If you manufacture, store, transport, or trade animal feed in the UK, you are legally required to operate a HACCP-based food safety management system under EC 183/2005 — the Feed Hygiene Regulation, retained in UK law post-Brexit. Most HACCP guidance, training courses, and software tools are written for food manufacturing and then awkwardly adapted for feed. The hazard categories overlap but are not identical. The regulatory framework is different. The process contexts are different. The scheme requirements (UFAS, FEMAS) have their own structure and expectations.
This reference guide covers the regulatory framework, feed-specific hazards, and scheme requirements that a feed manufacturer's HACCP team needs to understand. It is not a substitute for reading the legislation and standards themselves — but it is a practical starting point that tells you what matters and where to find it.
The Regulatory Framework
EC 183/2005 — Feed Hygiene Regulation: This is the primary legislation. Retained in UK law under the European Union (Withdrawal) Act 2018, it requires all feed business operators to implement, apply, and maintain a permanent written procedure based on HACCP principles. The obligation applies to feed manufacturers, premix producers, merchants, storekeepers, and transporters. It is enforced in England and Wales by the Food Standards Agency, in Scotland by Food Standards Scotland, and in Northern Ireland by DAERA.
The regulation establishes two tiers of obligation. Annex I covers primary production of feed (farming) with simplified requirements. Annex II covers all other feed business operations — manufacturing, processing, storage, transport, distribution — and requires a full HACCP-based system. If you are a compound feed manufacturer, you fall under Annex II.
Codex CAC/GL 80 — Code of Practice on Good Animal Feeding: This is the Codex Alimentarius guidance specifically for animal feed. It provides the HACCP methodology adapted for feed contexts, covering hazard identification, CCP determination, and control measures relevant to feed production. It should be read alongside CXC 1-1969 (the general HACCP methodology) — CAC/GL 80 does not replace CXC 1-1969 but supplements it with feed-specific guidance.
Regulation (EC) No 767/2009 — Placing on the market and use of feed: Covers labelling, claims, and composition requirements for feed. Relevant to your HACCP system because labelling errors — including incorrect nutritional declarations, missing additives information, or incorrect species suitability — are regulatory non-compliance and should be addressed in your hazard analysis.
Regulation (EC) No 1831/2003 — Feed Additives: Governs the authorisation, marketing, and use of feed additives. Only authorised additives may be used, and within the conditions specified in their authorisation. The GB Register of Feed Additives (maintained by the FSA) and the EU Register (maintained by the European Commission) are the reference databases. Unauthorised additive use is a serious regulatory offence and a hazard that your HACCP system must control.
Feed-Specific Hazards
Feed hazard analysis must address the same four categories as food — biological, chemical, physical, and radiological — but the specific hazards within each category differ significantly from food manufacturing. The following are the hazards that a feed manufacturer's hazard analysis must address as a minimum.
Mycotoxins: The single most prevalent chemical hazard category in compound feed manufacturing. The key mycotoxins are aflatoxins (particularly aflatoxin B1 — the most toxic, with EU maximum limits of 0.02 mg/kg in compound feed and 0.005 mg/kg in feed for dairy cattle), deoxynivalenol (DON — widespread in cereals, guidance values of 8 mg/kg in cereal by-products), zearalenone (oestrogenic effects in pigs, guidance values of 0.25 mg/kg in feed for gilts and sows), ochratoxin A (nephrotoxic, guidance value of 0.25 mg/kg in cereal-based feed for pigs), and fumonisins (guidance values of 60 mg/kg in maize by-products). Mycotoxin risk is driven by ingredient origin, harvest conditions, and storage — your supplier approval and incoming material testing programmes are the primary controls.
