EU Pet Food Regulations: Resources

The manufacture and the sale of pet food is heavily regulated by the European Union.

However, figuring out EU pet food rules can be challenging because most of the regulations are contained within Human Food and Livestock Feed regulations. The EU Pet Food Industry Group (FEDIAF) may be a good place to learn more. Also the EU Website on Animal Feed is a good resource.

Since 1970, the European Commission has adopted a succession of directives and regulations having a direct impact on all the production stages and the marketing of pet food.

Here is the List of EU legislation and other rules applicable to or of relevance for pet food  as of  12.12.2018 as provided by FEDIAF.

The current EU Regulations apply in the 28 EU Member States. However, Member States may have specific requirements in areas that are not covered by any EU regulation or may have more extensive requirements then those in the EU regulations. For Member State specific information, contact the Offices of Agricultural Affairs in the individual EU countries.

Marketing Pet Food: General Requirements

 General Labeling Requirements

Pet food products may not be marketed in the EU unless their labels conform to the requirements established by the  EU pet food labeling regulation 767/2009.

The regulation, intended to modernize pet food labels in Europe, was developed with explicit objectives to:

• Achieve legal clarity and information transparency;
• Simplify technical requirements and remove unnecessary administrative burden;
• Increase competitiveness of the EU pet food sector;
• Facilitate smooth functioning of the internal market;
• Encourage innovation and quality-relevant marketing;
• Enable consumers to make informed choices without being misled.

For clarity it is important that terms used in the legislation are well defined. This is established in Article 3 of Regulation 767/2009[1], and some important definitions are given hereafter: 

(c) Food-producing animals: any animal that is fed, bred, or kept for the production of food for human consumption, including animals that are not used for human consumption but belong to a species that is normally used for human consumption in the community. 
(d) Non-food producing animals: any animal that is fed, bred or kept but not used for human consumption, such as fur animals, pets and animals kept in laboratories, zoos or circuses. 
(i) Complete feed means a compound feed which, by reason of its composition, is sufficient for a daily ration. 
(j) Complementary feed means a compound feed which has a high content of certain substances but which, by reason of its composition, is sufficient for a daily ration only if used in combination with other feeds. 
(s) Labelling means the attribution of any words, particulars, trademarks, brand names, pictorial matter or symbol to a feed by placing this information on any medium like packaging, container, notice, label, document, ring, collar or the internet referring to or accompanying such feed, including for advertising purposes. 
(t) Label means any tag, brand, mark, pictorial or descriptive matter, printed, stencilled, marked, embossed, impressed on, or attached to the packaging or the container, of feed. 

Mandatory Labeling Requirements

Articles 15 to 20 state that the following particulars have to be declared in the statutory section of a pet food label:

1. Complete Feed or Complementary Feed
A pet food label must indicate whether the pet food is complete or complementary, in other words, whether the food can satisfy all nutritional demands without an additional ration (complete) or whether it must be fed with another product (complementary). The description “complete” or “complementary” must be considered in relation to the animal the food is intended for. Optionally, the life stage or purpose for which the food is intended may be indicated (e.g., adult, growth, all life stages, activity or light). This should be clear from the label e.g., Product X is a complete pet food for adult dogs or Product Y is a complete pet food for growing and reproducing cats.
2. Name and address of the feed business operator (company) responsible for the labelling.
3. Approval or registration number(s), or, if not available, the address of the manufacturing plant.
In cases where the producer is not the person responsible for the labelling: the business name and address of the producer (e.g., private label manufacturer), or the approval number of the producer should be given.
4. Batch Number
This is needed for traceability. Where circumstances require it, most pet food manufacturers can trace a bag or can back to the minute it was produced.
5. Net Quantity
The net quantity must be expressed in units of mass (g, kg) for solid products and units of mass or volume (ml, L) for liquid products. The “e” often seen after the weight statement indicates that the product complies with all packers rules. In addition, strict rules regulate the limits of variation permitted under the declared weight to ensure that the consumer receives, on average, the amount stated on the package (Directive 2009/34)[3].
6. Minimum Storage Life
This may also be called an expiry date and requires a DD/MM/YYYY.
7. Animal species or category of animals for which the compound feed is intended
E.g. adult cat, puppy etc.
8. Directions for Use
In practice these consist mainly of the feeding instructions, but it is not specified by law what is required as a minimum. This can also include storage instructions, especially once a pack is opened.
9. Composition
This is the list of feed materials .
10. Analytical constituents
This is the nutrient content of the feed. In Europe, the typical or proximate analysis has to be declared (see details below).
11. Additives
12. Additional Labelling Requirement
Pet food has an additional labelling requirement in Regulation 767/2009, and that is the requirement to provide a free telephone number or other suitable means of communication to enable consumers to contact manufacturers to request additional information on the additives in the pet food and also on feed materials that are listed by category rather than as single feed material. (See Common Ingredients Used In Pet Food).

