Animal by-products are entire animal bodies, parts of animals, or products of animal origin that are not intended for human consumption, and although they are a routine output of farming and food production, the legal duties attached to them are widely misunderstood. Anyone who keeps livestock, runs a butchery or processes food has a responsibility to identify their animal by-products correctly and dispose of them through approved routes. Martlands deals with these materials every day as part of our fallen stock and ABP collection operation, and this guide sets out what the term actually covers and, more importantly, what the law expects you to do about it.
What Counts as an Animal By-Product
At its simplest, an animal by-product is any material derived from animals that is not destined for the human food chain. That covers a broad range of materials, from whole carcasses and parts of slaughtered animals to blood, hides and skins, hooves and horns, feathers, wool and hair, the contents of the digestive tract, manure, and reproductive material not used for breeding. It also includes former foodstuffs of animal origin, such as eggs, milk past its sell-by date and meat withdrawn from sale. A point that catches many businesses out is that meat or fish becomes an animal by-product the moment it is no longer intended for people to eat, even if it remains perfectly edible. Edibility is not the test; intended use is. Once a product crosses that line it must be handled under the rules that govern by-products rather than as ordinary waste.
The Three Categories and Why They Matter
Animal by-products are graded into three categories according to the risk they present, and the category determines how the material may lawfully be processed. Category 1 is the highest-risk tier and includes specified risk material and animals suspected of carrying certain diseases; it must be destroyed through approved routes with no possibility of returning to the feed or food chain. Category 2 covers material such as fallen stock and manure that carries a moderate risk. Category 3 is the lowest-risk tier, comprising parts of animals passed fit for human consumption at slaughter but diverted for commercial reasons, along with many former foodstuffs, and it may go on to be rendered into other products. Getting the category right is the foundation of compliant disposal, because the wrong route for a high-risk material is a serious failure. The distinctions are explained further in our blog on the categories of animal by-products explained, and each tier has its own dedicated service in our Category 1 ABP collection, Category 2 ABP collection and Category 3 ABP collection.
Your Legal Duty of Care
Disposing of animal by-products is governed in England by the Animal By-Products (Enforcement) (England) Regulations 2013, and it is against the law to dispose of them outside the controls those rules set out. For livestock keepers this includes a duty of care to arrange collection of fallen stock promptly, generally within 24 hours of an animal’s death being discovered, and a longstanding ban on burying or burning carcasses on the farm, which has been unlawful in the UK since 2003 apart from very limited exceptions in remote areas. The practical consequence is that nearly every farm, abattoir, butcher and food business must use a licensed collector. Cutting corners is not only an offence but a biosecurity risk, and fly-tipping by-products is treated especially seriously; our guidance on ABP fly tipping guidance explains why and what the consequences are.
Some Materials Sit Outside the Controls
The regulations include a number of sensible exceptions, and knowing them avoids unnecessary worry. Raw pet food sold directly to the final consumer is generally outside the main controls, as is liquid milk and colostrum disposed of or used on the farm where it was produced. Animals caught in the wild and not suspected of carrying disease, the excrement and waste of domestic pets, and waste from zoo or circus animals also fall outside the stricter requirements. Catering waste is exempt unless it is being used to feed animals or sent to a composting or biogas plant, at which point it comes back into scope. These carve-outs are narrow and specific, so when there is any doubt the safest course is to treat the material as a by-product and seek advice rather than assume an exemption applies.
Why Correct Handling Is Worth Getting Right
Handling animal by-products properly protects public health by keeping potentially hazardous material out of the food chain, protects the environment by preventing pollution and disease spread, and allows valuable materials to be recovered into fertiliser, renewable energy and other products rather than wasted. It also keeps the business itself out of trouble, because failure to comply can lead to enforcement action and significant penalties. The thread running through all of this is traceability. Every compliant collection produces a Commercial Document, and where relevant a Waste Transfer Note, recording what was collected and where it went, which is exactly the evidence an inspector or assurance scheme will ask for. For livestock specifically, this is part of the same disciplined process that underpins our farm and fallen stock collection service.
Disposing of Your Animal By-Products Compliantly
Understanding what animal by-products are is only the first step; acting on that knowledge with a licensed collector is what keeps a business compliant. Martlands provides suitable vehicles for transporting by-products safely, follows rigorous hygiene procedures, and maintains the detailed records that ensure traceability at every stage. As a DEFRA approved processing and sampling facility, an NFSCO member and the holder of Animal By-Products Licence APB/CCN21/373/8002, we are licensed to collect and process all three categories, including acting as a sampling centre for the BSE testing required on fallen cattle over 48 months of age. To arrange collection or to talk through how your own materials should be classified and disposed of, call 01704 776977 or visit our contact us page.
