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Selling pet food in the EU

In the EU, pet food is animal feed. Regulation (EC) No 767/2009 sets the rules for placing it on the market and labelling it, Regulation (EC) No 183/2005 requires feed businesses to be registered and follow hygiene rules, feed additives must be authorised, and Directive 2002/32/EC sets maximum levels for undesirable substances.

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

What it is
Compound feed, under EU feed law
Marketing and labelling
Regulation (EC) No 767/2009
Feed businesses
Registered with the competent authority (Regulation (EC) No 183/2005)
Additives
Authorised for 10 years, listed in the EU Register of Feed Additives
Label language
An official language of the member state or region of sale
Pet food label
A free telephone number or other means to ask for more information

Before a product goes on sale

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

  1. 1Is the feed safe, and within the limits for undesirable substances? Read more
  2. 2Is each establishment registered, and is an imported product from a listed country and establishment? Read more
  3. 3Is each feed additive authorised, and used within its conditions? Read more
  4. 4Does the label carry the mandatory particulars, in the right language? Read more
  5. 5Can each claim be substantiated, and does none claim to treat disease? Read more

The rules, by area

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

Feed safety and undesirable substances

Pet food as feed, and the safety duty and limits that come with it.

  • The Commission lists three types of feed: feed materials, feed additives, and compound feed including pet food.
  • Feed may only be placed on the market if it is safe and has no direct adverse effect on the environment or animal welfare; the feed safety requirements of Regulation (EC) No 178/2002 apply to feed for non-food producing animals (Article 4, Regulation (EC) No 767/2009).
  • Feed placed on the market must be sound, genuine, unadulterated, fit for its purpose and of merchantable quality.
  • Directive 2002/32/EC sets maximum limits for heavy metals such as arsenic, lead, mercury and cadmium, and for dioxin, aflatoxin, certain pesticides and botanical impurities, and prohibits diluting contaminated feed materials.
  • Commission Recommendations cover mycotoxins in feed, including T-2 and HT-2 toxin in compound feed for cats.

How we help: Compliant Always keeps your certificates of analysis and contaminant results with the batch they cover, and shows which limits each one answers. Ask about this

Registration, hygiene and imports

Who must be registered, and how feed comes into the EU.

  • Feed business operators notify the competent authority of each establishment under their control, for registration, and keep that information up to date (Article 9, Regulation (EC) No 183/2005).
  • Establishments working with more sensitive substances, such as certain feed additives, premixtures and compound feed, need approval, and feed businesses beyond primary production apply HACCP principles.
  • Feed imported from outside the EU comes from a listed country and a listed establishment, and meets EU feed rules or conditions recognised as equivalent (Article 23).
  • The Commission publishes national lists of feed importers and of EU representatives of establishments outside the EU.
  • Official controls follow Regulation (EU) 2017/625, with methods of sampling and analysis in Regulation (EC) No 152/2009.

How we help: Compliant Always keeps each establishment's registration and each supplier's listing with the products they make, and shows what is missing before a shipment. Ask about this

Feed additives

What may be added to pet food, and on what terms.

  • Feed additives may not be put on the market unless authorised after a scientific evaluation shows no harmful effects on human and animal health and on the environment.
  • There are two types of authorisation, each valid for 10 years throughout the EU and the European Economic Area.
  • The European Union Register of Feed Additives lists authorised additives and links to the Regulations that authorise them.
  • Regulation (EC) No 1831/2003 sets a common procedure for authorising feed additives and rules for their placing on the market, labelling and use.

How we help: Compliant Always reads your formula against the Register of Feed Additives, and watches it for changes to the additives you use. Ask about this

Labelling

What a pet food label has to show.

  • The label gives the type of feed ('complete feed' or 'complementary feed', or 'compound feed' for pets other than cats and dogs), the name and address of the feed business operator responsible for labelling, any establishment approval number, the batch or lot reference, net quantity, the additives under the heading 'additives', and moisture content (Article 15).
  • Compound feed also states the species or categories of animal, instructions for proper use, minimum storage life, and a 'composition' list of feed materials in descending order by weight (Article 17).
  • For pet food, feed materials may be named by category instead of individually, and the label gives a free telephone number or other means for purchasers to ask about the additives and the feed materials named by category (Articles 17 and 19).
  • The particulars appear in a prominent place, conspicuous, clearly legible and indelible, in the official language or one of the official languages of the member state or region where the feed is sold (Article 14).
  • When feed is sold at a distance, the mandatory particulars appear on the material supporting the sale or are given before the contract is concluded; a few, such as the batch number and net quantity, may be given at delivery (Article 11).
  • The Commission published the reference of the 'Code for good labelling practice of pet food', which was updated and endorsed in September 2018.

