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Exporting pet food from the EU

Pet food is feed, and feed exported from the EU must meet EU law unless the destination says otherwise; the animal by-products Regulation applies the same rule to Category 3 material and its products. Destinations often require an export certificate, issued by member state officers. The exporter lodges an export declaration with an EORI number.

Updated · Each section links to the official source it comes from

Feed law on exports
Article 12 of Regulation (EC) No 178/2002
Animal by-products
Article 43 of Regulation (EC) No 1069/2009
Certificates
Member state officers; TRACES; the Commission's Export library
Declaration
Electronic export declaration in AES, with an EORI number
Origin
REX statements on origin or EUR.1, by agreement

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Does the pet food meet EU feed and animal by-product law, or has the destination asked for something different? Read more
  2. 2Does the destination require a veterinary or health certificate, and is there one agreed with the EU? Read more
  3. 3Is the product or the destination subject to an export restriction? Read more
  4. 4Does the pet food meet the agreement's list rule, and what proof of origin goes with it? Read more
  5. 5Who lodges the export declaration, and are the documents ready? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

EU feed and animal by-product law on exports

Whether pet food made for export must meet EU rules.

  • The Commission treats pet food as feed: it is compound feed under the feed marketing rules, and the 70 million pet-owning households in the EU buy roughly 10 million tonnes of feed for their pets a year.
  • Food and feed exported or re-exported from the EU for a third country's market must comply with the relevant requirements of EU law, unless the importing country's authorities ask otherwise or its laws set different requirements (Article 12 of Regulation (EC) No 178/2002).
  • Unsafe feed may not be exported. Other feed that cannot be placed on the EU market may be exported only if the destination's competent authorities have expressly agreed, after being fully informed.
  • Article 12 applies in the same way to exports of Category 3 animal by-product material, and products derived from it, in line with the animal by-products Regulation (Article 43(4) of Regulation (EC) No 1069/2009).
  • The export of animal by-products and derived products for incineration or landfill is prohibited, as is their export to non-OECD countries for use in a biogas or composting plant (Article 43(1) and (2)).

How we help: Compliant Always keeps the destination's stated requirements beside your recipe and raw-material records, so a departure from EU rules is documented with the shipment. Ask about this

Export certificates for pet food

The certificates destinations ask for, and who in the EU issues them.

  • TRACES is the Commission's platform for sanitary certificates, used for EU exports of animals and certain animal products as well as imports.
  • The Commission's Export library helps officers in member states issue export certificates, covering harmonised certificates agreed with the destination and SPS requirements that go beyond the EU's.
  • For Canada, the Export library lists harmonised certificates for animal by-products and Canadian labelling requirements for processed animal proteins exported from the EU.
  • For Ukraine, it compares Ukraine's import certificate for processed pet food other than canned pet food with EU legislation, and notes any differences.
  • Access2Markets notes that most countries require health certificates for animal products.

How we help: Compliant Always keeps each export certificate with the shipment and lot it covers, dated, and reads it against what the destination asks for. Ask about this

Export restrictions, licences and sanctions

Goods and destinations that need an export licence or cannot be exported at all.

  • Access2Markets says the export of some goods, or exports to certain destinations, may be prohibited or restricted and need a licence; check TARIC for export licences and the EU Sanctions Map for restrictions.
  • Restricted or prohibited types include some live animals, meat and plants, certain food products, dangerous chemicals, drugs and medicines, dual-use goods, waste, cultural goods and counterfeit goods.
  • Member states may exceptionally have national restrictions, which are checked with their competent authorities.
  • The export procedure includes presenting export licences, and an oral declaration is not allowed for goods subject to prohibitions or restrictions.
  • EU sanctions on Russia (Regulation (EU) No 833/2014) prohibit exports of listed goods and oblige operators to contractually prohibit the re-export of certain sanctioned goods.

How we help: Compliant Always keeps any licence with the shipments it covers and shows when it is near its end, before the next shipment is declared. Ask about this

Origin and proof of origin

Preferential origin under EU trade agreements, how it is proved, and certificates of non-preferential origin.

  • To get a lower or zero tariff under a trade agreement, goods must be wholly obtained in the EU or sufficiently worked or processed there under the product-specific 'list rules' of the agreement's origin protocol, read by HS heading.
  • The Commission's Rules of Origin Self-Assessment tool (ROSA), in Access2Markets' My Trade Assistant, helps check a product against the rules and explains which proof of origin to prepare.
  • Proof can be a movement certificate EUR.1 or EUR-MED issued by customs, or a self-declaration by the exporter on a commercial document: a statement on origin, or an invoice or origin declaration.
  • EU exporters must be registered in REX, with their national competent authorities, to make out statements on origin under agreements including those with Canada, Japan, Vietnam, Singapore, the UK, New Zealand and Chile, and the EU-MERCOSUR Interim Agreement.
  • Without a REX number, an exporter may make out statements on origin for consignments of originating products worth up to EUR 6 000 (EUR 10 000 for trade with the OCTs).
  • Suppliers' declarations let an exporter rely on the originating status of materials bought in the EU. Exporters keep copies of proofs of origin and related records for at least three years.
  • A Binding Origin Information (BOI) decision from customs fixes the origin of goods for up to three years, but does not replace the proof of origin.
  • A certificate of non-preferential origin may be required by the destination; Access2Markets says these are usually issued by the local chamber of commerce, and in some countries by ministries or customs.