Heavy metals — lead, cadmium, arsenic, mercury: Maximum limits are set in Directive 2002/32/EC (retained in UK law). Lead: 10 mg/kg in most feed materials. Cadmium: 1 mg/kg in feed materials of vegetable origin. Arsenic: 2 mg/kg in most feed materials. Mercury: 0.1 mg/kg in most feed materials. Sources include contaminated soil (root crops, cereals), industrial contamination of water sources, and certain mineral supplements. Incoming material testing on a risk-assessed basis is the primary control.
Dioxins and PCBs: Particularly relevant in fish meal, fish oil, and animal fats — these ingredients carry the highest dioxin risk in compound feed. Maximum limits are set in Regulation (EC) No 1881/2006 as adapted for feed. The UFAS scheme requires participants to use assured suppliers for fish meal and animal fat, and AIC operates a dioxin monitoring programme funded through scheme fees. Your hazard analysis must identify dioxin risk at the ingredient receipt step for any ingredient of animal origin or marine origin.
Drug residues and carry-over from medicated feeds: If your mill produces both medicated and non-medicated feeds, cross-contamination of veterinary medicines into non-target feeds is a significant hazard. Coccidiostats are the most common carry-over risk. The Veterinary Medicines Regulations 2013 (as amended) set out the requirements for manufacturing medicated feeds, including scheduling rules, flushing procedures, and sequencing. UFAS 2024 Appendix 2 covers the updated approval categories for businesses handling controlled products following the Veterinary Medicines (Amendment etc.) Regulations 2024. Your HACCP plan must document flushing procedures, sequencing rules, and verification testing to demonstrate carry-over is within acceptable limits.
Salmonella in finished compound feeds: A persistent biological hazard in feed manufacturing, particularly in feeds containing soya, rapeseed meal, and other oilseed meals. The FSA considers Salmonella in feed a public health risk because it enters the food chain through livestock. Your hazard analysis must address Salmonella introduction at ingredient receipt, potential growth during storage (moisture control is critical), survival through the manufacturing process, and recontamination post-heat treatment. Environmental monitoring of the production environment for Salmonella is a PRP verification activity — not a CCP.
Physical hazards: Metal contamination from worn equipment, stones and earth in cereal ingredients, string and packaging material from bagged ingredients. Metal detection or screening at intake and before dispatch is common. Foreign body management procedures should be documented as PRPs.
Undesirable substances: Directive 2002/32/EC (retained in UK law) sets maximum limits for a range of undesirable substances in feed including dioxins, heavy metals, mycotoxins, pesticide residues, and botanical impurities (including ergot alkaloids and weed seeds with toxic properties). Your hazard analysis must demonstrate these are considered.
UFAS 2024 — What the Scheme Requires
The Universal Feed Assurance Scheme, managed by AIC and certified by Kiwa Agri-Food, covers approximately 95% of commercially produced compound feed in the UK and Ireland. UFAS certification is a commercial requirement — Red Tractor, Quality Meat Scotland, and the British Egg Industry Council's Lion Code all require feed to come from UFAS (or FEMAS/TASCC) certified suppliers.
UFAS 2024 (Version 1, effective 1 October 2024) is the current standard. Key HACCP-related requirements include:
HACCP study scope: The HACCP study must cover all activities within the scope of certification, including any services provided to third parties such as storage and transport of combinable crops for food. The scope must include hazards arising from any non-feed activities on the same site.
HACCP team: A designated HACCP team with a competent leader. AIC provides the "Principles of HACCP for Agri-Food" Level 2 online training course specifically for the feed sector.
Supplier approval: A documented list of approved feed ingredient suppliers with details of each supplier's feed assurance status. Where suppliers are not assured under a scheme recognised by AIC, additional due diligence is required including on-site assessment, testing, and documented risk assessment.
Sampling and testing: UFAS requires a risk-based sampling and analysis schedule. AIC publishes specific guidance on sampling and testing (the UFAS Guidance — Sampling and Testing document) which should be used to develop your schedule. Laboratories used for analysis must be accredited or demonstrate equivalent competence.
