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Regal Reauthorisation of Amino Acids in Europe Ruud Bremmers, director of Regal B.V. [email protected]

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Page 1: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Reauthorisation of

Amino Acids

in Europe

Ruud Bremmers, director of Regal B.V.

[email protected]

Page 2: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Topics

Basic regulations registration

Required kind of information for a registration

Procedures

Status of amino acids

Examples threonine, tryptophan, lysine

Critical factors in registration

Costs for registration

Page 3: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Development issues of a new

product

Screening on possible effect/lab phase

Identity of the product

Test efficacy

animal phase

Safety

Production

New product

Page 4: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

European Union

Regulation (EC) No 1831/2003 of the

European Parliament and of the Council of

22 September 2003 on additives for use in

animal nutrition

Commission Regulation (EC) No. 429/2008

EFSA guidances

Page 5: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Re-evaluation of additives

Same regulations as for new authorisation!

Page 6: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Dossier

Identity

Safety

Efficacy

Page 7: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Identity of the additive

1. Identity of the additive

2. Characterisation of the active substance(s)

3. Manufacturing process

4. Physical-chemical and technological properties

5. Conditions of use

6. Methods of analyses

Page 8: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Safety: case by case

approach Of the additive for target species

Risks to the consumer

Risks to the user/worker

Risks to the environment

Page 9: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Efficacy

Studies?

– literature

– animal studies

Page 10: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Procedure

Page 11: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Procedure

Page 12: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Status amino acids

Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010

These products were subject to re-registration and can stay on the market until decision on authorisation is made

Products submitted after 2010 are considered “new” applications

Page 13: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Status amino acids

During the period of re-registration of a type of

amino acid, there is a general allowance to sell this

amino acid (not bound to the producing organims)

When all applications of a specific amino acid are

finished, the general allowance will finish and

only the authorisations of amino acids for which a

dossier was submitted may be marketed.

Page 14: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Status threonine

Applications done by Ajinomoto, Evonik, Meihua, Global BioChem, Star Lake, ADM, Zhejiang Guoguan, CJ, Evonik Degussa

EFSA has finalised opinions Sept 2015-May 2016, but not for all

EC authorised July 2016

Transitional measures

New applications pending

Page 15: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Status tryptophan Applications done by Ajinomoto, Meihua, Dear

Garden Biotech, CJ, Evonik. New applications by Global BioTech, Feedway

EFSA has finalised opinions on applications for re-evaluation 2014-March 2017

EC has authorised in May 2017 (not all)

Transitional measures

New applications pending

Page 16: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Status lysine Applications done by Global Biotech, Ajinomoto, Helm,

Meihua, Agroferm, ADM, SA Bioproducts, CJ, Evonik,

Paik Kwang, VitaLys

New application by Feedway

EFSA has finalised opinions on applications for re-

evaluation

EC has not authorised all lysine products under re-

authorisation, however individual products have been

approved

Page 17: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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What happens with the rest?

Generic or Authorisation holder?

Withdrawal from market

Transitional measures

Page 18: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Critical factors in amino acid

registration Micro-organism used in the fermentation to produce

the amino acid, ...

Does product contains fermentation residues or other impurities?

Details of the strain and method of manufacturing can be asked to keep confidential

Page 19: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Critical factors in amino acid

registration The strain that is used for fermentation?

QPS or not?

Purity ?

Sensitivity towards antibiotics?

GMO?

Page 20: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

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Critical factors in amino acid

registration In case of GMO:

Information on the genetic modification

Antibiotic resistance?

Plasmids?

Residues in the additive?

Page 21: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were

Regal

Costs for studies

Analyses on batches, impurities, product characteristics

Strain

Stability

Homogeneity

Strain

Costs: 30-60k€

EURL: 6 k€

Page 22: Reauthorisation of Amino Acids in Europe...Status amino acids Regulation 1831/2003 offered companies to submit dossiers for amino acids, before the end of 2010 These products were