New Definition for T3.1 Suncured Alfalfa Meal, or Pellets, or Ground Alfalfa Hay
AAFCO Ingredient Definition Committee and AAFCO Board of Directors passed T3.1 Suncured Alfalfa Meal, or Pellets or Ground Alfalfa Hay.At the August 5, 2019, Annual AAFCO Meeting, AAFCO Board of Directors accepted the recommendation from the Ingredient Definition Committee to establish and publish in the AAFCO Official Publication a new definition regarding the term “Suncured”.
The Definition is:T3.1 Suncured Alfalfa Meal, or Pellets, or Ground Alfalfa Hay: is the aerial portion of the alfalfa plant, reasonably free of other crop plants, weeds, and mold, which has been dried by solar means, stored as bales or stacks, and finely or coarsely ground. If it is chopped instead of ground, it must be designated as “Suncured Chopped Alfalfa” or “Chopped Alfalfa Hay”. If the ingredient is further dehydrated by thermal means after being ground, it must be designated as “Dehydrated Suncured Alfalfa Meal, or Pellets”
Before the new definition (prior to August 2019):
Dehydrated Alfalfa (Dehy - 3.2) as currently sold in the marketplace, may contain alfalfa that was ground and previously stored as bales [or stacks]. Based on def 3.1 (Suncured Alfalfa), this means that Dehy (3.2) actively bought and sold, could contain Suncured alfalfa (3.1). Thus, a new definition should modify 3.1, such that any Dehy (3.2) that contains alfalfa that was stored as bales (3.1) should be designated as Dehydrated Suncured Alfalfa Meal, or pellets (3.1).
Differences in viewpoint around the newly adopted definition have existed for several years. The main disagreement is that the definition centers on changes of storage requirements (baling or stacking) which are irrelevant to the quality and nutritional value of processed alfalfa. Moreover, almost all alfalfa traded in the United States is in bale form and many alfalfa dehydrators suggest deleting storage requirements in T3.1 as they don't contribute to quality and nutritional value which are the most important feed attributes for our animals.
This industry viewpoint about the language requirement of baling or stacking exists because stacking is no longer a common industry practice. Moreover, neither baling or stacking effects important and measurable product quality attributes, such as moisture uniformity and resulting product stability achieved by the act of thermal dehydration.
Fears of the new definition are that:
- It implies that the newly defined product is less moisture stable, despite having been thermally dried in its entirety, simply because it may have been previously stored in bales or stacks.
- Adds confusion to the definitions. Dehydrated Suncured Alfalfa is an oxymoron; and
- Changes the perceived supply of Dehydrated Alfalfa (3.2) for consumers who currently shop for this defined product.
Nebraska Grain and Feed Association reached out in July 2019 to Nebraska's alfalfa industry, feed manufacturers, and pet food manufacturers regarding the definition T3.1 proposal to provide feedback to our Nebraska Department of Agriculture officials who are voting members of AAFCO and can provide our state's feedback and input on proposals.
Engage on Feed IssuesIt's important for the industry to be an active participant in definitions and feed manufacturing regulations if you have a proposal, question, or input on a subject under AAFCO purview reach out to the NEGFA office and we will make sure it is communicated to the individuals who need to hear it and are representing our state.
AAFCO Definition Process Documentation:April 4, 2019 Ingredient Definition Committee Meeting Minutes https://www.aafco.org/Portals/0/SiteContent/Regulatory/Committees/Ingredient-Definitions/Minutes/Ingredient_Definitions_Minutes_2019_eMeeting.pdf
August 5, 2019 - Annual Business Meeting Minutes https://www.aafco.org/Portals/0/SiteContent/Meetings/Association-Business/General_Session_Minutes_2019_Louisville_KY.pdf