The Association of American Feed Control Officials (AAFCO) has warned against bringing hemp feed and pet food to market through a state-by-state patchwork of laws before in-depth research into such products, a formal review process and approval at the federal level.
AAFCO, comprising state, federal and international control officials who regulate animal feed products, said in a recent call to action that rushing such products to market could lead to inconsistent manufacturing methods, dubious marketing claims and restrictions in interstate and international markets.
Warning on impacts
“Allowing hemp byproducts to be used for animal nutrition before rigorous research and legal approval processes have been completed could have adverse impacts on ranchers’ access to markets, on animal health, and ultimately on human health,” said Susan M. Hays, AAFCO executive director.
Hemp advocates have focused on passing state legislation to allow the use of hemp as a feed ingredient despite a lack of national approval that would be underpinned by comprehensive safety reviews, AAFCO said.
Montana passed a measure authorizing hemp food ingredients as commercial animal feed earlier this year. The definition of commercial feed in that measure included hemp seed food ingredients and substances. Proponents said the measure is a major advancement in the development of the U.S. hemp grain industry, gives farmers a wider berth to do business, and opens up the market for producers of products for pets, specialty pets, and horses.
“We understand the hemp industry is eager to enter the animal food market, but we are concerned that not enough research has been completed on these products,” Hays said.
“Rather than unilaterally approving the use of hemp as a feed ingredient, in conflict with AAFCO’s century-old model for animal food ingredient approval, advocates should support continued research and development, and promptly submit applications to AAFCO and the FDA for review and approval on a national level,” the Association said.
AAFCO provides ingredient definitions, label standards and laboratory guidance for state, federal and international feed regulators. The Association’s Official Publication is relied on globally by animal food regulators and the animal nutrition industry as the authoritative guide to animal feeding ingredients approved for use in the United States.
The Association said it wants to work with lawmakers, key stakeholders such as the Food & Drug Administration, the U.S. Department of Agriculture, the National Association of State Departments of Agriculture, livestock and dairy associations, and consumer advocacy groups in guiding hemp through AAFCO’s formal process for review and approval.
Standards and definitions
AAFCO said more research is needed on hemp and hemp byproducts such as whole hemp plants, hemp seed oil, CBD, and other cannabinoids. Data needs to be compiled on THC, nutrition, safety and efficacy before safety standards and definitions for various ingredients can be established, the Association said.
The U.S. Hemp Feed Coalition (HFC) announced earlier this year it is seeking approval of its first hemp product – hempseed meal and cake for laying hens – from AAFCO and the U.S. Food and Drug Administration’s Center for Veterinary Medicine. That application was prepared by hemp and feed industry experts and researchers over two years and is based on clinical trials.
In other observations in AAFCO ‘s call to action, the Association noted:
- While research is currently underway, there has yet to be a definitive scientific understanding of the transfer rate of THC, CBD and other cannabinoids into meat, milk and eggs.
- Consumers should have reasonable expectations that the food they are consuming is free of any residual levels of THC or CBD. But research and a regulatory structure needed to provide that security do not yet exist.
- Even if a state legalizes hemp or hemp byproducts for use in animal food, their use is still illegal at the federal level.
- The allowance of hemp in livestock feed prior to it becoming an approved ingredient could result in trade barriers or affect reciprocity agreements for feed and livestock between states.
- The use of hemp byproducts may close market opportunities for ranchers and dairies, with stockers and suppliers unwilling to accept the risk of purchasing products from operations that feed their animals hemp byproducts prior that do not have federal approval.