Animal Feed Supplements


A Dispassionate Analysis
Like any product, animal feed supplements which are also called as Feed Additives, are governed by relevant rules of our country. Therefore, it is imperative that there should be clear understanding about them so that all Government authorities concerned, in different departments - be they are at the Centre or States - can interpret them correctly and treat them accordingly. This is more so, with Government of India signing the Agreement with World Trade Organisation - WTO - and adopting the Harmonised System of Nomenclature ( HSN ). Our Governments both at the Centre and in states will have to redraft the Customs, Excise, and Sales Tax rules, tariffs, schedules, and treat animal feed supplements / additives according to HSN rules, schedules and tariffs.

In this context, it is most pertinent to ponder over the recent landmark and unanimous decision of the extended 5-Judge Bench of Customs, Excise & Gold (Control) Appellate Tribunal ( CEGAT ). After studying judgements of different High Courts and even the Supreme Court of India, and after hearing for a week cases of eleven parties to the issue, the Hon'ble judges of CEGAT held that animal feed.
feed supplements must necessarily be classified in the same Chapter as other feed ingredients to manufacture high performing compound animal feed.
(Ref :MISC. ORDER No.248/98-C Dtd. 13.11.98).
CEGAT were fully convinced of the importance of " High Performing Compound Animal feed in optimizing animal productivity and enhancing the production of animal products. They admitted that Government had inadequate data and information on feed supplements which caused their inability to classify feed supplements and additives unambiguously for revenue purposes of Customs & Excise. They directed the files to the respective Benches for passing appropriate orders. This landmark decision should have finally settled this long drawn problem and for ever. But, unfortunately, it didn't.

Earlier, in response to CLFMA representation, even the Central Board of Excise and Customs (CBEC) had issued a Notification ( Circular No.188/22/96-CX ; File No.23/1/94-CX.I ) Dated 26th March, 1996 very clearly describing the Feed Supplements / Additives ; and categorically stating that they should be classified under Chapter 23.02 of CET corresponding to Heading 23.09 of HSN. However, CBEC verdict did not go far enough to remove the interpretationery discretion vested with Collectorates. This created a lacuna and provided a breeding ground for misinterpretation by different Collectorates; and the anomalies persisted.

That's not all. Lately, the Directorate General of Foreign Trade (DGFT) also clarified the issue vide their Policy Circular No.44 (RE-99)/1997-2002 Dtd.25.11.99.

With this, coupled with the landmark, unanimous and crystal clear decision of the 5-Judge Bench of CEGAT, all ambiguities are removed and the room for misinterpretation was sealed.
All Collectorates of Customs and Central Excise can now on assess and clear all feed supplements and additives uniformly under Chapter 23.
The big question, however is :
Whether they will do so? If so, how soon?

To understand Feed Supplements / Additives, their nature, use and role in animal husbandry promotion, we have to understand, first, the concept of nutritionally balanced animal feed, its safety and high quality / efficiency in optimizing the genetic potential of farm animals and maximizing their production. Considerable research into animal nutrition has helped us in identifying factors that perfectly balance the feed to be fed to animals for enabling them to perform at the highest level of output. Animal feed supplements, which are also called as animal feed additives or premixes enhance the quality of animal feed by balancing and enriching all required nutrients.

Animal Feed Supplements are a group of various organic and inorganic substances, and also chemicals and antibiotics, which when added, have been found to enhance the production potential and boost up the production by animals. Today, the feed supplements are playing such a vital role in the animal feed industry, that no balanced animal feed can be manufactured without proper supplementation of animal feeds, if the performance of the animal has to be enhanced.

Feed Supplements, Feed Premixes and Feed Additives, are all part and parcel of balanced animal feed with varying nomenclature. All these are complementary to each other, forming an inseparable and indispensable part of the complete feed that is well balanced in all required nutrients. The objective of all these commodities is also the same, viz. to enhance the productivity of producing animals.
India is endowed with rich natural seed resources of shrimps in the sea and vast stretch of coastal land for farming . Universal taste, High Unit value, Short duration of crop, Quick return on Investment, persistent demand and fast expanding world market are the major attraction to take up aquaculture in India.

