EU Pet Product Regulations: Resources

The European Union or EU regulates a variety of products; however most of these regulations do not apply specifically to pet products. In the absence of a specific EU regulation, called a “Directive” in EU terminology, the local laws of each EU member country would apply. Therefore, if a US manufacturer wants to export to an EU member country and the product is not regulated by EU law, the importer must refer to the pertinent laws of the EU member country.

Figuring out EU pet product import requirements can be especially challenging because some of these general rules only apply to products intended for human use, and not in the case of products intended solely for pets. While not attempting to cover any of the national laws of member countries, this page may help you determine which EU regulation applies to the marketing of pet products, and provides a number of links to relevant EU legislation.

European Regulation of pet products mainly relate to product labeling requirements and to the legal responsibility of manufacturers for allegedly defective products.

APPA has a cooperative agreement with Blue Tiger International and they have worked closely in advising APPA members as to the requirements for shipping goods overseas. Contact Tom Cook at  tomcook@bluetigerintl.com  (516)359-6232 or go to the APPA Web Page on Import-Export Solutions for additional information or on the APPA Web Page on APPA's Export/Import Services. 

Labeling Pet Products

To market pet products in the EU you must verify whether your products require the “CE” Mark and conform to the prepackaged products requirements.  Also, if you manufacture a textile product you must refer to the relevant EU labeling regulation applicable to textiles. If your product has a reduced environmental impact or environmentally friendly component, you can also apply to use the EU approved eco-label award to promote your product.

“CE” Conformity Marking

The Council Decision of 22 July 1993 sets forth the rules for use of the CE mark (an acronym for the French "Conformité Européenne").

The mark is required to market most products in the EU.The CE mark certifies that a product has met the EU health, safety, and environmental requirements incumbent on the manufacturer of the product. 

What is CE Marking (CE Mark)?

CE Marking is the symbol. The letters "CE" are the abbreviation of French phrase "Conformité Européene" which literally means "European Conformity". The term initially used was "EC Mark" and it was officially replaced by "CE Marking" in the Directive 93/68/EEC in 1993. "CE Marking" is now used in all EU official documents.

CE Marking on a product is a manufacturer's declaration that the product complies with the essential requirements of the relevant European health, safety and environmental protection legislation, in practice by many of the so-called Product Directives. CE Marking on a product indicates to governmental officials that the product may be legally placed on the market in their country. CE Marking on a product ensures the free movement of the product within the EFTA & European Union (EU) single market (including totally 30 EEA* countries), and CE Marking on a product permits the withdrawal of the non-conforming products by EEA customs and enforcement/vigilance authorities.

Products requiring the CE mark: Unfortunately, there is no comprehensive list of all the products that require a CE mark. Therefore, it is the manufacturer's responsibility to determine whether the product requires the CE mark by looking in each EU Directive that regulates the particular product. However this can be challenging because the wording of EU Directives can be very confusing and also because several Directives can apply to one single product.

For additional information see:

The CE Mark

Products "Mark" Required for US Exports to Europe

Labeling of Prepackaged Products

A product is considered as “prepacked” in EU terminology when it has been placed in a package without the purchaser being present and when the product contained in the package cannot be altered without opening the package.Therefore the term “prepacked products” covers most of the products into the EU.

Council Directive 76/211/EEC of 20 January 1976 sets forth the labeling requirements for prepacked products.

“Prepacked products” must contain a list of information including:

• The indication of weight or volumeusing a harmonized format meaning by using trade practice or by complying with the national regulations of the country where the product will be marketed if such indications vary in the Member States.

The EEC mark(different from the CE mark)

• The label of a prepacked product may bear the EEC mark (a small "e") only if it is certified as complying with the requirements set out in the Directive with regards to metrological control.This control is used to verify the accuracy of the weight and volume, i.e. the quantity of product indicated on the prepackage by the manufacturer. The metrological services of each Member State are the authorities responsible for carrying out this metrological control and for granting the EEC mark (they follow the instructions of Annex I, Section 5 and Annex II of the Directive).

For complete information access the following link: Prepacked Products

Labeling of Textile Products

Textile product regulation has been harmonized across all member countries in the EU, and the labeling of textile products must comply with the requirements set up by the Directive 96/74/EC of 16 December 1996 in order to enter the EU market.

Fiber Content- According to the Directive, textile products for sale in the EU should be labeled by reference to their fiber content whenever they are put onto the EU market. These Regulations apply to products entirely made of textile fibers, as well as products containing at least 80% textile components.

• In most applications the labels on textiles must show the percentages of materials contained in the item. For example, clothing may be labeled ‘100% cotton’ or ‘50% wool, 50% acrylic’.

Care Instructions- There is no legal obligation to include care labels under EU regulations; however, if a manufacturer does include care instructions, the information shown must be accurate.

Language requirements- The Directive also provides language requirements for textile labels (Article 8):

• Member States may also require that, when textile products are offered for sale in their territory, their national languages mustbe used for the labeling of textile products.

The Directive does not apply to textile products which:

• are intended for export to third countries,
• enter Member States, under customs control, for transit purposes,
• are imported from third countries for inward processing,
• are contracted out to persons working in their own homes or to independent firms that make up work from materials supplied.

For further information see: Labeling of Textile Products

Eco-label

The Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17 July 2000 sets up the rules on the Community eco-label award.

The Community eco-label award scheme is intended to promote products with a reduced environmental impact during their entire life cycle.The eco-label may be awarded to products available in the Community which meet certain environmental requirements and specific eco-label criteria.

The criteria are based on:

• the product's prospects of market penetration,
• the technical and economic feasibility of the necessary adaptations,
• the potential for environmental improvement.

The criteria are reviewed by the European Union Eco-Labeling Board (EUEB), which is also responsible for assessment and verification requirements.

For complete information refer to the link: Eco-label

Responsibility of Pet Products Manufacturers

US pet product companies can be held strictly liable under EU law for putting defective products on the EU market (Council Directive 85/374/EEC of 25 July 1985).

A manufacturer can be held responsible “without fault”: meaning that a manufacturer may be held strictly liable for any damage caused to a human or to a pet by a defective product, regardless of whether or not there is proof of actual negligence.

For detailed information see: Liability for Defective Products

OTHER USEFUL LINKS

Can be found on the APPA Website under the heading Pet Products and the Law, including the page on Exporting Pet Products: Resources 

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.