EU 1069/2009

This glossary term is part of the SG Systems Global regulatory & operations guide library.

Updated January 2026 • Regulation (EC) No 1069/2009 (Animal By-Products), ABP categorization (Cat 1/2/3), storage segregation, identification controls, transport/commercial documentation, traceability & chain of custody, permitted routes (rendering, incineration, biogas), contractor governance, audit-ready evidence • EU & UK Food, Feed & Animal Health-adjacent operations (processors, co-packers, cold stores, logistics, waste contractors, ingredient sites)

EU 1069/2009 is the European Union’s foundational regulation governing animal by-products (ABP) and derived products not intended for human consumption. Operationally, it is the rule set that turns “waste” into a controlled material stream with defined categories, permitted uses, prohibited uses, and traceability expectations that extend beyond your site. If you handle animal-origin inputs, mixed ingredient streams, rework/returns, or disposal flows, 1069/2009 often becomes the compliance boundary that decides whether a material can be repurposed, rendered, routed to biogas, shipped to a third party, or must be destroyed under strict controls.

This regulation matters because ABP is not “ordinary waste.” It carries biological risk, cross-contamination risk, environmental risk, and reputational risk. It is also a fraud magnet: when financial pressure rises, uncontrolled “reuse” and unverified disposal become tempting. EU 1069/2009 is designed to prevent that drift by forcing categorization, segregation, durable identification, controlled movement, and defensible records. It turns ABP into a supply-chain governed flow—where mistakes don’t stay inside your fence line.

Tell it like it is: ABP compliance fails for boring reasons. Sites misclassify category, mix streams during busy shifts, store ABP in “temporary” areas that become permanent, hand off to contractors without complete documentation, and lose the evidence chain between “generated,” “stored,” “moved,” and “disposed.” Then an incident happens—pests, odor, temperature failure, misrouting, or an authority questions a destination—and the site can’t prove what it did. EU 1069/2009 is where that model collapses, because the regulation assumes you can demonstrate control over ABP like any other risk-critical material.

“ABP control isn’t about having a waste vendor. It’s about proving that nothing risky silently re-entered product, feed, or the environment.”

1) What people mean when they cite EU 1069/2009

When someone says “we need to comply with 1069,” they usually mean one of three practical realities:

• ABP is mixing with product risk: rework, trim, returns, offcuts, or by-product streams are close enough to the main process that misrouting is plausible.
• Handoffs are messy: contractors pick up material and the site can’t prove what left, when, in what category, and where it ended up.
• An inspection is coming: competent authorities (or major customers) want evidence of classification, segregation, labeling, and destination controls.

Tell it like it is: ABP is often treated as “operations housekeeping.” EU 1069/2009 treats it as a regulated stream. That difference is why sites get caught out—because housekeeping habits don’t create a defensible evidence trail.

2) Scope map: what 1069/2009 actually controls

1069/2009 can feel broad, but operationally it’s a control map for ABP lifecycle: classify → segregate → identify → store → move → route/dispose → retain proof.

The practical takeaway: ABP compliance is won by workflow discipline. If ABP is treated as “outside the system,” you will lose control exactly where the regulation expects it most: in handoffs and evidence.

3) ABP categories (Cat 1/2/3): why classification is everything

Category is the first control gate because it determines what you are allowed to do next. A site that cannot classify reliably will inevitably misroute material, mix streams, or create compliance exposure with contractors.

At a high level (simplified for operational thinking):

• Category 1: highest risk—strictest controls and disposal routes.
• Category 2: high risk—restricted uses and controlled processing/disposal routes.
• Category 3: lower risk—materials that may be eligible for certain uses under controls (often relevant to pet food/feed and certain processing chains).

Tell it like it is: if your ABP category decision is “who’s working today,” you don’t have a system. You have roulette. Build category rules into SOPs, training, and workflow gates so classification is consistent, auditable, and hard to override.

4) Segregation and storage: the “busy shift” failure mode

ABP segregation fails during the exact moments that matter most: peak production, staffing gaps, line downtime, sanitation pressure, and logistics congestion. That’s why segregation must be physical, visual, and procedural—not implied.

Strong segregation is usually built from:

• dedicated containers and locations by category and destination route,
• clear labeling conventions that survive moisture, cold, and handling,
• controlled access so people can’t “just drop it anywhere,”
• checks at generation points (trim stations, rework points, returns intake),
• hard rules on mixing and a defined escalation if mixing occurs.

Tell it like it is: ABP mixing usually isn’t malicious. It’s operational convenience. EU 1069/2009 assumes you’ve engineered convenience out of risky decisions.

5) Identification and labeling: make ABP unconfusable

ABP must remain identifiable through storage, internal moves, and external transport. Identification is where a lot of programs fail because labels are treated as temporary and informal. In practice, ABP labeling has to survive reality: condensation, cold rooms, washdowns, forklifts, and vendor handoffs.