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Feed Supplements
Presently , the following feed supplements are used exclusively in the manufacture of animal feeds :-
  1. Feed grade vitamin premixes
  2. Mineral mixes
  3. Feed grade amino acids / mixes
  4. Antibiotic feed supplements
  5. Pro-Biotics
  6. Enzyme preparations specific to animal feeding

  7. Anti-oxidants

  8. Mould inhibitors
  9. Taste enhancers

  10. Feed Flavours

  11. Coccidiostats

  12. Feed preservatives


The combination of the above substances also can be classified under Feed Supplements. These Feed Supplements can be mixed in feed & can also be offered through water. Their physical state could be in powder, pellet or liquid form.

Whereas it is theoretically adequate to feed animals, merely on fodder and other feed ingredients for sustenance, the intention of the animal husbandry, and therefore, of animal feed industry, is not merely to keep animals alive, but to make them highly productive. Thus, the argument that Feed Supplements / Additives are not essential in animal ration, does not stand to reason. This view had been vindicated even by law courts. Likewise, Animal Feed Supplements by themselves cannot keep the animal alive or sufficient to enhance production; they will have to be in combination with whole feed. This is how they are complementary to each other, and are a part and parcel of the end product -- complete animal feed. In other words, all of them are supplementary feeds.

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Guidelines for Legislation
Because of lack of consistency, different policy makers have been taking different views in legislating this commodity. Recently, the Government of India, adopted the World Trade Organisation (WTO) guidelines and introduced Harmonised System of Nomenclature (HSN), which is used by all member-countries of WTO. The HSN provides for comprehensive definitions of all major commodities. These guidelines should be utilized and followed by various authorities of Central Excise, State Excise, Customs, Sales Tax, Food & Drug Administration and all other Government agencies concerned, throughout India, uniformly.

HSN is the language of classification developed by Customs Co-operation Council (CCC), an arm of WTO based in Belgium. The objective of this CCC is to have uniform nomenclature for each commodity regardless of variable tariff nature from country to country. All member-countries have their representative at CCC.

According to HSN, these Supplements / Premixes / Additives are specifically prepared for use in animal feeding. They are not items of general use even though they may contain specific vitamins, minerals, amino acids, antibiotics, coccidiostats, or any other separately defined products. The main objective in making these premixes ( Feed Supplements / Additives ), is to ensure uniform distribution throughout the entire mass of animal feed so that the animal / bird eating such a feed, gets equal quantities of the supplementary feed also, besides the nutrients such as protein, energy and the like.

The key to understand therefore, is to demarcate the part played by CARRIER material, which is defined by HSN as any commodity which is used to make uniform dispersion of the active substance. It may be organic substance, such as Rice bran, Soya flour, wheat or maize middling, sucrose, etc., or inorganic substance like Calcium Carbonate, DCP, Kaolin, Bentonite, Silicates, etc. Once an active ingredient has been made into a premix along with CARRIER material, it loses its original identity, whether it be antibiotic, coccidiostats, amino acid, vitamin, mineral or any other Feed Supplement. It is then virtually impossible to separate the CARRIER from the mixed whole substance, and therefore, it can only be used in the animal feeding, performing the specific role of feed supplements.

The HSN Handbook clearly and unambiguously describes preparations for use in making the complete feeds or supplementary feeds. Accordingly, the Import Trade Control manual was proposed to be amended by our Government of India through the Export import Policy announcement on 31st March, 1999 ; effective 1st April, 1999. "Compounded animal feed" and "Concentrates for compounded animal feed" are proposed to be changed from 'Restricted' to 'Free' category. The unanimous, landmark decision of the extended 5-Judge Bench of CEGAT makes it amply clear that :

(1) Feed supplements / additives are absolutely necessary for making the complete feed "High performing compound animal feed"; and ;
(2) the "Government had inadequate data and information on feed supplements which caused their inability to classify feed supplements and additives unambiguously for revenue purpose of Customs and Excise".
The CEGAT had addressed their decision to both Customs and Central Excise.

However, the Drug Control authorities in India, have still been expressing doubts about the nature and use of Feed Supplements, since they contain either vitamins or antibiotics or other therapeutic substances. However, as long as the Feed supplements / Additives
/ Pre-mixes are routinely used for the enhancement of animal production do not conform to pharmacopoeia standards of purity,
and are administered at dosages substantially below therapeutic levels; they do not form part of therapeutic substances to be legislated as drugs under Drugs & Cosmetics Act. Only those substances used in high concentration, achieving therapeutic serum levels, and conforming to pharmacopoeia, warrant legislation under the Drugs & Cosmetics Act. NOWHERE IN THE WORLD ANIMAL FEED SUPPLEMENTS ARE COVERED UNDER THE DRUGS & COSMETICS ACT.

Considerable confusion exists under laws of various State Governments also vide their respective Sales Tax Act. Although most State Governments have rightly exempted or given concession to animal feed on Sales Tax, Purchase Tax, Entry Tax,. etc., they slap these levies heavily on feed supplements, which form an essential and inseparable part and parcel of balanced animal feed, and they must necessarily be in the complete feed. They are complementary to each other. Either of them cannot serve the objective independently. Productivity improvements for maximizing output
from farm animals and utilizing farm and agro-industrial residues,
are inevitable to Indian farmers. Feed Supplements must therefore
be considered by State Government authorities also, as an essential farm input, and not as an unnecessary luxury for the purpose of sales tax / or any other state legislation. Therefore, all State Governments should promote animal husbandry in their respective States by extending the same concession/ exemption to Feed Supplements also, as they have been doing or expected to do to animal feed, in the matter of all State levies; also in view that all these levies ultimately get reflected in the price of end-product i.e. nutritionally balanced animal feed, thereby pushing up the feed cost to farmers, and with chain reaction on prices of food products like milk, egg and meat; thus defeating the purpose of animal husbandry.


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Mis-use of levy concession offerred on feed supplements
It is possible that some unscrupulous traders and / or manufacturers may mis-use the definition of Animal Feed Supplements for taking undue advantage of the concessions / or exemptions given to feed supplements by our Central & State Governments. However, while this should not be allowed, it may not be prudent and practical to punish the entire industry and the whole of animal husbandry for the wrong doing by a few gullible. The miscreants can be, as they must be, brought to books by legislative measures with deterrent punishments. Therefore, supplements in as high concentration and purity standards as could be used for therapeutic use, should not qualify for the concession / exemption available for Feed Supplements. Based on the dosage recommendation and serum concentration achieved, such products should be specifically eliminated by attracting penal provisions of Drugs & Cosmetics Act.

The law and rules framed and enforced by the Governments - Central and /or States - should be such that they will spur the intended economic (production) activity and at the same time, inherently guard against any possible misuse. No policy / rule / law should, in effect, limit the progress and development of an industry merely for the reason of stopping on their tracks the outlaws who use them to their own advantage or benefit, at the cost of the Nation. The unscrupulous elements must be punished and the genuine ones encouraged. This principle could be adopted as a State Policy also or atleast in the case of Animal Feed Supplements vis-Ã-vis the legislation governing them.

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Description / Explanatory notes on animal feed supplements / additives, as stated in the handbook of harmonised system of nomenclature. (HSN)

23.09 PREPARATIONS OF A KIND USED IN ANIMAL FEEDING.

2309.10 Dog or cat food, put up for retail sale

2309.90 Other

This heading covers sweetened forage and prepared animal feeding stuffs consisting of a mixture, nutrients designed :

1) To provide the animal with a rational and balanced daily diet (complete feed);

2) To achieve a suitable daily diet by supplementing the basic farm-produced feed with organic or inorganic substances (supplementary feeds) ; or

3) For use in making complete or supplementary feeds.

The heading includes products of a kind used in animal feeding obtained by processing vegetable or animal materials to such an extent that they have lost the essential characteristics of the original material, for example, in the case of products obtained from vegetable materials, those which have been treated to such an extent that the characteristic cellular structure of the original vegetable material is no longer recognizable under a microscope.

(I) SWEETENED FORAGE

Sweetened forage is a mixture of molasses or other similar sweetening substances (generally more than 10% by weight), with one or more vital nutrients. It is used mainly for feeding cattle, sheep, horses or pigs.

Besides being highly nutritive, molasses enhances the palatability of foodstuffs and thus extends the use of products of low nutritive value such as straw, cereal husks, linseed flakes and fruit pomace which the animals, would otherwise be reluctant to accept.

