Processed Animal Proteins (PAPs) in Animal Nutrition: Regulations, Applications and Quality Standards

1. What Are Processed Animal Proteins (PAPs)?

Processed animal proteins are protein-rich feed ingredients produced by rendering Category 3 animal by-products from approved slaughter and processing facilities. The term is a defined regulatory classification under EU feed law — not a commercial label — specifying both the origin of the raw material and the production conditions that must be met before the ingredient can legally enter the animal feed chain.

The PAP category includes poultry meal, meat and bone meal (MBM), blood meal, hydrolysed feather meal, and fish meal derived from fish processing by-products. What unites these ingredients is their derivation from Category 3 material — slaughter by-products from animals fit for human consumption — and their production through an EU-approved rendering process under an approved processing method as defined in Regulation (EU) No. 142/2011.

What falls outside the PAP category is equally important for procurement clarity. Rendered fats such as poultry fat and beef tallow, hydrolysed proteins produced through acid or enzymatic hydrolysis, gelatin, and collagen are distinct categories not classified as processed animal proteins under EU feed legislation — even though they share Category 3 raw material origins. Where the classification begins and ends determines which regulatory requirements apply, and which do not.

2. EU Regulatory Framework for Processed Animal Proteins

The legislative framework governing PAPs in Europe is layered across four key instruments.

Regulation (EC) No. 1069/2009 establishes the Category 3 classification system for animal by-products and defines approval requirements for rendering establishments producing processed animal proteins. Every facility — whether located within the EU or in a third country supplying into it — must hold formal Category 3 processing establishment approval, granted by the national competent authority and listed on publicly accessible national registers.

Regulation (EU) No. 142/2011 specifies the approved processing methods for PAP production. Processing Method 1 — heat treatment at ≥133°C, ≥3 bar pressure, for ≥20 minutes — is the standard method applied by the majority of producers. Compliance must be documented per batch.

Regulation (EC) No. 999/2001 — the TSE regulation — introduced the ruminant feed ban following the BSE crisis and remains fully in force. Processed animal proteins derived from mammalian species cannot be used in feed for cattle, sheep, or goats. Fish-derived PAPs are exempt from this prohibition.

Commission Regulation (EU) 2021/1372, in force from September 2021, reinstated the use of non-ruminant processed animal proteins in pig and poultry feed for the first time since the BSE crisis. Subject to conditions including dedicated processing lines, enhanced species segregation documentation, and feed mill monitoring, this derogation opened a substantial new demand channel for PAPs across Europe and materially changed the sourcing landscape for pig and poultry integrators and compound feed producers.

3. Types of Processed Animal Proteins and Their Nutritional Profiles

The PAP category covers a wide range of nutritional profiles, production processes, and commercial applications. The following matrix covers the primary processed animal proteins available at commercial scale in the European market.

The nutritional range across processed animal proteins is substantial — from blood meal at 85–92% CP to MBM at 50–55% CP, with wide variation in digestibility and amino acid profiles. Different PAP types are not interchangeable substitutes. Each serves a distinct formulation function and requires its own specification framework, quality parameters, and supplier qualification process.

4. PAPs in Petfood

Petfood is the longest-established commercial application for processed animal proteins in Europe and remains the largest volume market outside aquafeed. The “meat and animal derivatives” declaration on EU petfood labels — defined under Regulation (EC) No. 767/2009 — covers a broad range of PAP types, giving petfood manufacturers significant formulation flexibility.

In dry petfood manufacturing, processed animal proteins serve as the primary animal protein source in the kibble matrix. Poultry meal — in standard and low-ash grades — is the most widely used PAP in dry dog food and cat food across economy and mid-market segments, valued for its high CP, consistent composition, and favourable palatability profile.

Economy segment dry petfood relies more heavily on poultry by-product meal and MBM as cost-competitive options that still deliver declared animal protein content within acceptable palatability parameters. Premium segment petfood — particularly single-protein or limited-ingredient formulations — typically specifies prime low-ash poultry meal or fish meal as the primary PAP, with stricter sourcing and documentation requirements to support label claims.

In wet petfood, blood meal is used selectively at low inclusion for its high protein concentration, typically as a minor blend component. Quality variance in wet formats is more perceptible than in extruded dry formats — the flavour and texture contribution of the protein source is directly detectable in a high-moisture product. Consistent batch-to-batch specification is consequently more operationally critical for wet petfood manufacturers than for dry.

For petfood manufacturers operating under retailer sustainability frameworks, the circular economy credentials of PAPs — Category 3 by-products from the human food chain utilised as feed protein rather than discarded — are increasingly accepted as a positive sustainability narrative, particularly as an alternative to dedicated crop protein production.

5. PAPs in Aquaculture Feed

Aquafeed is the highest-specification commercial application for processed animal proteins, and the sector where quality variance between suppliers has the most direct and measurable operational consequence. FCR, growth rate, and fillet quality in farmed fish and shrimp are sensitive indicators of nutritional consistency — making aquafeed operations the most demanding buyers of PAPs in the European market.

