Gatekeeping in the Feed Industry: EFISC-GTP Safety Rules

In the modern feed production chain, product safety depends on every link. However, situations arise when it is necessary to purchase raw materials from a supplier without a recognized safety certificate. For such cases, the international EFISC-GTP standard has developed a gatekeeping protocol—a system of strict incoming rules that allows for the safe integration of uncertified raw materials into the overall supply chain.
1. What is gatekeeping and why is it needed?
The main goal of EFISC-GTP certification is to ensure end-to-end feed safety, starting with the raw material processor. Gatekeeping is applied in exceptional cases where a supplier or part of the supply chain is not certified. This protocol obliges the buyer (the certified company) to assume full responsibility for auditing and verifying the safety of incoming materials.
The protocol clearly divides raw materials into several categories, each with its own rules:
• Unprocessed products: Grains, oilseeds, and legumes. • Processed feed materials: Products that have undergone physical or chemical processing (meals, bran, pulp, etc.), as well as by-products of the oil and fat industry: fatty acids, distillates, soapstocks – to which additional requirements may apply according to section 6.2.1.
• Palm oil: Crude, refined, and fractionated oil.
• Former food products: Products produced for human consumption but converted to feed for commercial or logistical reasons.
Compared to other mutually recognized certification schemes, the EFISC-GTP has no geographical restrictions, and depending on whether the company is registered as a food operator under the European Regulation, different recognition mechanisms exist. However, the Gatekeeping procedure does impose restrictions on certain products. For example, the purchase of uncertified grain from countries such as the Netherlands, Belgium, Germany, France, the United Kingdom, Canada, and several others is prohibited. For processed products, the list of restrictions is expanded by Pakistan (for molasses), Malaysia, and Indonesia (for palm kernel cake).
Safety is confirmed by a rigorous testing schedule. Key requirements include:
• Sampling Methods: Samples must be collected in accordance with GAFTA, FOSFA, or ISO standards.
• Inspector Qualifications: Sampling must be performed by an independent organization accredited to ISO 17020 or ISO 9001 (in conjunction with GAFTA approval).
• Mandatory Analysis Parameters: Each batch is tested for pesticides, heavy metals (arsenic, lead, mercury, cadmium), dioxins, and mycotoxins (aflatoxin B1, DON, zearalenone).
• Positive Release Principle: By-products of the oil and fat industry are subject to a "positive release" policy—the product cannot be used until a laboratory confirms its safety. Particular attention is paid to processed oil products. The regulation establishes a "negative list" of materials that are strictly prohibited from being used in feed:
• By-products of biodiesel production (e.g., MONG).
• Tank bottoms.
• Fats recovered from wastewater treatment systems.
• Animal fats (in the context of this plant-based protocol).
Companies using gatekeeping are required to:
1. Notify their certification body of the application of these regulations.
2. Conduct audits of suppliers of former food products (at least annually).
3. Report annually to EFISC-GTP, indicating the volumes of raw materials purchased, their origin, and the periods of gatekeeping application.
However, these regulations allow the use of uncertified suppliers without limiting the rights of other producers or having a point of sale that can be the first in the chain, assuming additional risks for the use of the product in the chain of certified producers, both under EFISC-GTP and other mutually recognized certification schemes.