NGFA comments on Canadian DDG import rules

By Jerry W. Kram | April 08, 2008
Web exclusive posted April 21, 2008 at 11:57 a.m. CST

The National Grain and Feed Association has submitted comments to the Canadian Food Inspection Agency, urging it to make significant changes to proposed rules on the importation of dried distillers grains into Canada.

In a statement to the CFIA, the NGFA stressed the importance of the agency developing sound science- and risk-based policies to facilitate the safe production and use of DDG, while preserving cross-border trade. The NGFA said several elements of CFIA's draft policy exceed the requirements necessary to ensure the safe production and use of distillers grains products, and they are not in harmony with current U.S. feed regulations applicable to such co-products.

Dave Fairfield, director of technical services for the NGFA, said association has four main concerns: antibiotic residues, processing aids, sulfur and ingredient labeling. "What we are trying to do is emphasize the need for the CFIA and the U.S. Food and Drug Administration to have harmonized regulations for distillers grain products to allow continued cross border trade," Fairfield said. "Currently, distillers grains exports by U.S. biofuels producers to Canada are significant. And there are some companies in the U.S. feed business that rely on Canadian imports as well. So we want to try and ensure that however this process moves forward, there aren't any barriers to trade established."

The NGFA urged the CFIA to limit, for the time being, the use of antimicrobial drugs allowed during fuel-ethanol fermentation. CFIA proposed to set maximum inclusion rates for four approved antimicrobial drugs: penicillin, streptomycin, ampicillin and virginiamycin. The NGFA asked CFIA to limit the approved use of antimicrobial drugs to virginiamycin - the antimicrobial found in the only approved product currently recognized by the U.S. Food and Drug Administration for use by fuel ethanol producers in the United States.

The NGFA also strongly urged CFIA to revise its proposed policy to officially recognize fermentation microorganisms, enzymes and processing aids, which are approved by the FDA for use in producing human beverage alcohol, to also be acceptable for use by ethanol producers in the manufacture of distillers grain co-products. The CFIA proposed that such microorganisms, enzymes and processing aids be subjected to independent review and approval by a Canadian governmental body, such as Environment Canada, Health Canada or CFIA.

The NGFA urged CFIA to eliminate its proposal to require that labels of distillers grain products contain a maximum sulfur guarantee. The NGFA said the proposal would address just one potential ingredient, distillers grains products, in an animal's diet, and would not address the relevance for feed manufacturers as well as livestock and poultry feeders in determining the total dietary sulfur intake of an animal. Other feed ingredients, such as canola meal, typically have similar or greater sulfur content than distillers grains products, but are not subject to mandatory maximum sulfur guarantee labeling requirements by CFIA.

The NGFA also urged CFIA to remove references that DDG be labeled with guarantees for maximum moisture, sulfur, sodium and phosphorus. The NGFA maintained that such label guarantees are inappropriate for distillers grain co-products because they are not required for a variety of other feed ingredients that contain similar or greater concentrations of sodium or phosphorus. Association of American Feed Control Officials' model feed regulations and virtually all U.S. state feed laws require labels of distillers grains products to contain guarantees only for minimum crude protein, minimum crude fat and maximum crude fiber. Exceeding this requirement would require additional label guarantees for moisture, sodium and phosphorus solely for exported distillers grains products destined for Canada, thereby creating additional labeling costs and potential cross-border trade disruptions, according to the NGFA.


The NGFA's membership, which includes members from all sectors of the grain industry in the U.S., Canada and Mexico, use its Trade Rules and Arbitration System in their contracts. The NGFA also consists of 35 affiliated state and regional grain and feed associations, as well as two international affiliated associations.