The structural shift away from fish meal as the primary aquafeed protein source has made non-fish processed animal proteins — primarily poultry meal and blood meal — the backbone of reformulated European aquafeed. Atlantic salmon diets ran at 65%+ fish meal inclusion in the early 1990s and now operate commercially at 10–15%, with the balance provided by a blended PAP matrix. This reformulation is mature and commercially validated; the question for procurement managers is no longer whether processed animal proteins can replace fish meal, but which ones to specify and to what standards.

Low-ash poultry meal is the primary fish meal replacement in salmonid diets — its digestibility and amino acid profile are the closest match to fish meal performance among terrestrial PAPs. Blood meal functions as the high-lysine complement in the blend, addressing the lysine gap that poultry meal alone cannot close. Hydrolysed feather meal contributes volume protein at a cost point below poultry meal, typically at 5–10% inclusion in omnivorous species diets.

For shrimp diets, blood meal is particularly effective at moderate inclusion (3–6%), given shrimp’s high lysine requirement. For tilapia and carp, MBM and poultry by-product meal serve as cost-competitive bulk protein sources at higher inclusion rates, given the wider formulation tolerances of omnivorous species.

Digestibility is the critical quality parameter for PAPs in aquafeed — not crude protein. A batch of feather meal with inadequate hydrolysis, or poultry meal with elevated ash from poorly controlled raw material, can carry an acceptable CP figure while delivering substantially less digestible amino acid supply. Buyers must specify and enforce pepsin digestibility per batch from an ISO 17025-accredited laboratory — as an enforceable contract condition, not an advisory benchmark.

6. PAPs in Pig and Poultry Feed

The reinstatement of non-ruminant PAPs in pig and poultry feed under Commission Regulation (EU) 2021/1372 is the most commercially significant regulatory development in European feed ingredient markets in recent years. Prior to September 2021, the use of processed animal proteins in pig and poultry feed had been prohibited since the BSE crisis — a blanket precautionary restriction maintained for two decades beyond its original scientific rationale.

The derogation permits poultry-derived PAPs in pig feed and porcine-derived processed animal proteins in poultry feed, under conditions that prevent intra-species recycling and maintain traceability. These conditions include dedicated processing lines that prevent cross-contamination between species-origin streams, batch-level species-of-origin documentation at every supply chain transfer point, and feed mill monitoring by the national competent authority.

The commercial opportunity is real. Non-ruminant PAPs are available at a meaningful price discount versus soy protein concentrate and comparable alternative inputs, and are nutritionally well-matched to pig and poultry requirements. By 2025, early adopters in the Netherlands, Germany, and Belgium were already sourcing derogation-compliant processed animal proteins at commercial scale, with the broader European pig sector expected to follow as dedicated processing line infrastructure expands.

7. Species Restrictions: The Full Compliance Matrix

The species restriction framework is the single most operationally complex compliance area for buyers sourcing across multiple PAP types and supplying into multiple feed applications.

Two practical implications demand particular attention from procurement managers.

First, “mixed mammalian” PAPs — MBM or blood meal blends without batch-level species segregation documentation — are disqualified from use in pig and poultry feed regardless of the 2021 derogation. The derogation specifically requires species-specific processed animal proteins with documented segregation at every supply chain transfer point. Suppliers who routinely provide mixed mammalian product without batch-level species declarations are not supplying derogation-compliant material, even if they represent otherwise.

Second, for feed manufacturers supplying across multiple target species — aquafeed, petfood, and pig or poultry feed from the same facility — species origin documentation for every incoming PAP must be unambiguous and batch-specific. A single documentation failure that allows a species-origin mix-up can invalidate the compliance status of an entire production batch.

8. Quality Standards for PAPs

The quality standards framework for PAPs operates across four dimensions: compositional specification, digestibility, microbiological safety, and certification.

Compositional specification must be agreed per PAP type and enforced per batch. Minimum crude protein guarantees — 65%+ for low-ash poultry meal, 50%+ for MBM, 85%+ for blood meal — should be specified on a dry matter basis and backed by ISO 17025-accredited laboratory analysis. Ash content is a critical secondary parameter for poultry-derived processed animal proteins: it directly affects the digestible protein fraction, and suppliers who do not control ash are not controlling the nutritional value of their product.

Digestibility is the quality parameter most frequently underspecified in PAP supply contracts and most consequential for operational performance. Minimum pepsin digestibility should be specified by type: ≥85% for low-ash poultry meal, ≥80% for blood meal, ≥75% for hydrolysed feather meal. These specifications must be tested per batch from an accredited laboratory — a single sample at contract signing does not substitute for ongoing batch verification.