How we help: Compliant Always reads each label against Articles 15 to 19 and the pet food code, and shows what is missing for each product. Ask about this

Claims and presentation

What a pet food may say about itself.

  • Labelling and presentation may not mislead as to intended use, characteristics, composition, quantity or the species for which the feed is intended, or attribute effects it does not have (Article 11).
  • A claim about the presence or absence of a substance, a nutritional characteristic or a function must be objective, verifiable and understandable, and the scientific substantiation must be available when the feed is placed on the market (Article 13).
  • Feed may not claim to prevent, treat or cure a disease, except authorised coccidiostats and histomonostats.
  • A claim of a particular nutritional purpose needs the feed to meet the list of intended uses; the authorised uses for dietetic feed for pets are in Regulation (EU) 2020/354.

How we help: Compliant Always keeps the substantiation behind each claim with the label that makes it, dated. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Feed business operator responsible for labellingThe label, the claims and their substantiation, and the feed it places on the market.Labels, claims and the evidence behind them kept together by product.
ManufacturerRegistration or approval of its establishment, hygiene, and the safety of the feed it makes.Registrations, certificates and test results kept with each batch.
ImporterFeed brought in from listed countries and establishments, meeting EU feed rules.Suppliers' listings and documents read and dated before the goods arrive.
Online sellerGiving the mandatory particulars before a distance sale is concluded.Product information ready for each listing, from the record.

Member states

The Regulations apply directly in each member state. Feed businesses register with the competent authority of their member state, and each member state publishes its own lists of feed importers and representatives.

Shipping out of the EU?

Exporting pet food from the EU

Questions businesses ask

Is pet food regulated as feed in the EU?
Yes. The Commission lists compound feed, including pet food, as a type of feed, and Regulation (EC) No 767/2009 sets the rules for placing feed on the market and labelling it.
Does a pet food business need to register in the EU?
Yes. Feed business operators notify the competent authority of each establishment they control, for registration. Establishments working with more sensitive substances, such as certain additives and premixtures, need approval.
What must a pet food label show in the EU?
The type of feed, the operator responsible for labelling, batch reference, net quantity, additives, moisture content, the species it is for, instructions for use, minimum storage life and a composition list in descending order by weight.
Does a pet food label need a telephone number?
Yes. Pet food labels give a free telephone number or other means of communication, so purchasers can ask about the additives and the feed materials named by category.
Can pet food labels name ingredients by category?
Yes. For feed for non-food producing animals other than fur animals, the specific name of a feed material may be replaced by the name of its category.
Which language must a pet food label be in?
The official language, or at least one of the official languages, of the member state or region where the feed is placed on the market.
Can pet food make health claims in the EU?
Claims on nutrition and on supporting physiological conditions are allowed if objective, verifiable and substantiated. Pet food may not claim to prevent, treat or cure a disease.
Do pet food additives need authorisation?
Yes. Feed additives may not be put on the market unless authorised after a scientific evaluation. Authorisations last 10 years and are listed in the European Union Register of Feed Additives.
What contaminant limits apply to pet food?
Directive 2002/32/EC sets maximum limits for heavy metals such as arsenic, lead, mercury and cadmium, and for dioxin, aflatoxin, certain pesticides and botanical impurities in feed.
Can I import pet food into the EU from outside it?
Yes, if the country and the establishment of dispatch are on the lists of those from which feed imports are permitted, and the feed meets EU feed rules or conditions recognised as equivalent.
Is there a labelling code for pet food?
Yes. The 'Code for good labelling practice of pet food' was published under Article 26 of Regulation (EC) No 767/2009 and updated and endorsed in September 2018.
How does Compliant Always help with selling in the EU?
Our team reads the rules for the markets you sell in. Compliant Always shows which apply to your product, keeps the documents behind each one ready, 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.

Tell us what you make, and we will show you the rules for it.

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