Gatekeeping in the Feed Sector: EFISC-GTP Safety Requirements

Within today’s feed supply chain, safety depends on the reliability of every stage. Still, there are cases when a company has to buy raw materials from a supplier that does not hold a recognized safety certificate. For such situations, the international EFISC-GTP standard provides a gatekeeping procedure — a set of strict intake rules that makes it possible to safely introduce uncertified raw materials into the wider supply chain.
1. What gatekeeping means and why it is usedThe purpose of EFISC-GTP certification is to maintain feed safety throughout the entire chain, beginning with the raw material processor. Gatekeeping is used only in exceptional situations when a supplier, or a specific part of the chain, is not certified. Under this procedure, the certified buyer takes full responsibility for checking, auditing, and verifying the safety of incoming materials.
The protocol separates raw materials into several categories, with specific rules assigned to each of them:

• Unprocessed products: cereals, oilseeds, and legumes.
• Processed feed materials: products that have been physically or chemically processed, such as meals, bran, pulp, and similar materials, as well as by-products from the oil and fat sector, including fatty acids, distillates, and soapstocks. Additional requirements may apply to these materials in line with section 6.2.1.
• Palm oil: crude, refined, and fractionated forms.
• Former food products: goods originally produced for human consumption but redirected to feed use for commercial or logistical reasons.

Compared with other mutually recognized certification systems, EFISC-GTP does not impose geographical limits, and different recognition routes apply depending on whether the company is registered as a food operator under European legislation. At the same time, the gatekeeping procedure does restrict certain products. For example, uncertified grain cannot be purchased from countries including the Netherlands, Belgium, Germany, France, the United Kingdom, Canada, and several others.
For processed materials, the restriction list is broader and also includes Pakistan in the case of molasses, as well as Malaysia and Indonesia for palm kernel cake.
Safety must be demonstrated through a strict testing programme. The key requirements are as follows:

• Sampling methods: samples have to be taken in accordance with GAFTA, FOSFA, or ISO standards.
• Inspector qualifications: sampling must be carried out by an independent organization accredited to ISO 17020 or ISO 9001 together with GAFTA approval.
• Mandatory analysis parameters: every batch must be checked for pesticides, heavy metals such as arsenic, lead, mercury, and cadmium, as well as dioxins and mycotoxins including aflatoxin B1, DON, and zearalenone.
• Positive release principle: by-products from the oil and fat industry are subject to positive release, meaning the product may not be used until laboratory testing confirms that it is safe.

Special attention is given to processed oil products. The rules also define a negative list of materials that are strictly forbidden for use in feed:

• by-products from biodiesel production, for example MONG;
• tank bottoms;
• fats recovered from wastewater treatment systems;
• animal fats, within the scope of this plant-based protocol.

Companies applying gatekeeping must:

1. inform their certification body that these rules are being applied;
2. audit suppliers of former food products at least once a year;
3. submit an annual report to EFISC-GTP indicating purchased raw material volumes, their origin, and the periods during which gatekeeping was used.

At the same time, these rules make it possible to use uncertified suppliers without restricting the rights of other producers or the possibility of being the first point in the chain, provided that the additional risks connected with the use of such products in the supply chain of certified producers — both under EFISC-GTP and under other mutually recognized certification schemes — are assumed.