AAFCO’s Hurry-Up-and-Wait Approach for Approval of Hemp as Animal Feed
By Eric Singular, Director, Hemp Business Journal
Despite hemp grain and its byproducts having well-documented nutritional value and the U.S. Food and Drug Administration (FDA) granting each hulled hemp seed, hemp seed protein powder, and hemp seed oil with “Generally Recognized As Safe” status back in 2018, the ingredients remain strictly prohibited for use as animal feed. Last February, the Hemp Feed Coalition (HFC) completed its first submission for hemp to become an approved animal-feed ingredient for review under the Association of American Feed Control Officials (AAFCO) and the FDA’s Center for Veterinary Medicine – a process that could take anywhere from 18 months to four years.
Despite the U.S. hemp industry’s touting progress on that front, momentum faltered last week when AAFCO published a position paper urging stakeholders to advocate and sponsor thorough scientific research to ensure the safety and nutritional benefits of hemp ingredients used in animal food before engaging the existing channels, regulatory agencies, and American livestock organizations for stakeholders to cooperate with in getting ingredients formally approved. As AAFCO notes, “rather than unilaterally approving the use of hemp as a feed ingredient… advocates should support continued research and development, and promptly submit applications to AAFCO and the FDA for review and approval on a national level.” Reading between the lines, available research on hemp as a feed ingredient leaves concerns on the table for AAFCO.
The announcement served to remind any farmer, rancher, or other stakeholder currently feeding hemp to livestock that they are violating federal laws and warned that approving hemp could hinder access to international markets for the U.S. ranching and dairy industries. According to the 2018 Farm Bill, any feed ingredient derived from industrial hemp ultimately falls under the jurisdiction of the FDA; per its position on CBD, more research is needed.
Though Montana state officials asserted state-level approval of hemp as animal feed, AAFCO stands firm in its warning against similar strategies. Like other sectors of the U.S. hemp market having developed without federal regulatory oversight, reconciling a patchwork of state hemp pilot programs causes issues for growers and operators. In lieu of federal approval and standards, risks concomitant to inconsistent manufacturing guidelines, unsupported marketing claims, or restrictions of interstate and international markets greatly increase.
Rather than adopt a state-by-state approach, AAFCO offers that by working in lockstep with university researchers, the FDA’s Center for Veterinary Medicine, the National Association of State Departments of Agriculture, livestock and dairy associations, and consumer advocacy groups, the odds of hemp’s gaining approval through the established processes of review will be strengthened.
As spearheaded by the HFC, several universities nationwide are studying the safety and efficacy of hemp and its byproducts. In August 2020, HFC earned an Agricultural Products Utilization Commission grant from the North Dakota Department of Agriculture to help fund a study of hempseed cake and meal in chicken feed. Likewise, researchers from Kansas State University were awarded a $200,000 federal USDA grant to study cannabinoid transference in the meat, milk, and eggs of hemp-fed animal byproducts in cattle feed. In March, the USDA’s National Institute of Food and Agriculture (NIFA) granted nearly $300,000 to Oregon State University for research into feeding spent hemp biomass to cattle. In addition to those, Colorado State University is studying hemp seed meal for lambs, Tuskegee University is studying the impact of hemp seed meal on goats, and North Carolina State University is studying the effect of hemp seed oil on horses.
Hemp industry stakeholders are banking on the approval of hemp grain ingredients. A 2019 Farm Journal survey of 950 U.S. farmers and ranchers found 60% of respondents agreeing that farmers should grow hemp for animal feed, while 48% agreed that they would use hemp for animal feed themselves. Approval of hemp for the animal feed market would greatly broaden the total addressable market for hemp producers. The American Feed Industry Association reports there being more than 5,800 animal food manufacturing facilities in the U.S. producing more than 284 million tons of finished feed and pet food each year. The domestic animal feed industry meanwhile supports over 944,000 jobs, ranking it among the largest economic contributors to the U.S. agricultural sector.
In addition to having the world’s largest fed-cattle industry, the U.S. is also the world’s largest consumer of beef—primarily high-value, grain-fed beef. In 2019, the Institute for Feed Education and Research (IFEEDER) found that major species of livestock, poultry, aquaculture, and pets in the United States consumed approximately 284 million tons of feed, with a value of $59.9 billion. Beef cattle consumed 64.5 million tons of feed, hogs consumed 61.8 million tons, and broiler chickens consumed 60.8 million tons, respectively.
The current animal feed market is dominated by corn, grain sorghum, barley, oats, rye, millet, hay, and dried distillers grains (DDG). While price is paramount when choosing a feed grain, finishing and healthy animal growth is greatly affected by protein quantity and quality. In 2016, corn accounted for more than half of the total amount of animal food consumed, with soybean meal and DDGs representing another 25%.
The key players operating in the global animal feed market – e.g., Archer Daniels Midland Co., Cargill Inc., Land O’Lakes, and Perdue Farms – would be quick to capitalize on new feed grain, especially given some soaring prices for other agricultural commodities. According to the National Industrial Hemp Council, a leading U.S. poultry provider was recently forced to secure more than 30,000 metric tons of soybeans from Brazil for livestock feed.
Outside of the U.S., conditions are mixed. In Canada, hemp products are not approved as livestock feed ingredients. However, several scientific articles published by European researchers have documented the safety and nutritional benefits of hemp ingredients used in animal food. In August, researchers at Australia’s Charles Sturt University announced their investigation of industrial hemp as feed for cattle and sheep.
The relative price and robust nutritional profile of hemp grain make it an increasingly cost-competitive commodity. Nevertheless, with years of research still potentially required before moving the needle forward for FDA-CVM’s approval, a lucrative end market remains off-limits.