New Regulatory Committee
Considering the dynamic road ahead with regard to the new proposed feeds legislation, AFMA has made a strategic decision to revise and restructure its ad hoc Legislative Committee into a full-time Regulatory Committee (RC). The RC held its first meeting on 13 February 2018 and has accepted the revised committee scope and agenda. The new agenda will provide feedback to members on quarterly and/or bimonthly liaison activities between AFMA and the Department of Agriculture, Forestry and Fisheries (DAFF) – and more particularly the Inspection Services (ICF), the Directorate of Animal Health and Veterinary Public Health (FSF) and the Directorate of Agricultural Inputs Control (AFF). A status update will also be provided on feed and ingredient registrations at DAFF and all matters related thereto. Standing agenda items will include updates on the Feeds and Pet Food Bill, related regulations, standards and guidelines, as well as import and export related matters. Each AFMA member has a representative on the RC, who will receive all relevant notifications and documentation to ensure that all members are kept well informed during these changing times. Mr Mark Manley from Sovereign Foods was elected as the chairperson and will guide the AFMA RC in its endeavours during the coming year.
Three new technical advisors have joined the Act 36 technical assessment team in September 2017 and have been on a steep learning curve the past seven months. The current volume of applications submitted for registration, however, still outweighs the capacity and efficiency of the approval system, with approximately 850 outstanding registrations at present. Renewed focus will be given to outstanding new registration applications versus amendments to improve the service delivery to the feed industry and support new business development. The lead time for new registrations is eight months (currently assessing applications submitted in November 2017) and two months for amendments (currently assessing applications submitted in March 2018).
Feeds and Pet Food Bill
The Feeds and Pet Food Bill was drafted last year, and the principles thereof were workshopped with AFMA members and other key stakeholders in October. Since then, the Registrar has been compiling two Socio-economic Impact Assessment (SEIAS) reports for the Department of Planning, Monitoring and Evaluation (DPME) to motivate the reasons for new legislation and to illustrate the intended and unintended consequences of the Feeds and Pet Food Bill. The requirement for the SEIAS reports to be submitted with all new proposed legislations is relatively new, which is indicative of Cabinet’s focus to ensure that government departments can prove that a new law is needed, that it can be implemented and that it does not negatively affect Small, Medium and Micro-sized Enterprises (SMMEs), farmers and competition. On acceptance of the SEIAS reports, a certificate will be issued and submitted in conjunction with the Bill to Cabinet for approval, scheduling and publication.
AFMA considers formal complaint against Foskor
AFMA is currently in discussion with its legal team on competition legislation and considering laying an official complaint at the SA Competition Commission against the State-Owned Enterprise – Foskor, on the merit of its monopolistic misuse of its position in the market as only supplier of phosphoric acid used in the production processes of fertiliser and critical products used in the manufacturing of animal feed, such as monocalcium phosphate (MCP), specifically used in poultry rearing.