Safeguarding Circularity: European Pet Food Industry Calls for Coherent EU Bioeconomy Policies  

The paper, Towards a coherent EU Bioeconomy: Safeguarding Sustainable Access to Category 3 Animal By-Products for Pet Food, highlights growing competition for these limited resources as demand from subsidised biofuels and biogas production increases under EU renewable energy policies.
 

Category 3 ABPs—safe materials not consumed by humans but suitable for animal nutrition—are a cornerstone of the circular economy. The European pet food sector transforms these resources into nutritious products for around 300 million companion animals across Europe while supporting the rendering industry and reducing food waste.
 

However, policy incentives linked to renewable energy frameworks are increasingly directing these materials toward energy recovery. According to FEDIAF, this risks undermining both circularity and the efficient use of biomass.
 

'Category 3 animal by-products are a finite resource and play a critical role in pet nutrition and animal welfare,' said Franco Garbelotto, Deputy Secretary General of FEDIAF. 'EU policies should ensure that these valuable materials remain available for their highest-value uses within the feed chain before being directed to energy applications.'
 

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The position paper warns that diverting feed-grade animal fats and other ABPs toward energy may create unintended consequences. If these ingredients become less available, pet food manufacturers could be forced to rely more heavily on alternative raw materials with potentially higher environmental footprints and greater dependency on imports.
 

FEDIAF therefore calls on EU policymakers to reinforce the cascading use principle, ensuring biological resources are used where they generate the greatest societal and environmental value. The association also stresses the importance of aligning renewable energy incentives with broader EU objectives on circularity, food security and sustainable resource management.
 

The publication comes at a critical moment for EU policymaking. Several forthcoming initiatives—including discussions around the EU Bioeconomy Strategy, the development of a Circular Economy Act, and the ongoing implementation and future review of renewable energy frameworks such as the Renewable Energy Directive and sectoral fuel regulations—will shape how biomass resources are prioritised across Europe's economy.
 

FEDIAF believes these policy processes offer an opportunity to ensure greater coherence between energy, agricultural and food-chain legislation. The association proposes measures such as improved monitoring of biomass flows, more transparent traceability of ABP use, and balanced incentive structures that avoid subsidising the use of feed-grade materials for energy.
 

'The pet food industry is a reliable partner in Europe's circular bioeconomy,' Garbelotto added. 'With coherent policies and transparent data, Europe can simultaneously support climate ambitions, safeguard feed and food security, and strengthen the competitiveness of its bio-based industries.'
 

FEDIAF stands ready to work with EU institutions, Member States and stakeholders across the value chain to ensure biological resources are used efficiently and sustainably as Europe advances its climate and circular economy goals.

Source: FEDIAF