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AFIA: Take action now on 16-4 updates before African swine fever

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Certificate required to export animal-based products and would be invalid if ASF present, regardless if product has porcine or other animal-derived ingredients.

When it comes to African swine fever (ASF), most of the dialogue across the U.S. swine and feed industries has been about prevention and domestic impact. One area not getting as much attention that needs to is U.S. animal food exports, according to Gina Tumbarello, American Feed Industry Association senior director of international policy and trade.

“A lot of people do not know that animal-based feed products-- almost all of them-- are exported on a veterinary health certificate called 16-4,” explains Tumbarello. “It says that the U.S. is free of a number of animal diseases, including African swine fever, so if we were to have an outbreak tomorrow, this statement would no longer be valid. The U.S would not be able to attest to this statement and this certificate is required in order to export animal-based product.”

However, Tumbarello says feed manufacturers might not realize that if an outbreak were to occurr, this certificate would then be invalid, regardless of whether the product contains porcine ingredients, or any other animal-derived product.

“It doesn't matter. The language is the same. It's hard to estimate how much product we're exporting that has animal-based product in it, but if we just stick to these core categories, we're talking about almost $2.5 billion for product. It would immediately stop because of this health certificate.”

In 2020, the U.S. exported more than $1.7 billion in dog and cat food, $37 million in feather meal, $180 million in fishmeal and $537 million in meat and bone meal.

The health certificate is also negotiated by the U.S. government with foreign regulators, for specific products for each country. Almost all of them, Tumbarello says, require the certificate as it ties with the agreed-upon negotiated protocol. It’s not something that feed exporters can stop using.

Another scenario many feed industry members may not consider is if they supply a non-animal origin product to a feed manufacturer and that manufacturer exports, she explains.

“You may be supplying a manufacturer with an ingredient that has no animal-origin ingredients in it, but the customer that you're supplying to exports. It may not have as much of a demand for your product, if they can't export it. Say 60% of the product out of their facilities exports and you supply your ingredients to that facility, that changes the demand situation.”

According to Tumbarello, AFIA has been working for several years with the U.S. government to address this situation and amend the 16-4 document, and the government has now received the regulatory authorization to amend it. She says there are a few different ways the document could be updated:

  1. Remove all reportable diseases. All of the animal diseases on the 16-4 are already OIE reportable diseases.
  2. Revise and remove ASF language.
  3. Revise for two versions-- porcine ingredients and non-porcine ingredients.

Even if one of these recommendations is chosen, Tumbarello says the veterinary certificate will still need to be negotiated with every trading partner for every product that is tied to a 16-4. Currently, the only country the U.S. has successfully negotiated with is Canada.

“That means that we could potentially open up that whole agreement that we have with them, and it can open up more than just changing that health certificate. They might not want to change some of the requirements per the product we sent them. That's bigger than just changing a document. Maybe they've been looking for an opportunity or a reason to update the negotiated protocol, and this now has just presented a perfect opportunity.”

Tumbarello stresses the issue should be addressed now, when there is time to communicate.

“Do we address it now when we have time to communicate and we're not under the gun, or do we wait until after the fact, and now we're running around because we have African swine fever?"

She said the feed industry is already trying to keep ASF from spreading, trying to protect the pork industry and trying to protect domestic movement of product. "Then we're going to add on top of that trying to renegotiate with a bunch of countries for a number of products all at the same time.”

As the U.S. government facilitates these trade negotiation discussions, she says AFIA and the industry can help prepare them by informing them about the products, the safety of them, and easing any concerns that trading partners might have in such a discussion about changing a 16-4.

In the meantime, Tumbarello encourages feed industry members to spread the word and educate each other about this issue.

“What does it mean to your company, to your suppliers, to your customers, to your facilities, to your employers, if a good chunk of your facility exports and your exports shut down, and we don't know how long it's going to shut down. What happens to that facility? Where does that product go? What do you do?” 

More people need to know and have perspective on what's happening with the potential risk, including understanding the money that's involved, the loss of business, and how it could affect the economy and employees, Tumbarello says.

 

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