As a rule, these sweetened preparations are fed directly to the animals. However, some of them combine molasses with highly nutritive feeds such as Wheat Bran, Palm Kernel or Copra Oilcake and are used to make complete feeds or supplementary feeds.

OTHER PREPARATIONS :
(II)
(A) PREPARATIONS DESIGNED TO PROVIDE THE ANIMAL WITH ALL THE NUTRITIVE ELEMENTS REQUIRED TO ENSURE A RATIONAL AND BALANCED DAILY DIET ( COMPLETE FEEDS ).

The characteristic feature of these preparations is that they contain products from each of the three groups of nutrients described below:

(1) " Energy " nutrients, consisting of high carbohydrate
(high caloric substances) such as Starch, Sugar, Cellulose and fats, which are "burned up" by the animal organism to produce the energy necessary for life and to attain the breeders' aims. Examples of such substances include cereals, half-sugar marigolds, tallow, straw.

(2) " Body-building ", protein-rich nutrients or minerals. Unlike energy nutrients, these nutrients are not "burned up" by the animal organism but contribute to the foundation of animal tissues and of the various animal products (Milk, Eggs, etc.). They consist mainly of proteins or minerals. Examples of the protein-rich substances used for this purpose are seeds of leguminous vegetables, brewing dregs, oilcake, dairy by-products.
The minerals serve mainly for building up bones and in the case of poultry, making egg shells. The most commonly used contain calcium, phosphorus, chlorine, sodium, potassium, iron, iodine etc.

(3) " Function " nutrients. These are substances which promote the assimilation of carbohydrates, proteins and minerals. They include vitamins, trace elements and antibiotics. Lack of deficiency of these nutrients usually causes disorders.
The above three groups of nutrients meet the full food requirements of animals. The mixing and proportions depend upon the animal production in view.


(B) PREPARATIONS FOR SUPPLEMENTING ( BALANCING ) FARM-PRODUCED FEED ( FEED SUPPLEMENTS )

Farm-produced feed is usually rather low in protein, minerals or vitamins. The preparations devised to compensate for these deficiencies, so as to ensure a well-balanced animal diet, consist of proteins, minerals or vitamins plus additional-energy feeds (Carbohydrates) which serve as a carrier for the other ingredients.

Although, qualitatively, these preparations have much the same composition , they are distinguished by a relatively high content of one particular nutrient.

This group includes :

(1) Fish or Marine mammal solubles, in Liquid or viscous solutions or in past or dried form, made by concentrating and stabilizing the residual water (containing Water-Soluble elements, viz. Proteins, Vitamins B, Salts, etc.), and derived from the manufacture of fish or marine mammal meal or oil.

(2) Whole green leaf protein concentrate and green fraction leaf protein concentrate obtained from Alfalfa (Lucerne) juice by heat treatment.

(C) PREPARATIONS FOR USE IN MAKING THE COMPLETE FEEDS OR SUPPLEMENTARY FEEDS.

These preparations, known in trade as "pre-mixes", are generally speaking compositions consisting of a number of substances (sometimes called additives) the nature and proportions of which vary according to the animal production. These substances are of three types:

1) Those which improve digestion and, more generally, ensure that the animal makes good use of the feeds and safeguard its health; vitamins or pro vitamins, amino acids, antibiotics, coccidiostats , trace elements, emulsifiers, flavourings, and appetizers, etc.

2) Those designed to preserve the feeding stuffs ( particularly the fatty components) until consumption by the animal by using stabilizers, anti-oxidants, etc.

3) Those which serve as carriers and which may consist either of one or more Organic nutritive substances (maize or Soya flour or meal middlings, yeast, various residues of the food industries, etc.) or of inorganic substances (eg. Magnesite, Chalk, Kaolin, Salt, Phosphates.)

The concentration of the substances described in (1) above and ;the nature of the carrier are determined so as to ensure, in particular, homogeneous dispersion and mixing of these substances in the compound feeds to which the preparations are added.

