogchews are those referred to in Article 6(1)(a) to (j). However, raw petfood may be manufactured only from animal by-products referred to in Article 6(1)(a).

B. Processing standards

5. Raw petfood must be packed in new packaging preventing any leakage. Effective steps must be taken to ensure that the product is not exposed to contamination throughout the production chain and up to the point of sale. The wording ‘petfood only’ must be visibly and legibly displayed on the packaging.