Operational identification usually needs:

• a unique container ID (bin, tote, drum, or skip),
• category + material description tied to that container,
• generation timestamp/shift for time/temperature governance,
• location status (segregated area, hold, ready for pickup),
• destination route (render, biogas, incinerate, etc.).

Tell it like it is: if ABP is “the unlabeled bin near the dock,” your compliance posture is imaginary.

6) Movement controls: documentation and handoff discipline

EU 1069/2009 becomes supply-chain visible the moment ABP leaves your site. That’s where documentation and chain-of-custody discipline matter most. You need to be able to show what was shipped, in what category, in what condition, to whom, and under what documentation—without reconstructing from memory.

In practice, movement control often includes:

• pickup scheduling that prevents over-accumulation and hygiene drift,
• load verification (container counts, IDs, seals where relevant),
• documentation completeness at handoff time,
• exception handling when documentation or containers don’t match,
• retained evidence that survives audit and dispute.

Tell it like it is: vendors lose paperwork, trucks get swapped, loads get consolidated. If your proof depends on “the driver said so,” you will eventually lose an argument you should have won.

7) Permitted destinations: rendering, biogas, compost, incineration

1069/2009 is strict about what ABP can be used for and where it can go. Even when a destination is “permitted in principle,” the details still matter: category, processing conditions, approvals, and documentation requirements are not optional.

Operationally, destination control is about ensuring that:

• the category matches the destination route,
• the contractor/site is approved or authorized as required,
• transport and documentation meet expectations,
• receipt or processing confirmation can be evidenced when challenged,
• any diversion or rejection is captured as an exception event.

Tell it like it is: “we always send it to the same place” is not a control. A control is being able to prove the place was permitted and the load arrived as intended for the category you declared.

8) Temperature and time: why ABP becomes a hygiene risk fast

ABP degrades. It attracts pests, creates odor, and raises contamination risk when storage conditions drift. That’s why ABP controls often intersect with hygiene programs and temperature governance—especially for sites with cold stores, chilled collection, or shared dock environments.

Strong ABP time/temperature governance typically includes:

• defined maximum holding times by category and storage type,
• temperature expectations for chilled/frozen ABP where used,
• inspection and cleanup routines that are verified,
• excursion response (hold, reclassify, expedite removal),
• facility hygiene integration so ABP doesn’t silently compromise production zones.

Tell it like it is: ABP control is often the hidden backbone of “site hygiene.” If ABP storage is sloppy, everything else will eventually look sloppy too.

9) Contractors and waste vendors: “outsourced” doesn’t mean uncontrolled

Most sites rely on third parties for collection, transport, and processing. That’s normal—but the compliance liability doesn’t vanish. In audits and investigations, you’ll still be asked to demonstrate that you selected appropriate partners and maintained control at handoff points.

Practical contractor control usually means:

• qualification and approval (licenses/authorizations, scope, insurance, documented suitability),
• defined pickup rules (containers, labeling, sealing, counts),
• defined documentation expectations at pickup and receipt,
• incident and exception escalation (spills, rejected loads, route deviations),
• performance review (missed pickups, documentation quality, repeated errors).

Tell it like it is: the moment ABP leaves your site, the risk becomes “shared,” which usually means it becomes “nobody’s.” Build explicit ownership and evidence so that doesn’t happen.

10) Traceability and chain of custody: prove the full ABP story

When ABP is questioned, you need an end-to-end story: where it came from, how it was classified, how it was stored, who moved it, when it left, and where it went. That is classic chain of custody and traceability—applied to the ABP stream, not only to finished goods.

Tell it like it is: ABP traceability is usually weaker than product traceability because “it’s waste.” That’s exactly why it gets attention during inspections and incidents—because weak evidence creates room for misrouting, fraud, and uncontrolled re-entry.

11) Records and retrieval: the “prove it now” expectation

ABP programs fail most often on retrieval. Sites may be doing the right things, but evidence is scattered across paper forms, emails with vendors, gate logs, and spreadsheets that don’t agree. When a competent authority asks for proof, slow retrieval looks like weak control even if intent was good.

High-value ABP evidence packages typically include:

• classification rules and training (how the site decides Cat 1/2/3),
• container-level logs (IDs, contents, category, dates, locations),
• movement events (internal transfers and staging),
• handoff documentation (pickup records and load verification),
• destination proof (processing/receipt confirmations where applicable),
• exceptions (mixing events, spills, missing labels, rejected loads).

Tell it like it is: if you can’t produce the last 90 days of ABP movements confidently, you don’t have ABP governance—you have ABP hope.

