By Nelson Mandela Muhoozi
Stakeholders in the animal feeds industry have said the proposed Animal Feeds Bill, 2023, will put in place standards that will be able to compete both on a local, regional and international scene.
Aimable Mbarushimana, the Chairperson of Uganda Animal Feeds Manufacturers Association, said they welcome the Bill, and noted that it is intended to promote the production of safe and nutritious animal feeds, and to protect consumers from the dangers of contaminated or adulterated feeds.
“It will put in place standards that will regulate the operations and boost the industry’s competitiveness regionally and internationally,” he said.
He was speaking on Wednesday at Parliament during an interface with legislators on the Parliamentary committee of agriculture. The Committee is collecting opinions from various stakeholders on the Bill.
The committee sought the opinion of Uganda Animal Feeds Manufacturers Association, Uganda Law Reform Commission and Uganda Veterinary Association on the proposed Animal Feeds Bill.
Emmanuel Kaweesi, the legal officer at Uganda Law Reform Commission said the Bill is a good step towards improving the quality of animal feeds on the market.
He noted that since Uganda subscribes to International and regional obligations that include, among others, the Eastern Africa Livestock Feed and Feeding Strategy, World Organization for Animal Health, Uganda Food Nutrition Policy, it is undeniable that quality must be upheld.
“In terms of substance and purpose, the Bill will go a long way in promoting and professionalizing the animal feeds industry. If we are to achieve quality, we must ultimately leave manufacturing to those who can do it to the required standards. But if we allow everyone, we shall have an influx of substandard products on the market,” he said.
However, Kaweesi said that the Bill is restrictive noting that it leaves out aspects of animal feeding and concentrates on feeds leaving out the intended beneficiary which is the animal.
“If you legislate about feeds and don’t legislate about the feeding, you will have left out a critical element. We need to consolidate the aspects of animal feeding into the animal Feeds Bill, and call it The Anima Feeding Bill,” he said.
Much as the requirements in the Bill such as laboratory analysis, licencing, inspection of chambers, among others, are likely to increase the price of feeds, the stakeholders said it’s a price that Uganda must pay as she grows towards attainment of the middle-income status.
Expensive lab services
Manufacturers decried poor laboratory services from Government, alleging UNBS has disappointed them by failing to provide services on time.
Mbarushimana said the services are costly and take a lot of time. “We are struggling with availability of affordable laboratories. People mix their own feeds without knowing the exact composition for animals. So, there is need for labs to be placed across different regions to offer affordable laboratory services,” he said.
Animal feeds prices to increase
Mbarushimana said once passed into Law, the Bill will affect the prices of animal feeds since the Law will enforce packaging and labeling standards that will increase the cost of feeds.
“The dealers are going to be required to use special bags and labeling elements and this will lead to an increase in the production costs, prices and eliminate some players out of business,” he said.
He argued the Bill will favour international companies that are doing business in the industry since they already package and label their products, but also noted that quality cannot be compromised, and asked Government to create awareness on the Bill and rollout it out in Phases.
A sh4m fine or a two-year jail term, or both awaits animal feed dealer who will be found producing, importing, exporting, or selling animal feeds that contains contaminants beyond the recommended limits according to the Animal Feeds Bill 2023.
“A person who produces, imports, exports, or sells animal feeds that contains contaminants beyond the recommended limits, commits an offence and is liable on conviction to fine not exceeding two hundred currency points (one currency point is equivalent to sh20,000) or to a jail term not exceeding two years, or both,” Clause 15 subsection 3 of the Bill indicates.
In addition to the penalty in subsection 3, the Bill indicates that Court may order for the destruction of the animal feeds, at the expense of the producer, importer, exporter, or seller of the feed.
Clause 16 and subsection 3 of the Bill prohibits a person from producing, importing, exporting, selling or using animal feeds that contains prohibited substances.