Provided they are of a kind used in animal feeding, this group also includes:

a) Preparations consisting of several mineral substances.
b) Preparations consisting of an active substance of the type described in :

(1) above with a carrier, for example, products of the authorities manufacturing process obtained by simply drying the mass, ie. the entire contents of the fermentation vessel (essentially) mycelium, the culture medium and the antibiotic).
The resulting dry substance, whether or not standardized by adding organic or inorganic substances, has an antibiotic content ranging generally between 8% and 16% and is used as basic material in preparing, in particular, "pre-mixes".

The preparations of this group should not, however, be confused with certain preparations for veterinary use. The latter are generally identifiable by the medicinal nature and much higher concentrates of the active substance, and are often put up in a Different way.


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Extracts from export policy 1992-97 aligned on ITC (HS) classification as amended on 31.03.1999, effective from 01.04.1999.

23.09 Preparations of a kind used in animal feeding.
230910 00 Dog or Cat food, put up for retail sale R
230990 00 Other
230990 01 Compound animal feed R
230990 02 Concentrates for compound animal feed R
230990 03 Feeds for fish ( prawn etc.) F
230990 03.10 Prawn, Shrimp and Poultry feed * F
230990 03. 20 Fish meal in powdered form F
230990 03. 90 Other F
230990 09 Others R


R means Restricted.
Not to be permitted except against a Licence
or in accordance with a Public Notice.
F means Free.

* Poultry feed was removed vide Union Budget for 2000-2001

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Government Circulars
GOVERNMENT OF INDIA
MINISTRY OF COMMERCE
DIRECTORATE GENERAL OF FOREIGN TRADE
UDYOG BHAVAN, New Delhi - 110 011



POLICY CIRCULAR NO.44 ( RE-99 )1997-2002
Dated 25.11.99

To
All Licensing Authorities
All Commissioners of Customs


Attention is invited to Policy Circular No.22 (RE-99)/1997 - 2002
Dated 27.7.99, regarding classification of animal feed supplements.

In this regard it is further clarified that ' Pre-mixes ' containing vitamins or pro-vitamins, Amino-Acids, coccidiostats etc. for use exclusively in animal feed as supplements continue to be classified under the Heading 23.09 as per Explanatory Notes to Harmonised Commodity Description and coding system.

This issues with approval of DGFT.


Sd/-
( O.P.HISARIA )
Deputy Director General of Foreign Trade.

(Issued from File No.01/89/180/00072/AM99/PCI-A)

Circular No.188/22/96-CX
F.No.23/1/94-CX.I
Government of India
Ministry of Finance
Department of Revenue
Central Board of Excise and Customs.

New Delhi, the 26th March, 1996

To
All Chief Commissioners, Central Excise / Customs
All Commissioners, Central Excise / Customs,
All Commissioners of Central Excise (Appeals)
All Commissioners of Central Excise (Judicial)


Subject:- Classification of Animal Feed Supplements under
Sub-heading No.23.02 or 29.36 or Chapter 30 -
Instructions - Regarding.
Sir,

It has been brought to the notice of the Board that a large number of products with different compositions are being cleared as 'Animal feed supplements' / Additives / Premixes etc. but are being classified either under heading 23.02 or heading 29.36 or under Chapter 30 of the Central Excise Tariff in various Commissionerates.

2. It would be recalled that in its Circular No.1/90 dated 1.1.1990, issued from F.No.15/20/89-Cx.I, Board had observed that animal feed supplements which are just inter-mixtures of vitamins only without other ingredients, except Solvents, Stabilizers or Anti-oxidants, cannot be classified under heading 23.02 even though they are used as animal feed supplements . Board had observed that such inter-mixture of vitamins are specifically covered under heading 29.36.

3. Trade interests have however represented that animal feed supplements use vitamins, pro-vitamins , amino acids, anti-biotics, 'Coccidiostats' etc. in very small quantities (micro quantities) and that the feed supplements contain other organic and inorganic feed ingredients as well. They have also represented that micro-nutrients do not have independent identity as pure chemicals, that they cannot be easily separated into individual pure chemicals; nor do they conform to standards laid down for medicaments. As such, it is claimed that animal feed supplements cannot be classified under Chapter 29 or Chapter 30 of the Central Excise Tariff merely because they contain the said micro-nutrients.

