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AAFCO Release on Hemp as Animal Feed (Sept 2021)

Updated: Dec 19, 2021

AAFCO recently released a statement on hemp as animal feed, as well as an updated policy. The official release and updated policy are linked below.

A few key highlights from the Updated Policy (9-13-21):

  • AAFCO’s update is an “industrywide call to action”

  • Acknowledges that legislators are being “lobbied to consider legislation allowing the use of hemp in feed ingredients”

  • AAFCO does not want to see unilateral approval of the use of hemp as a feed ingredient

  • AAFCO is concerned about “serious adverse effects”:

    • Can hemp be safely fed to all animal species?

    • Concern about the “transfer rate of THC, CBD, and other cannabinoids into meat, milk, and eggs” and any residual levels

  • Feed in interstate commerce is regulated federally and currently is federally illegal, but that “all regulatory barriers can be addressed through the pursuit of AAFCO ingredient definitions for hemp and hemp byproducts desired for use in animal food.”

  • Concern of creating trade barriers

  • Overall- more research is needed and AAFCO strongly encourages applications for ingredient definitions

  • Call to Action:

    • Calling on industry to bring forth information for scientific review to est. definitions and to address the safety of target animals and resultant human food.

    • AAFCO expects to see ingredients like hemp seed oil, hemp seed meal, and whole hemp seeds.

    • “Instead of supporting legal or administrative changes at the state level”- Encourages lawmakers to work on AAFCO ingredient definitions

    • “encourages lawmakers to work with key stakeholders, such as FDA, USDA, National Association of State Departments of Agriculture, livestock and dairy associations, consumer advocacy groups, and AAFCO to develop a path forward in which hemp byproducts can be legally approved and used.”

A few key highlights from the AAFCO Release (9-20-21):

  • AAFCO “encourage the hemp and feed industries to continue researching the proposed hemp and hemp byproducts as nutritional ingredients to gather data on the products’ safety and efficacy.

  • “[P]roducts to be evaluated include whole hemp plants, hemp seed oil, CBD, and other cannabinoids”

  • Concern not enough research done and to follow normal steps of the ingredient approval process

  • It’s unknown if hemp can safely be fed to all animal species

  • Research needed to address THC levels in hemp and effects it has on intended uses and species

  • Approval before thorough research is completed could have adverse impacts on “ranchers’ access to markets, on animal health, and ultimately on human health when hemp-fed animal products enter the human food chain”

  • Concern about state-by-state patchwork:

    • AAFCO is concerned that bringing hemp products to market through a state-by-state patchwork of laws, without the backing of in-depth research and a formal review process, will lead to inconsistent manufacturing methods, unsupported marketing claims across the country, and restriction of interstate and international markets.”

  • Encourages Lawmakers to work with stakeholders, FDA, USDA, NASDA, livestock & dairy associations, consumer advocacy groups and AAFCO to expedite formal review and approval of hemp byproducts for animal nutrition.

  • AAFCO will help guide hemp producers through submission and review process

The Hemp Feed Coalition (HFC) replied to AAFCO’s release, stating:

  • “The vision of the Hemp Feed Coalition is to grow hemp producers and processors and

gain access to the billion-dollar animal feed and supplements market, completing a local supply

chain from farmer to feeder. Our mission is to gain Federal approval for hemp and its byproducts

as animal feed ingredients.”

  • “HFC is committed to continuing to work closely with Association of American Feed

Control Officials (AAFCO) and the FDA-CVM and has used some of the most experienced,

technical, and scientific advisors in the industry, including many university researchers, to

provide compelling and credible evidence that hemp and its by-products are safe and nutritious.”

  • “While we will continue to work closely with AAFCO and

respect their position on evaluating the many technical concerns about using hemp as a feed

product, we also appreciate the needs of farmers and ranchers who are not only looking to create more value for their crops but are also anxious for feed alternatives in this time of record-

breaking feed costs, shortages, and other critical supply chain issues.”

  • “HFC is looking forward to a continued collaborative effort with AAFCO and are confident they will continue to urge regulators to evaluate hemp ingredients on a level playing field like any other animal feed ingredient.”

  • “If federal and state regulators want to encourage the industry to maintain the established pathways for approval, then more funding and research opportunities are needed along with timely review of the information submitted when following the established approval pathways.”

Full response here

To contribute to our Animal Feed Campaign to advance federal policy and open the market for hemp as an approved ingredient, please donate here.

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