12) Copy/paste ABP compliance scorecard

Use this as a practical self-assessment. If you can’t answer these cleanly, your 1069/2009 posture is fragile.

The goal isn’t “a good waste program.” The goal is a controlled ABP stream that cannot silently re-enter product, feed, or the wrong disposal route—and can be proven under scrutiny.

13) Selection pitfalls: how ABP compliance gets faked

• Category by habit. People classify based on what’s convenient, not what’s required.
• Shared bins. Categories mix because bins are reused “just this once.”
• Labels that don’t survive reality. Condensation and handling erase the identity chain.
• Vendor as a black box. Pickups happen, but proof of category and destination is weak.
• Temporary areas. ABP is staged “briefly” until it becomes the new normal.
• Retrieval chaos. Evidence exists across many places and never reconciles into one truth.
• Exceptions disappear. Spills and mixing are corrected physically but never captured as events.

Tell it like it is: these failure modes don’t just trigger findings. They create the conditions for serious incidents—contamination, pest escalation, misrouting, fraud allegations, and reputational damage.

14) How this maps to V5 by SG Systems Global

V5 supports EU 1069/2009 outcomes by treating ABP like a controlled inventory and movement stream, not a footnote. The advantage isn’t that software “knows the regulation.” The advantage is that software makes classification, segregation, movement logging, and proof-of-handoff executable—without relying on memory and ad-hoc paperwork.

• Platform overview: V5 Solution Overview
• Execution control: Manufacturing Execution System (MES) for ABP generation points, segregation gates, and exception capture
• Inventory + movements: Warehouse Management System (WMS) for container IDs, location control, scan-based transfers, and pickup reconciliation
• Quality governance: Quality Management System (QMS) for nonconformances, deviations, contractor issues, corrective actions, and audit-ready closure
• Integration layer: V5 Connect (API) to link contractor documentation, ERP transactions, scanners, and external systems into one evidence chain

The point isn’t “digital equals compliant.” The point is that ABP compliance collapses when evidence is fragmented. V5 centralizes the ABP story so handoffs and disposal routes remain defensible under inspection and incident pressure.

15) Where this matters by industry

EU 1069/2009 is most visible in animal-origin and mixed-stream operations where by-product categories, segregation, and disposal routes are constant. In Sausage & Meat Processing, ABP control shows up as trim/offal categorization, dedicated container IDs, dock discipline, and proof that nothing misrouted or re-entered production. In broader Food Processing, the risk is usually mixed lines and busy handoffs—ABP and rework streams can collide unless segregation and labeling are engineered into the workflow.

ABP control also matters in ingredient-centric environments. In Ingredients & Dry Mixes and Bakery, the by-product conversation becomes “what can be reworked” versus “what must be disposed,” and the compliance risk is weak evidence when a stream is reclassified under time pressure. For logistics-heavy operations like Produce Packing, the ABP-adjacent failure mode is disposal chain-of-custody—returns, rejected lots, and quarantine disposal need proof-of-handoff and fast retrieval when customers or authorities ask what happened to affected product.

Even in sectors where ABP isn’t the headline, the same disposal evidence discipline reduces risk. In Dietary Supplements, Pharmaceutical Manufacturing, and Medical Device Manufacturing, regulators and customers still expect controlled destruction and chain-of-custody evidence for returns, rejects, and quarantined goods. If you want the full market map, start here: Industry Solutions.

16) Extended FAQ

Q1. Is EU 1069/2009 “just waste regulation”?
No. It’s a control framework for animal by-products and derived products. The core expectation is categorization, segregation, controlled movement, permitted destinations, and chain-of-custody evidence that prevents risky re-entry and misrouting.

Q2. What’s the most common operational failure?
Misclassification + mixing during busy operations, followed by weak handoff documentation. Once streams mix or category truth is lost, the destination route may become noncompliant and the evidence chain collapses.

Q3. Why do authorities care about ABP traceability?
Because ABP can create public health and fraud risk if it is misrouted or re-enters the wrong chain. Traceability and chain-of-custody proof reduce that risk and make enforcement decisions faster and fairer.

Q4. How do we stress-test our ABP control?
Pick a random day from the last month and reconstruct the ABP story without guessing: quantities, categories, container IDs, storage locations, internal moves, pickup records, and destination proof. If you need multiple spreadsheets and emails to assemble truth, the posture is fragile.

Q5. What changes ABP compliance fastest?
Durable container IDs + scan-based movement logging + hard segregation rules. Those three controls eliminate most “busy shift” failures and make retrieval straightforward.

Related Reading
Treat ABP like a controlled stream: build evidence with Chain of Custody, enforce segregation with Quarantine + role controls, protect proof with Data Integrity and Audit Trails, and keep handoffs defensible using WMS + QMS workflows. See where this applies across markets via Industry Solutions.