Controlled products (medicated feeds): UFAS 2024 Appendix 2 covers the approval categories for businesses producing, storing, or trading feeds containing controlled products. Following the Veterinary Medicines (Amendment etc.) Regulations 2024, the approval categories in Great Britain have been updated. Your site must hold the appropriate competent authority approval for the controlled products you handle.
Traceability: Full traceability one step back (suppliers) and one step forward (customers) is a fundamental requirement. Traceability exercises must be conducted at least every 12 months and must be completed within a defined timeframe.
FEMAS — Feed Materials Assurance
If you source feed ingredients rather than manufacture compound feeds, FEMAS (Feed Materials Assurance Scheme) is the relevant AIC scheme. FEMAS covers the supply of feed materials — individual ingredients rather than finished compound feeds. The HACCP requirements are equivalent in principle to UFAS but applied to the ingredient supply context. FEMAS has specific sector notes for high-risk ingredient categories including fishmeal and fish oil, former foodstuffs, and minerals.
Where Feed HACCP Differs from Food HACCP
Technical managers moving from food manufacturing into feed — or managing both — need to understand several key differences.
The consumer is not a person. In food HACCP, the end consumer is a human. In feed HACCP, the immediate consumer is an animal — but the ultimate concern is the human consumer of animal-derived products. Your hazard analysis must consider both: the effect on the target animal species and the potential for hazards to transfer through the food chain to the human consumer. This dual consideration is explicit in Codex CAC/GL 80 and is the reason feed safety legislation exists under the same regulatory framework as food safety.
Species-specific considerations: Different animal species have different sensitivities. Copper levels that are nutritionally essential for pigs are toxic to sheep. Ruminants can tolerate higher mycotoxin levels than monogastrics. Coccidiostats authorised for poultry are toxic to horses. Your hazard analysis and product specifications must account for species-specific tolerances and restrictions.
Medicated feed adds regulatory complexity: If you manufacture medicated feeds, you operate under both feed hygiene legislation and veterinary medicines legislation. The two regulatory frameworks intersect at your manufacturing process. Your HACCP system must address both — feed safety hazards and veterinary medicine compliance — in an integrated way. Scheduling rules, flushing procedures, and sequencing are not just HACCP controls; they are legal requirements with specific enforcement provisions.
Environmental monitoring is different: Feed mills are dry environments with very different microbiological ecology compared to food factories. Salmonella is the primary pathogen of concern, and its behaviour in a dry environment (persistence on surfaces, resistance to desiccation, reactivation when moisture is introduced) drives a different environmental monitoring approach compared to, say, Listeria control in a chilled food factory.
Thermal processing is not always present: Many compound feed manufacturing processes include a conditioning and pelleting step that applies heat — but the temperatures and times involved may not achieve full pathogen kill. Whether your conditioning step is a CCP depends on validated evidence that the temperature-time combination achieves a defined reduction in the target pathogen. If it does not meet CCP criteria, Salmonella control relies on your PRP framework — incoming material control, environmental hygiene, and post-process protection.
Building Your Feed HACCP System
Start with the legislation: EC 183/2005 Annex II sets out what you are legally required to do. Use Codex CAC/GL 80 alongside CXC 1-1969 for the methodology. Then layer on your scheme requirements — UFAS 2024 if you are a compound feed manufacturer, FEMAS if you are a feed ingredient supplier. Your HACCP plan must satisfy all three layers: legal requirement, Codex methodology, and scheme standard.
The most common failure in feed HACCP systems is treating it as a food HACCP plan with the word "feed" substituted in. The hazards are different, the regulatory framework is different, the scheme requirements are different, and the dual food-chain consideration (animal health plus human consumer safety) adds a dimension that food HACCP does not have. Build your system from the feed context upward, not from a food template downward.
SafetyCore supports both food and animal feed HACCP with EC 183/2005 and Codex CAC/GL 80 built in. Feed-specific hazard categories, species considerations, and regulatory references are part of the platform — not an afterthought bolted onto a food-only system.
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