Feed Hygiene

Please see the EU Page on Feed Hygiene.

On 26 of April 2004 the Council adopted Regulation 183/2005 EC the European Parliament and of the Council laying down requirements for feed hygiene.

The proposal was presented by the by Commission on 14 of April 2003 in the framework of the Commission's White Paper on Food SafetySearch for available translations of the preceding linkEN•••, and the way the three institutions negotiated allowed a successful first reading agreement in a short time.

The final text adopted by the Council and the Parliament retains all the main principles of the Commission proposal. Therefore guaranteeing a good improvement on the safety of feed.

This Regulation will ensure that feed safety is considered at all stages that may have an impact on feed and food safety, including primary production.

In particular it introduces the following main elements:

• The compulsory registration of all feed business operators by the competent authority
• Approval of feed business establishments carrying out operations involving the more sensitive substances, such as certain feed additives, premixtures and compound feedingstuffs
• The approval system for feed businesses for the cases dealing with more sensitive substances will be maintained but provisions are made to extend the current scope for the approval requirement when necessary
• To ensure that all feed businesses operate in accordance with harmonised hygiene requirements
• To implement the application of good hygiene practice at all levels of agriculture production and use of feed
• To introduce the Hazard Analysis Critical Control Point (HACCP) principles for the feed business operators other than at the level of primary production
• Community and national guides to good practice in feed production
• To introduce compulsory requirements for feed production at farm level
• To provide for a European Union framework for guides to good practice in feed production

Inspection and certification of imported pet food

APHIS (Animal and Plant Health Inspection Service of the US Department of Agriculture) must inspect and approve of all US facilities that export animal feed, or provide ingredients of animal origin, including animal fats as well as animal proteins to the EU.For complete information see Byproducts Regulation.

A health certificate has to accompany each individual pet food shipment containing products of animal origin.For links to Specimen Health Certificates see: Health Certificates and APHIS Establishment Inspection.

Marketing Pet Food: Specific requirements for specific ingredients/products

For some ingredients/ products in addition to general requirements, specific labeling and authorization procedures are required.

Please see the EU page on Animal Feed for further information on Feed Marketing

OTHER USEFUL LINKS:

The European Pet Food Industry Federation (FEDIAF)

Pet Food Manufacturers' Association (United Kingdom Pet Food Association which includes information on the EU Regulations.)

FEFAC (European Feed Manufacturers’ Federation)

US Mission to the European Union

Regulations on Products and Substances

EU Regulations provide specific rules for some products and substances . See the EU Page on Undesirable  Substances in Animal Feed for additional  information.

The aim of EU legislation on undesirable substances in animal nutrition is to ensure that feed is put into circulation only if they are sound, genuine and of merchantable quality and, when correctly used, do not represent any danger to human health, animal health or the environment or do not adversely affect livestock production.

"Undesirable substances" in EU legislation on animal nutrition means any substance or product, with the exception of pathogenic agents, present in and/or on the product intended for animal feed which presents a potential danger to human health, animal health or the environment or do not adversely affect livestock production.

EU legislation on undesirable substances in animal feed from the 1970s on was consolidated by Council Directive 2002/32/EC. This Directive was replaced by Directive 2002/32/EC (consolidated version) of the European Parliament and of the Council, of 7 May 2002, on undesirable substances in animal feed. The Directive has been subsequently regularly amended in the light of developments in scientific and technical knowledge.

Directive 2002/32/EC introduced some major amendments:

• The most important prohibits the dilution of contaminated feed materials
• It also includes maximum limits for heavy metals such as arsenic, lead, mercury and cadmium as well as for dioxin, aflatoxin, certain pesticides, and botanical impurities in certain feed materials, feed additives and feeding stuffs

In addition, several Commission Recommendation have been adopted in relation to the presence of mycotoxins, in particular ochratoxin A, deoxynivalenol, zearalenone, fumonisins, T-2 and HT-2 toxin in cereals and cereal products intended for animal feed.

Commission Recommendation 2006/583/EC of 17 August 2006 on the prevention and reduction of Fusarium toxins in cereals and cereal products

Commission Recommendation 2006/576/EC of 17 August 2006 on the presence of deoxynivalenol, zearalenone, ochratoxin A, T-2 and HT-2 and fumonisins in products intended for animal feeding as amended by Commission Recommendation 2013/637/EU of 4 November 2014 as regards T-2 and HT-2 toxin in compound feed for cats- Commission Recommendation 2013/165/EU of 27 March 2013 on the presence of T-2 and HT-2 toxin in cereals and cereal products.

A guidance document on the application of Commission Recommendation 2013/165/EU has been elaborated together with a simplified data submission format for submitting data to EFSA.