Changes

====Additional Labelling Requirement====

====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 [[How Pet Food is Made - Nutrition#Ingredient Selection|single feed material]].

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 [[How Pet Food is Made - Nutrition#Ingredient Selection|single feed material]].

=== Derogation ===

=== Derogation ===

As a derogation, the following mandatory labelling items may be declared outside the statutory section: the ‘best before date’, ‘batch number’, ‘net quantity’, ‘name and address of the feed business operator responsible for labelling’, and the ‘approval, registration number or address of manufacturing plant’.  In such cases it shall be pointed out in the statutory section where these particulars appear.  

As a derogation, the following mandatory labelling items may be declared outside the statutory section:  

*‘best before date’,  

*‘batch number’,  

*‘net quantity’,  

*‘name and address of the feed business operator responsible for labelling’, and  

*‘approval, registration number or address of manufacturing plant’.   

In such cases it shall be pointed out in the statutory section where these particulars appear.  

   

   

=== Composition = List of Feed Materials ===

=== Composition = List of Feed Materials ===

Feed materials (ingredients) have to be listed in descending order by weight, and the list has to be preceded by the heading: Composition. On the label of pet foods for dogs and cats, individual feed materials can be replaced by ingredient categories. These categories are designed to provide consumers with some indication of the source of raw materials used, while allowing the manufacturer some flexibility in the selection of the ingredients within a specific category (Burger ’93).  The categories are defined by law in Commission Directive 82/475/EEC laying down the categories of feed materials which may be used for the purposes of labelling compound feeding stuffs for pet animals (Table 1).  

Feed materials (ingredients) have to be listed in descending order by weight, and the list has to be preceded by the heading: Composition. On the label of pet foods for dogs and cats, individual feed materials can be replaced by ingredient categories. These categories are designed to provide consumers with some indication of the source of raw materials used, while allowing the manufacturer some flexibility in the selection of the ingredients within a specific category (Burger ’93).  The categories are defined by law in Commission Directive 82/475/EEC laying down the categories of feed materials which may be used for the purposes of labelling compound feeding stuffs for pet animals (Table 1).  

 

   

   

Table 1: List of ingredient categories:  

'''Table 1:''' List of [[How Pet Food is Made - Nutrition#Ingredient Selection|ingredient categories]]:  

1. Meat and animal derivatives

#Meat and animal derivatives

2. Milk and milk derivatives

#Milk and milk derivatives

3. Egg and egg derivatives

#Egg and egg derivatives

4. Oils and fats

#Oils and fats

5. Yeasts

#Yeasts

6. Fish and fish derivatives

#Fish and fish derivatives

7. Cereals

#Cereals

8. Vegetables

#Vegetables

9. Derivatives of vegetable origin

#Derivatives of vegetable origin

10. Vegetable protein extracts

#Vegetable protein extracts

11. Minerals

#Minerals

12. Various sugars

#Various sugars

13. Fruit

#Fruit

14. Nuts

#Nuts

15. Seeds

#Seeds

16. Algae

#Algae

17. Molluscs and crustaceans

#Molluscs and crustaceans

18. Insects

#Insects

19. Bakery products

#Bakery products

* Moisture if >14%

* Moisture if >14%

The declaration of nutrients such as calcium, phosphorus, sodium, magnesium and other nutrients is optional. However, all nutrients must be declared to which a manufacturer draws attention either as a picture, icon or in words e.g., stating that the food is “high or rich in nutrient A”.

The declaration of nutrients such as [[Calcium - Nutrition|calcium]], [[Phosphorus - Nutrition|phosphorus]], [[Sodium - Nutrition|sodium]], [[Magnesium - Nutrition|magnesium]] and other nutrients is optional. However, all nutrients must be declared to which a manufacturer draws attention either as a picture, icon or in words e.g., stating that the food is “high or rich in nutrient A”.

 

 

In addition for pet food there is a derogation that permits "crude protein" to be replaced by "[[Protein - Nutrition|protein]]" and "crude oils and fats" to be replaced by “[[Fats - Nutrition|fat]] content".