4. The matter has been further examined by the Board in consultation with the Chief Chemist, Central Revenue Chemical Laboratory (CRGL), New Delhi.

5. Heading 23.02 of Central Excise Tariff i.e. "Preparations of a kind; used in animal feeding including Dog and Cat food" corresponds to Heading 23.09 "Preparations of a kind used in animal feeding" of the HSN. As per Explanatory notes under Heading 23.,09 of the HSN, the said heading covers complete animal feeds, supplementary animal feeds and preparations for use in making the complete feeds or supplementary feeds. The preparations for use in making complete feeds or supplementary feeds are known in the trade as "Pre-mixes". These preparations are compound compositions consisting of a number of substances - each type of these substances being present in the 'premix' in varying propositions to serve a particular purpose. The explanatory notes under Heading 23.09 of HSN (pp.177-178) further indicates that pre-mixes contain, in addition to the active substances ( Vitamins, Amino-acids, Anti-biotics, Coccicodiastats etc.) and Stablizers, Anti-Oxidants etc. certain Organic or In-organic nutritive substances known as carriers which help in homogenous dispersion and mixing of the active substances in the compound feeds to which the preparations referred to in the said explanatory notes are added.

6. In this view of the matter, it would appear that preparations containing the active substances ( Vitamins or Pro-vitamins, Amino-acids, Antibiotics, Coccidiostats etc) along with the said carriers would fall under Heading 23.02 of the CET provided such preparations are of a kind used in animal feeding. It may however be noted that Heading 23.09 of the HSN excludes products to Chapter 29 and medicaments of heading 30.03 or 30.04. Hence, while deciding the classification of products claimed to be animal feed supplements, it may be necessary to ensure that the said animal feed supplements are ordinarily or commonly known in the trade as products for a specific use in animal feeding.

7. In view of the foregoing discussions, the classifications of each product being claimed as animal feed supplements may be decided on merits in the light of the above & in accordance with the explanatory notes to Heading 23.09 of the HSN read with Chapter Note I of Chapter 23 of the CET.

8. Board's Circular No.1/90 dated 1.1.1990 stand modified to the extent indicated above.

9. Field formations and trade interest may be informed suitably.

Please acknowledge receipt of this letter ( Hindi Versions will follow )

Yours faithfully,

Sd/-
(S.C.BHATIA)
UNDER SECRETARY TO THE GOVT. OF INDIA.

Summary Table on ANIMAL FEED SUPPLEMENTS

Animal Feed Supplements may be made up of different types of Vitamins, Minerals, Proteins, Enzymes, Extracts, Coccidiostats, Antibiotics, Pro-biotics and other ingredients, which are suitable to be mixed in water or feed as a supplementation to feed animals. These are essential for the maintenance, growth and productivity of cattle, poultry, and other food producing animals to provide complete, stable and balanced animal diet. These are given to animals by mixing in water or feed. The use of feed supplements in intensive animal production has a maximum effect, because a feed as optimal as possible is important and essential.


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Standards for Feed Supplements
Active ingredients of feed supplements are generally added in micrograms / Milligrams / grams per tonne of feed.

A concentration of an active ingredient above 16% is considered to be of having therapeutic value and anything below 16% having no medicinal / therapeutic influence. .

The most commonly used auxiliary material in animal feed supplements are Lactose, Calcium carbonate, Kaolin, Dextrose, DCP, Soya meal and any other suitable inert materials with biding property.

There is no known negative list of expedients banned for use in feed supplements that is currently used by manufacturers world over.

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Conditions Of Manufacturing

For all Nutritional Feed Supplements of Category 1, 2 & 3 the conditions are Same as applicable to the manufacture of Animal Feed.

The general guidelines for manufacturing of other Feed Supplements is given in Annexure : A.

ANNEXURE A
Note :- This annex applies to Animal Feed Supplements for prophylactic use other than Veterinary drugs which are at present covered under the Drugs & Cosmetics Rules.

Manufacture of Animal Feed Supplements.