Microbiological safety is a non-negotiable baseline. All processed animal proteins must test negative for Salmonella in 25g under EU feed safety legislation. Enterobacteriaceae limits (≤300 CFU/g) should be specified as a broader hygiene indicator. Suppliers who test every production batch and provide the certificate as part of their standard COA package are operating to the minimum professional standard.

Certification requirements for PAPs should include GMP+ B2 Feed Safety Assurance as the minimum third-party quality standard, verified independently through the GMP+ International database. Halal certification is required where processed animal proteins are destined for halal-certified petfood or aquafeed operations — and must cover the rendering plant, not just the trading operation. HACCP certification at the rendering facility level is a prerequisite for GMP+ and must be verified as part of the initial supplier qualification process.

9. Sourcing PAPs in Europe

Every supplier of PAPs in the European feed market must source from an EU-approved Category 3 rendering establishment. This approval must be verified independently by the buyer — through the national competent authority register in the relevant member state — not accepted solely on the basis of documentation provided by the supplier. Approval status is not permanent and must be re-verified at contract renewal.

The Netherlands occupies a strategically central position in European PAP trade. Rotterdam is the primary EU entry port for third-country origin processed animal proteins — Peruvian fish meal, South American MBM, Asian poultry meal — and Netherlands-based trading companies have established import compliance infrastructure, BCP relationships, and TRACES pre-notification capabilities that reduce the import burden for buyers sourcing non-EU origin material.

For feed manufacturers sourcing multiple PAP types, a Netherlands-based specialist trading company with multi-product range, GMP+ certification, and verified rendering plant approval across all supply origins provides meaningful advantages over managing direct renderer relationships per ingredient type. Consolidated documentation, flexible order volumes, and single-point logistics management reduce the administrative and compliance burden of multi-product procurement without sacrificing traceability.

Tuva Euro BV, headquartered in Enschede in the Netherlands, supplies the full range — including poultry meal, MBM, blood meal, feather meal, and fish meal — to European petfood and aquafeed manufacturers. With GMP+ and Halal certification, ISO 17025-accredited batch COAs, and verified EU rendering plant approval across all PAP supply origins, Tuva Euro provides the compliance foundation and supply chain flexibility that demanding B2B feed operations require.

10. FAQ

Is PAP the same as meat and bone meal?

No — meat and bone meal is one type within the PAP category, which also includes poultry meal, blood meal, feather meal, and fish meal. All MBM is a PAP, but not all processed animal proteins are MBM. Different types carry different species restriction profiles, quality parameters, and permitted feed applications. Procurement managers should specify PAP type precisely in supply contracts rather than using the umbrella term as a generic ingredient description.

Can processed animal proteins be used in organic feed?

No. EU organic feed regulations prohibit the use of PAPs in feed for organically certified livestock and aquaculture production. This applies regardless of the Category 3 compliance status of the processed animal proteins or the certification status of the rendering facility. Feed manufacturers supplying organic operations must exclude them entirely from those product line specifications.

What does the 2021 derogation cover and what does it not cover?

Commission Regulation (EU) 2021/1372 permits poultry-derived PAPs in pig feed and porcine-derived material in poultry feed, subject to dedicated processing line requirements and enhanced documentation. It does not change the ruminant feed ban — bovine and ovine-derived processed animal proteins remain prohibited in ruminant feed. It does not permit intra-species recycling — poultry-origin material in poultry feed and porcine-origin material in pig feed remain prohibited. Mixed mammalian product without species segregation cannot be used in pig or poultry feed under any circumstances.

What are the buyer’s traceability obligations when purchasing PAPs?

EU feed legislation places traceability obligations on feed business operators at every link in the supply chain, including buyers. Procurement managers must maintain complete documentation for every delivery for a minimum of five years: COAs, Category 3 declarations, species-of-origin declarations, delivery notes, and import documentation for third-country origin material. For derogation-covered PAPs used in pig or poultry feed, the documentation trail must also demonstrate species segregation at every transfer point. These are buyer obligations — not supplier obligations that can be delegated back.

11. Conclusion

Processed animal proteins are among the most nutritionally concentrated, cost-competitive, and regulatory-intensive feed ingredients in the European market. From petfood to salmonid aquafeed to pig nutrition, PAPs underpin the protein supply chain of the European feed industry — with a compliance framework that has grown progressively more sophisticated since the post-BSE legislative reset.

The 2021 derogation has expanded the commercial application into pig and poultry feed, creating new sourcing requirements and compliance obligations for buyers who had previously managed PAPs only in petfood and aquafeed contexts. The quality standards — EU rendering plant approval, accredited batch COAs, GMP+ certification, species-specific documentation, and five-year buyer-side traceability — apply across all applications and ingredient types without exception.

For European feed manufacturers sourcing across multiple ingredient types and feed applications, the procurement foundation is consistent: qualified suppliers with verified approval status, transparent raw material sourcing, and the documentation infrastructure to support the compliance demands of modern feed production.

Sourcing processed animal proteins (PAPs) for your European petfood or aquafeed operation? Contact Tuva Euro BV.