Interpretation of Analysis Results in Counter-analyses

This newsletter provides an explanation of the interpretation of analysis results in counter-analyses, specifically in Belgium. This is based on Regulation (EU) 2024/771, which establishes the sampling and analytical methods for the official control of feed (amending Regulation (EU) 2009/152).

Measurement Uncertainty and Counter-analysis
Annex 6, point 6, Analytical Measurement Uncertainty and Recovery Rate in the Analysis of Undesirable Substances, and point 7, Analysis of Additive Content, state:
“If the analysis result of the sample taken for arbitration purposes exceeds the maximum content (without taking into account the expanded analytical measurement uncertainty), the non-compliance of the control sample is confirmed in the absence of specific national provisions.”

 In practice, this means that measurement uncertainty may not be deducted from the analysis result in a counter-analysis.

Application of Measurement Uncertainty
The table below provides an overview of the parameters for which measurement uncertainty is considered in the first and second analysis.

Parameter First analysis Second analysis
RL 2002/32/EC Yes No
Recommendation on mycotoxins Yes No
Animal proteins No No
Pesticides (Regulation (EC) 396/2005) Yes No
Veterinary medicines Yes No
Authorized GMOs Yes Yes
Additives with maximum content Yes No
Additives with minimum content Yes Yes
Analytical constituents (guarantees) No No
Additives (guarantees) Yes Yes

Interpretation by the FAVV

Counter-analysis in Microbiological Testing
In the opinion of the Scientific Committee from December 2024, it is stated that samples for microbiological analyses, such as Salmonella or Enterobacteriaceae, are not allowed for counter-analysis.

“The Scientific Committee concludes that a second microbiological analysis is not scientifically relevant, as the analysis of the first sample by an accredited laboratory already provides a reliable assessment of the microbiological safety of the analyzed batch. Repeating the analysis on a sample that may come from a different batch and whose microbial composition may have evolved will not provide a more accurate picture of the original contamination. The heterogeneity of contamination in batches is also an important factor, as the uneven distribution of microorganisms means that an initial positive result may not be repeated in a second analysis due to this variability.”

Questions or Advice
If you have any questions or need advice regarding the interpretation of analysis results, please feel free to contact us. Our team is ready to assist you with expert guidance and practical solutions, by info@schoutenadvies.nl