Animal Feed Supplements may be made up of different types of Proteins, Enzymes, Extracts, Coccidiostats, Antibiotics, Probiotics and other ingredients, Which are suitable to be mixed in water or feed as a supplementation to the feed of animals. These are essential for the maintenance, growth and productivity of cattle, poultry and other food producing animals to provide complete, stable and balanced animal diet. These are given to animals by mixing in water or feed. The use of Feed Supplements in intensive animal
production has a maximum effect, because a feed as optimal as possible is important and essential.

A Pre-mix is a product prepared in advance with a view to the subsequent manufacture of animal feed supplement

I. Requirements of Factory Premises and Hygienic conditions for manufacture of Animal Feed Supplements.

1. The factory shall be situated in a place which shall not be adjacent to an open sewage drain, public lavatory or any factory producing disagreeable or obnoxious odor or fumes or smoke. The factory should be located in a sanitary place, remote from filthy surroundings and should also be subject to a regular pest control programme in view of use of large quantities of vegetable matter.

2. The walls of the rooms in which manufacturing operations are carried out shall upto a height of six feet from the floor, be smooth, water-proof and shall be capable of being kept clean. The flooring shall be smooth, even and washable and shall be such as not to permit retention or accumulation of dirt.

3. The water used in the manufacture shall be pure and of drinkable quality, free from pathogenic organisms. Adequate provision of good water for washing the premises shall be made.

4. In factories where operations involving the use of containers such as bottles, jars, etc. are conducted, there shall be adequate arrangements separated from the manufacturing operations for washing, cleaning and drying of containers with suitable equipment for the purpose.

5. Suitable arrangements shall be made for the disposal of waste water and other residues from the manufacturing premises in a manner as may not effect the health of the people in the area.

6. All workers employed in the factory shall be free from contagious or obnoxious disease. The workers shall wear clean aprons suitable for the nature of work and climate. Adequate facilities for personal cleanliness, such as clean towels, soap and nail scrubbing brushes shall be provided. Facilities for drinking water and washing premises shall be provided and such lavatories shall be located at places which are well away from the processing rooms.

II. Requirement of Plant and Equipment.

a. The following equipment is recommended for the manufacture of Premix ( Powders ).

1. Weighing Balances.
2. Mixer
3. Sifter
4. Suitable containers and Scoops
5. Filling equipment.

Workers should be provided with suitable masks during operation.

An area of 25 sq.meters is recommended for this basic installations.

b. The following equipment is recommended for the manufacture of Internal Oral liquid premix.

1. Mixing and Storage tank.
2. Portable mixer.
3. Filtering Equipment.
4. Suitable filling equipment

An area of 25 sq.meters is recommended for the basic installations.

III 1. Personnel
Each manufacturer should employ qualified personnel responsible for the manufacture and quality control of the feed supplement. Desired essential qualification is graduate in Chemistry, Pharmacy or Microbiology. Staff at all levels should be adequately trained for the tasks and responsibility assigned to them.

III 2. Storage
Adequate separate storage facility should be provided for raw material and finished Product.

IV. Testing

Adequate laboratory facility shall be provided for testing of raw materials and finished products

V. Documentation

1. Raw Materials
The manufacturer shall maintain record for all raw materials received and issued for manufacture.

2. Batch Manufacturing Records
The manufacturer shall maintain Batch Manufacturing Record for each batch of the feed supplement produced. Manufacturing records are required to provide a complete account of the manufacturing history of each batch.

3. Retention of Samples
It is recognized that because of the large volume of animal feed supplements it may not be feasible to retain samples from each batch in its final packaging.
However, manufacturer should ensure that sufficient representatives samples of Each batch are retained and stored.

4. Distribution Record
Record for distribution shall be maintained for distribution of finished batch of the product in order to facilitate prompt and complete recall of the batch if necessary.


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Conditions of Sale
All Animal Feed Supplements of Category 1, 2 & 3 to be sold and distributed directly to consumers or through all outlets dealing with farmers.

Advertising & Label Claim :
All Nutritional Feed Supplements of category 1 & 2 shall possess a label claim as under :-
" For growth, maintenance, productivity and performance "
" NOT FOR MEDICINAL USE - FOR USE IN ANIMALS ONLY "
Administration :
" Administer through Feed / Water "

For other Feed Supplements :
" FEED SUPPLEMENT FOR PROPHYLACTIC USE IN ANIMALS ONLY - NOT FOR HUMAN USE "

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