How we help: Compliant Always keeps the REX number, suppliers' declarations and each statement on origin or certificate with the shipment it covers, and shows which proofs are missing or out of date. Ask about this

EORI and the export declaration

Who may export, the registration number every declaration carries, and the two stages of the export procedure: export and exit.

  • The export procedure (Article 269 UCC) is obligatory for EU goods leaving the EU customs territory, with very few exceptions, so that export measures such as restrictions are applied.
  • An EORI number is mandatory for customs operations in the EU, export included. It is assigned by the customs authority of the member state where the operator is established, and does not expire.
  • Access2Markets says an exporter normally needs to be established in the EU, including a VAT registration; a non-EU resident needs a person established in the EU, such as a logistics provider or customs agent, to act as exporter.
  • The export declaration is lodged electronically in the Automated Export System (AES), at the customs office for the place where the exporter is established or where the goods are packed or loaded (Article 221(2) UCC-IA).
  • It gives the origin of the goods, the destination country, commodity codes, customs procedure codes and the value. Customs may release the goods, ask for documents, or check them physically.
  • The goods and the Master Reference Number (MRN) are then presented at the customs office of exit, which supervises their departure. Goods stay under customs supervision until they leave.
  • Keep invoices, transport documents and packing lists for at least three years. Exports are exempt from EU VAT if records and the customs proof of export are kept.

How we help: Compliant Always keeps the EORI, invoice, packing list, MRN and proof of exit with each shipment, dated, and shows what is missing before the goods are declared. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Pet food manufacturerFeed that meets EU law or the destination's stated rules, and the records the certifying officer relies on.Production and raw-material records kept by lot.
ExporterThe export declaration, the EORI number, and proof of origin.The shipment's certificates, declaration and origin proofs kept together.
Member state competent authorityIssuing export health or veterinary certificates, including harmonised certificates in TRACES.Each certificate kept with the lot it covers.
Customs representative or forwarderLodging the declaration and presenting the goods for export and exit.The documents behind the declaration, ready before it is lodged.

Member states

The export rules are EU law, but member states run them. The EORI number, the export declaration, origin registrations such as REX and approved exporter status, and dual-use licences go through the national authorities of the member state concerned.

Export certificates for food, animal products and plants are issued by member states' competent authorities; the Commission supplies harmonised certificates through TRACES and guidance in its Export library. Certificates of non-preferential origin are usually issued by local chambers of commerce.

Where are the goods going?

Most of what pet food have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Do EU rules apply to pet food made only for export?
Yes, as a rule. Feed exported from the EU must meet EU law unless the destination's authorities ask otherwise or its laws set different requirements. The animal by-products Regulation applies the same rule to Category 3 material.
Who issues export certificates for pet food in the EU?
Officers of member states' competent authorities. The Commission supports them with TRACES and an Export library of destination requirements and harmonised certificates.
Is there an EU export certificate for pet food to Canada?
The Export library lists harmonised certificates for animal by-products for Canada, and Canadian labelling requirements for processed animal proteins exported from the EU.
What does Ukraine require for pet food from the EU?
The Export library compares Ukraine's import certificate for processed pet food other than canned pet food with EU legislation, identifying the differences the certifying officer should check.
Can I export pet food that is not allowed in the EU?
Only if the destination's competent authorities have expressly agreed, after being fully informed why it cannot be sold in the EU. Unsafe feed may not be exported.
Can animal by-products be exported from the EU for disposal?
No. Exporting animal by-products and derived products for incineration or landfill is prohibited, as is exporting them to non-OECD countries for biogas or composting.
Do I need an EORI number to export pet food?
Yes. An EORI number is needed for every export declaration. It is assigned by the customs authority of the member state where you are established.
What proof of origin does pet food need for a lower tariff?
The proof set by the agreement: usually a statement on origin by a REX-registered exporter, or an EUR.1 or EUR-MED certificate. Unregistered exporters may make out statements for consignments up to EUR 6 000.
Is VAT charged on pet food exported from the EU?
No. Exports are exempt from EU VAT provided you keep records of the export and the proof of export issued by customs.
How does Compliant Always help with exporting from the EU?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

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