FEDIAF Contribution to the Circular Economy Act Consultation

This system is one of Europe's most effective and mature examples of circularity: it keeps valuable bio-based materials in productive use, reduces waste, and contributes to food and feed security. To ensure the Circular Economy Act (CEA) delivers its objectives effectively, it must build on, not disrupt, such established highvalue circular systems.
 

The current focus of the Circular Economy Act is largely on waste and secondary raw materials. Yet circularity also depends on biological systems that already keep materials in productive loops. Category 3 ABPs are safe, high-quality, bio-based inputs that provide essential nutrients for pets, and their use in pet food represents a long-standing, regulated circular model.
 

While ABPs are often not the primary output of food production, it is important to clarify that they should not be mischaracterised as merely residual materials. In fact, ABPs are primarily materials produced for human consumption that, for various reasons, are not consumed by humans. Classifying ABPs as secondary materials can lead to misunderstandings and potential confusion with waste, which undermines their value in the circular economy. The CEA should explicitly recognise such systems as part of the EU's circular economy, embedding the cascading use principle to ensure nutrition and feed uses are prioritised before energy recovery.
 

For circularity to be effective, EU policies must be coherent. Today, incentives under the Renewable Energy Directive (RED) allow certain ABPs to be diverted into biofuel production, creating competition with the feed sector. Such diversion can lead to unintended leakage of critical nutrition into biofuels, undermining resource efficiency, feed security, and the cascading use principle. Providing resources for feeding is fundamental before any consideration for other purposes, e.g., energy.

The CEA should align with existing bioeconomy and renewable energy legislation to avoid duplication or regulatory overlap. Clear, consistent definitions of terms such as 'waste,' 'by-product,' and 'animal byproduct' will ensure legal certainty and encourage sustainable investment. The ABP regulatory framework provides a robust reference model, demonstrating how circular systems can operate safely and efficiently.

3. Safeguarding Feedstock Availability and Encouraging Responsible Innovation
Europe's feed and food security rely on stable access to high-quality raw materials. Policy-driven competition for ABPs, or incentives that prioritise energy over nutrition, risks disrupting these supply chains. Protecting the availability of Category 3 ABPs ensures continuity of feed supply, supports EU competitiveness, and strengthens SME resilience.

At the same time, the CEA should foster innovation responsibly. The pet food industry actively explores alternative proteins, including plant-based, insect, microbial, and fermentation-derived ingredients. To succeed, such innovations must be introduced through science-based regulatory pathways that guarantee safety, nutritional adequacy, and consumer acceptance, while complementing, not replacing, existing circular systems.

4. A Coherent, Integrated Approach to Circularity
The CEA should serve as a framework that bridges the circular economy, bioeconomy, and food systems. Biological materials have unique value and require tailored management: their highest value often lies in nutrition rather than energy recovery. Recognising the pet food sector's role demonstrates how circularity, sustainability, and food security can advance together.

By safeguarding existing loops, promoting responsible innovation, and aligning policies across sectors, the Circular Economy Act can strengthen Europe's resource efficiency, resilience, and competitiveness, delivering benefits for pets, people, and the planet.

Key Recommendations

To ensure the Circular Economy Act achieves its objectives while preserving essential bio-based systems, FEDIAF recommends that the Commission: