1. Introduction
The use of meat and bone meal for poultry feed in Europe entered a new regulatory chapter in September 2021. Commission Regulation (EU) 2021/1372 reinstated the use of porcine and bovine-derived processed animal proteins — including MBM — in poultry compound feed for the first time since the BSE crisis imposed a blanket ban across all mammalian-derived rendered proteins in 2001. For compound feed producers who had not used this ingredient in over two decades, the derogation opens a genuine cost optimisation opportunity — but one that comes with specific operational, documentation, and supplier qualification requirements that must be in place before the first batch is sourced.
This article covers what the 2021 derogation permits, what it does not permit, what the operational conditions are for using meat and bone meal for poultry feed compliantly, and how to qualify a supplier capable of meeting those conditions.
2. Historical Context: Why MBM for Poultry Was Banned and What Changed
The use of mammalian-derived processed animal proteins in poultry feed was prohibited across the EU from 2001 under Regulation (EC) No. 999/2001 — the TSE regulation introduced in response to the BSE crisis. The ban was precautionary in nature: at the time of its introduction, the science on TSE transmission pathways across non-ruminant species was insufficiently settled to distinguish between risk levels across different PAP types and target species. The entire mammalian PAP category was removed from non-ruminant feed as a single precautionary measure.
For twenty years, the European poultry compound feed industry operated without access to mammalian-derived meat and bone meal for poultry as a protein source. Soy protein concentrate and other plant-based proteins filled the protein gap, with poultry meal — derived from poultry slaughter by-products — remaining the primary animal protein permitted in poultry feed throughout this period.
The 2021 derogation followed a comprehensive scientific risk assessment by EFSA — the European Food Safety Authority — which concluded that non-ruminant processed animal proteins, including porcine and bovine MBM, do not pose a TSE transmission risk when used in poultry and pig feed under controlled conditions. Commission Regulation (EU) 2021/1372, in force from 1 September 2021, reinstated porcine-derived PAPs in poultry feed and bovine-derived PAPs in both pig and poultry feed, subject to species segregation and dedicated processing line requirements. Two elements of the prior restriction remain fully in force: the ruminant feed ban — no mammalian-derived PAP in cattle, sheep, or goat feed — and the intra-species recycling ban — no poultry-derived PAP in poultry feed.
3. Which MBM Types Are Permitted for Poultry Feed?
Not all MBM is eligible for use in poultry feed under the 2021 derogation. The derogation is species-specific, and the compliance matrix determines which MBM types a compound feed producer can legally incorporate in a poultry formulation.
| MBM Type | Permitted in Poultry Feed? | Conditions |
|---|---|---|
| Porcine MBM | ✅ Yes — 2021 derogation | Dedicated processing lines, species segregation per batch |
| Bovine MBM | ✅ Yes — 2021 derogation | Dedicated processing lines, species segregation per batch |
| Mixed mammalian MBM | ❌ No | Cannot be definitively species-attributed |
| Poultry-derived PAP (poultry meal, feather meal) | ❌ No | Intra-species ban — unchanged |
| Fish meal (PAP) | ✅ Yes | No species restriction in poultry feed |
The exclusion of mixed mammalian MBM from poultry feed applications is operationally significant. Mixed mammalian product — blends that aggregate porcine and bovine raw material without batch-level species segregation — cannot be attributed to a single non-ruminant species and therefore falls outside the derogation regardless of processing history or certification status. Any supplier offering “mixed mammalian meat and bone meal for poultry feed applications is not supplying derogation-compliant material.
The intra-species recycling ban deserves equal attention. Poultry meal, poultry by-product meal, feather meal, and blood meal of poultry origin remain prohibited in poultry feed — a restriction that applies regardless of the 2021 derogation. Compound feed producers who have historically used poultry-derived ingredients across species lines should review their formulation records carefully: the derogation does not affect this restriction.
4. The 2021 Derogation: Operational Requirements for Using MBM in Poultry Feed
The 2021 derogation does not permit the use of meat and bone meal for poultry feed on a declaration basis. It requires specific operational infrastructure and documentation practices that must be implemented and verifiable before the first batch of derogation-covered MBM enters a poultry compound feed formulation.
Dedicated processing lines are the most capital-intensive requirement. Rendering facilities must process species-specific material on dedicated lines that prevent cross-contamination with other species-origin streams or prohibited PAP types. A facility that processes both porcine and poultry-derived material on shared equipment cannot supply derogation-compliant meat and bone meal for poultry feed regardless of its other credentials. Compound feed producers must verify dedicated processing line status directly with their MBM supplier — a declaration on a COA is not sufficient; formal confirmation from the rendering facility with competent authority validation is required.
Batch-level species-of-origin documentation must accompany every transfer of meat and bone meal for poultry feed at every point in the supply chain. From the rendering facility to the trading company to the feed mill intake, each transfer must be supported by a species declaration that confirms the material is porcine or bovine-derived and has been processed through a dedicated line. Generic Category 3 compliance declarations without species-specific content do not meet this requirement.
Feed mill monitoring by the national competent authority is a condition of the derogation. Compound feed producers using meat and bone meal for poultry must be registered with the relevant national authority as an operator using derogation-covered PAPs and must be available for competent authority inspection of their incoming ingredient documentation, formulation records, and finished feed labelling.
Labelling obligations apply to poultry compound feed produced with derogation-covered MBM. Feed bags and accompanying documentation must declare the presence of non-ruminant processed animal proteins in the feed in a manner that supports the downstream traceability chain.
Record keeping for meat and bone meal for poultry feed applications must cover a minimum of five years from the date of use: supplier documentation, species declarations, COAs, delivery records, and formulation batch records. These are buyer obligations — not supplier obligations that can be delegated — and must be integrated into the feed mill’s existing quality management systems from the outset of derogation-covered sourcing.
5. Nutritional Value of MBM in Poultry Feed
Meat and bone meal for poultry delivers a nutritional profile that is most valuable when understood in relation to the specific requirements of broiler and layer formulations — not evaluated as a generic protein source in isolation.
At 50–55% crude protein on a dry matter basis and pepsin digestibility in the 70–80% range, MBM delivers lower digestible protein per unit of inclusion than prime poultry meal (65–72% CP, 85–92% digestibility) or soy protein concentrate. This digestibility differential means that formulation models must account for the digestible amino acid supply of MBM rather than its headline CP figure — particularly in broiler starter diets where amino acid precision has the most direct impact on early growth performance.
The phosphorus contribution of meat and bone meal for poultry is a genuine formulation advantage that partially offsets its protein cost position. MBM typically delivers 4–6% phosphorus on a dry matter basis, with a meaningful portion in a highly bioavailable inorganic form from the bone mineral fraction. In broiler and layer diets where dicalcium phosphate is used to meet phosphorus requirements, inclusion of this ingredient reduces the inorganic phosphorus supplementation cost — a benefit that does not appear in a protein-only cost comparison with soy protein concentrate.
For laying hens, the calcium and phosphorus contribution is particularly relevant. Layer diets have high demands for both minerals for eggshell quality and bone maintenance, and the bone mineral fraction of MBM delivers both. Formulation models that account for the phosphorus credit from inclusion often find that the true cost-per-unit-of-nutrients is more competitive than the headline price suggests.
Amino acid balancing is necessary when using meat and bone meal for poultry at meaningful inclusion levels. The ingredient is moderate in lysine and methionine — not deficient, but not a primary source of either amino acid at typical inclusion rates. Synthetic amino acid supplementation is standard formulation practice alongside MBM at the levels described in Section 6.
6. Practical Inclusion Rate Guidelines for Meat and Bone Meal For Poultry Feed
The following inclusion rate guidelines reflect commercially validated benchmarks for meat and bone meal for poultry feed applications. These are starting points for formulation modelling, not absolute limits — optimal inclusion depends on MBM quality specification, the other protein sources in the formulation, and the target performance parameters.
| Poultry Type | Recommended MBM Inclusion | Primary Benefit | Key Formulation Note |
|---|---|---|---|
| Broiler — starter (0–10 days) | 3–5% | Cost reduction | Higher-quality MBM preferred; digestibility critical |
| Broiler — grower (10–28 days) | 5–8% | Cost + phosphorus | Blend with poultry meal or SPC for amino acid balance |
| Broiler — finisher (28+ days) | 5–10% | Cost efficiency | Wider tolerance; phosphorus credit meaningful |
| Laying hen | 5–10% | Phosphorus + calcium | Reduces inorganic P supplementation cost |
| Turkey | 5–8% | Similar to broiler | Quality specification as important as for broiler |
| Breeder | 3–5% | Reproductive performance | Conservative inclusion; prefer higher-quality MBM |
The quality specification of MBM used for poultry feed directly affects the optimal inclusion rate. Higher-quality product — lower ash, higher CP, better digestibility — can be used at the upper end of these ranges without FCR impact. Lower-quality material with ash at 33–35% and digestibility below 75% should be used at the lower end, with the formulation cost model adjusted to reflect actual digestible nutrient supply rather than the headline CP figure.