Prohibited substances include gentian violet, propylene glycol in or on cat food, separated digestive tract content resulting from the emptying or removal of digestive tract, irrespective of any form of treatment or mixture, hide treated with tanning substances, including waste from the hide treated with tanning substances, among others.
Sand, stones, wood, including saw dust, wood shavings or other materials derived from wood, domestic and industrial waste water irrespective of any further processing of such waste water, and human drugs are also prohibited.
A person who produces, imports, exports, sells or uses animal feeds that contains prohibited substances commits an offence and is liable, on conviction, to fine not exceeding two hundred and fifty currency points (sh5m) or to a jail term not exceeding five years, or both.
Further, clause 17 and subsection 1 of the Bill indicates that a person shall not import or produce locally, animal feeds which contains veterinary drugs or hormones, without the approval of the National Drugs Authority.
A person who imports or produces locally, animal feeds which contains veterinary drugs or hormones contrary to this section commits an offence and is liable on conviction to a fine not exceeding two hundred currency points (sh4m) or to a term of imprisonment not exceeding one year, or both.
Recommendations on the Bill
The MPs said that although there are some people that adulterate feeds to make more profits by adding non nutritious and hazardous elements like soil and stones, there are substances that are stone elements but good the animals like Poultry.
The Acting President of Uganda Veterinary Association, Dr. Ben Ssenkeera, recommended that the list of contaminants in the animal feeds should be broadly defined to include physical, chemical and biological substances whose levels must be within the recommended limits by Uganda National Bureau of Standards.
He also said that the Government must establish an independent laboratory for quality assurance and control of animal feeds on the market.
Makerere University also yesterday submitted its list of recommendations to the Parliamentary Committee of Agriculture on the Bill.
The University’s proposals include a call for stating the minimum standards of feed quality control laboratories and nutrient analyses they conduct and having proof of access to a feed quality control laboratory with potential to analyze dry matter, ash, crude fat, crude protein, among others.
The institution also recommended that a person who intends to import, export or sell animal feeds should do so in packages that are labeled with the feed ingredients used to formulate the compound feed and proximate analysis compositions.
Makerere University’s response to the proposed Animal Feeds Bill, 2023, was presented by Dr. Kanifa Kamatara, Associate Professor Donald Kugonza and Dr. Sadat Walusimbi from the college of agriculture and environmental sciences, school of agriculture sciences.
Dr. Kamatara said there is need to have a clause in the Bill that differentiates commercial feed manufacturers, feed mixers and ingredient dealers, hence have different licences.
She suggested adding a clause that addresses non compounded feeds such as hay and silage, and another on storage premises since the Bill talks about regulating production, transportation and selling of animal feeds.
However, she said that some clauses in the Bill are vaguely and insufficiently defined. Kamatara said the definition of the term ‘Animal Feed’ in the Bill is insufficient, arguing that animal feed means any compound or mixed feed, manufactured feeds and the ingredients that make that feed whether derived from plant or animal origin.
According to her, the term ‘produce’ in the Bill is also misleading. The institution recommends that ‘produce should be replaced with ‘manufacture, formulate and mix’.
Although clause 15 (2) of the Bill indicates that contaminants Contained in the animal feeds that are produced, imported, exported or sold shall be within the limits recommended by Uganda National Bureau of Standards, Kamatara says the list of contaminants is not inclusive.
She also said physical contaminants should be included on the list of contaminants as these have been neglected.
Analysis in the Bill indicates that the productivity of livestock in Uganda is low due to the prevalence of among others, animal diseases, inadequate nutrition for the animals especially the low legume and protein content.
Animal feeds account for 70% of the production costs and therefore have a significant effect on the production costs and the profits.
The Animal Feeds Bill, 2023, is therefore a proposed law that aims to regulate the manufacture, importation, sale, and use of animal feeds in Uganda.
The bill is intended to promote the production of safe and nutritious animal feeds, and to protect consumers from the dangers of contaminated or adulterated feeds while boosting the industry’s competitiveness regionally and internationally.