Spent Grain and Animal Feed Registration

Here's one that almost nobody sees coming. If you give your spent grain to farmers — which most small breweries do, because otherwise you're paying to dispose of it — you are legally classified as an animal feed business. You must register with your local authority under the Feed Hygiene Regulation. This has applied to breweries, distilleries, and food manufacturers since 2006 as part of the "farm to fork" approach to food safety.

Registration means obligations. You must keep detailed records of every batch of spent grain you supply: the quantity, the date, and the name and address of the farm or business you supplied it to. You need to track grain batch codes so that if there's ever a problem — contamination, illness in livestock — the grain can be traced back through the supply chain. Article 18 of the General Food Law makes provision for the traceability of feed, and Article 20 sets out your responsibilities for withdrawing feed that doesn't comply with safety requirements.

This isn't theoretical. If an animal gets sick and it's traced back to your spent grain, you need to be able to show exactly which batch it was, what went into it, and where the rest of that batch went. If you can't, you're liable. Documentation must be kept for an appropriate period, and samples of ingredients and batches should be retained.

Most small brewers start out casually handing bags of grain over the fence to a local farmer and have no idea they're operating an unregistered feed business. Ignorance is not a defence.