For broiler starter diets, digestibility is the most performance-critical parameter. Amino acid delivery precision in the first 10 days of life has disproportionate impact on final body weight and feed conversion. Procurement managers sourcing meat and bone meal for poultry starter applications should specify minimum pepsin digestibility per batch from an ISO 17025-accredited laboratory as a non-negotiable contract condition.
7. Sourcing MBM for Poultry Feed: Supplier Qualification
The supplier qualification framework for meat and bone meal for poultry feed extends the standard Category 3 PAP qualification requirements with two additional derogation-specific verification steps.
Dedicated processing line verification is the qualification step that most directly determines whether a supplier’s MBM is actually derogation-eligible. Compound feed producers must obtain written confirmation from the rendering facility — not merely from the trading company — that porcine or bovine MBM is produced on dedicated lines that prevent cross-contamination with poultry-derived PAP streams. This confirmation should reference the specific equipment configuration and the national competent authority approval of the processing arrangement.
Species-of-origin declaration per batch must be provided as standard documentation — not on request. Every consignment of meat and bone meal for poultry feed must be accompanied by a species-specific declaration that identifies the material as porcine-derived or bovine-derived and references the rendering establishment from which it originates.
Beyond these derogation-specific requirements, the standard qualification framework applies: EU Category 3 rendering establishment approval verified independently through national competent authority registers; ISO 17025-accredited COA per batch covering CP, ash, moisture, fat, phosphorus, Salmonella, and Enterobacteriaceae; GMP+ B2 Feed Safety Assurance certification verified through the GMP+ International database; and multi-batch COA history covering at least 10 consecutive production batches before initial contracting.
The buyer’s five-year traceability obligation applies in full to meat and bone meal for poultry feed — covering all supplier documentation, species declarations, COAs, and delivery records from the point of receipt through to the finished feed production batch records.
8. Cost Opportunity: MBM vs. Alternative Protein Sources in Poultry Feed
The primary commercial case for using meat and bone meal for poultry is price arbitrage against soy protein concentrate and other plant-based protein sources. MBM is consistently priced at a discount to SPC on a per-tonne basis, and the effective cost differential — when its phosphorus contribution is credited against the inorganic phosphorus it displaces — is typically larger than the headline price gap suggests.
The phosphorus credit calculation is straightforward. MBM delivering 5% total phosphorus at, for example, 50% bioavailability contributes approximately 25g of bioavailable phosphorus per kg of ingredient. At current dicalcium phosphate prices, this mineral contribution has a calculable monetary value that reduces the effective protein cost of inclusion. Formulation teams that account for this credit find that the cost advantage of meat and bone meal for poultry is materially larger than a protein-only price comparison suggests.
The adoption gap between early movers and the broader European compound feed sector is real. Compound feed producers in the Netherlands, Belgium, and Germany who implemented the 2021 derogation infrastructure in the first year of its availability have been capturing this cost advantage since 2022. The infrastructure investment — primarily in dedicated intake and storage arrangements to segregate derogation-covered MBM from other ingredients — is a one-time cost that is recovered within a production season at commercial scale.
9. Sourcing Derogation-Compliant Meat and Bone Meal for Poultry in Europe
Derogation-compliant meat and bone meal for poultry feed requires sourcing from rendering facilities that hold both the standard Category 3 establishment approval and the dedicated processing line arrangements required under the 2021 derogation. Not all European MBM producers have made the infrastructure investment to qualify their production for derogation-covered applications — buyers cannot assume that any EU-approved rendering facility automatically supplies derogation-eligible product.
The Netherlands and Belgium are the most developed markets for derogation-compliant porcine MBM in Europe, reflecting the scale of the pig slaughter sector in both countries and the early adoption of derogation infrastructure by the major rendering operations in the region. Netherlands-based trading companies with established relationships across qualified rendering facilities can confirm derogation eligibility at the supplier qualification stage and manage the species-specific documentation chain from rendering plant to feed mill delivery.
Tuva Euro BV, headquartered in Enschede in the Netherlands, supplies derogation-compliant porcine and bovine MBM to compound feed producers across Europe. Species-of-origin declarations per batch, rendering plant dedicated line confirmation, GMP+ and Halal certification, and ISO 17025-accredited COAs are provided as standard. For compound feed producers implementing derogation-covered meat and bone meal for poultry for the first time, Tuva Euro’s qualification documentation package provides the evidentiary basis for the national competent authority registration that the derogation requires.
10. FAQ
Is meat and bone meal for poultry feed legal in the EU?
Yes — since September 2021 under Commission Regulation (EU) 2021/1372. Porcine-derived MBM is permitted in poultry feed and bovine-derived product is permitted in both pig and poultry feed, subject to conditions including dedicated processing lines at the rendering facility, batch-level species segregation documentation, feed mill registration with the national competent authority, and five-year record keeping. Mixed mammalian MBM — which cannot be attributed to a single non-ruminant species — is not permitted in poultry feed under the derogation.
What is the difference between porcine MBM and poultry by-product meal in poultry feed?
Porcine MBM is derived from pig slaughter by-products and is permitted in poultry feed under the 2021 derogation. Poultry by-product meal is derived from poultry slaughter by-products and is prohibited in poultry feed under the intra-species recycling ban — a restriction that the 2021 derogation did not change. The two ingredients have similar crude protein ranges (porcine MBM at 50–55%, poultry by-product meal at 58–65%) but very different regulatory status in poultry feed applications. Compound feed producers who use poultry by-product meal in aquafeed or petfood must ensure it is not inadvertently specified in poultry feed formulations.
What documentation is required when using meat and bone meal for poultry feed?
At the supplier level: a species-of-origin declaration per consignment specifying porcine or bovine origin and referencing the approved rendering establishment; confirmation of dedicated processing line arrangements at the rendering facility; an ISO 17025-accredited COA per batch covering standard proximate parameters and microbiological safety. At the compound feed producer level: registration with the national competent authority as a derogation-covered PAP user; batch-level traceability records linking incoming MBM consignments to finished feed production batches; labelling of finished poultry feed to declare the presence of non-ruminant processed animal proteins; and five-year retention of all supply and production documentation.
What inclusion rate of meat and bone meal for poultry is recommended for broilers?
For broiler starter diets (0–10 days), a conservative inclusion of 3–5% is recommended, given the amino acid precision demands of early growth performance and the digestibility sensitivity of young birds. For broiler grower and finisher diets, 5–10% MBM inclusion is commercially viable when the MBM specification meets minimum quality thresholds — at least 50% CP on a dry matter basis, maximum 35% ash, and minimum 70% pepsin digestibility, with higher digestibility (≥75%) preferred for grower applications. In all cases, the formulation should be modelled on digestible amino acid supply — not headline crude protein — with synthetic amino acid supplementation adjusted accordingly.
11. Conclusion
Meat and bone meal for poultry is a commercially viable, regulatory-approved protein and mineral source in European compound feed — with the right supplier, the right documentation infrastructure, and the right formulation approach. The 2021 EU derogation has created a genuine cost optimisation opportunity for poultry compound feed producers, and the gap between early adopters and the broader market is likely to narrow as derogation-compliant meat and bone meal for poultry supply and documentation infrastructure continue to mature.
The compliance framework for using meat and bone meal for poultry feed is more demanding than for petfood or aquafeed applications. Dedicated processing line verification, species-of-origin batch documentation, feed mill registration, and five-year buyer-side traceability are all non-negotiable conditions — not administrative preferences. Compound feed producers who build these requirements into their supplier qualification and procurement documentation systems from the outset are positioned to capture the cost advantage without the regulatory exposure that poorly documented derogation-covered sourcing creates.
For European poultry compound feed producers ready to qualify a supplier of derogation-compliant meat and bone meal, partnering with a Netherlands-based Category 3 trading company with established rendering facility relationships, complete derogation documentation capability, and GMP+ certification across all supply origins provides the compliance foundation that national competent authority registration and ongoing audit requirements demand.
Sourcing derogation-compliant meat and bone meal for poultry feed? Contact Tuva Euro BV.