*Ash is the term used to define the inorganic material left after organic material has been burnt. It is also permitted to call “ash”, “incinerated residue” or “inorganic matter”.

*Ash is the term used to define the inorganic material left after organic material has been burnt. It is also permitted to call “ash”, “incinerated residue” or “inorganic matter”.

==== How Additives Must Be Declared: ====

==== How Additives Must Be Declared: ====

The specific name of the additive as defined in the relevant legal act authorising the additive and/or its identification number*must be declared in a list preceded by the name of the functional group or category to which they belong (Table 2). In addition to the name, the added amount of the additive must be declared. The list of additives has to be preceded by the heading ‘additives’.

The specific name of the additive as defined in the relevant legal act authorising the additive and/or its identification number* must be declared in a list preceded by the name of the functional group or category to which they belong (Table 2). In addition to the name, the added amount of the additive must be declared. The list of additives has to be preceded by the heading ‘additives’.

*N.B. Since the beginning of the reauthorisation of feed additives under Regulation 1831/2003 as amended, E numbers are being replaced with new identification numbers.

*N.B. Since the beginning of the reauthorisation of feed additives under Regulation 1831/2003 as amended, E numbers are being replaced with new identification numbers.

==== Derogations ====

==== Derogations ====

For pet food, additives of the functional groups “preservatives, antioxidants and colorants” with a maximum legal level, only the respective functional group can be declared. In this case,

For pet food, additives of the functional groups “preservatives, antioxidants and colorants” with a maximum legal level, only the respective functional group can be declared. In this case, the name, identification number and the functional group of the feed additive, which are not declared, shall be disclosed to the purchaser on his request.

 

the name, identification number and the functional group of the feed additive, which are not declared, shall be disclosed to the purchaser on his request.

TABLE 2

[[File:Table 2 - Pet Food Labels Nutrition Page.png|thumb|600px|left|Table 2 - Categories (1-4) and examples of functional groups of additives]]

Directive 2008/38/EC lists all permitted PARNUTS (1), together with the essential characteristics (2) needed to meet the requirements for the specific PARNUT, the species (3) for which it is indicated, the additional mandatory labelling requirements (4) and other provisions where necessary (6) (Table 3). Consequently, a number of additional statements appear on the labels of dietetic pet foods.

Directive 2008/38/EC lists all permitted PARNUTS (1), together with the essential characteristics (2) needed to meet the requirements for the specific PARNUT, the species (3) for which it is indicated, the additional mandatory labelling requirements (4) and other provisions where necessary (6) (Table 3). Consequently, a number of additional statements appear on the labels of dietetic pet foods.

TABLE 3

[[File:Table 3 - Pet Food Labels Nutrition Page.png|thumb|600px|left|Table 3 - Required information on labels of dietetic pet foods in Europe]]

Since the legislator tends to consider most PARNUTs as being ‘temporary situations’, they make it '''mandatory to publish on the labels a defined length of time for use''' (Table 3 column 5). However, not all PARNUT indications are temporary, e.g., diabetes mellitus type 1 and chronic kidney disease are irreversible and need lifelong dietary management. This issue has been resolved by stating in column 5 ‘initially up to xx weeks or months’. In the same time this statement should stimulate the pet owner to visit the treating veterinarian for regular control check-ups.

Since the legislator tends to consider most PARNUTs as being ‘temporary situations’, they make it '''mandatory to publish on the labels a defined length of time for use''' (Table 3, column 5). However, not all PARNUT indications are temporary, e.g., diabetes mellitus type 1 and chronic kidney disease are irreversible and need lifelong dietary management. This issue has been resolved by stating in column 5 ‘initially up to xx weeks or months’. In the same time this statement should stimulate the pet owner to visit the treating veterinarian for regular control check-ups.

Feeds intended for particular nutritional purposes shall be marketed only if their intended uses are included in Part B of Annex I to this Directive and if they fulfil the other provisions laid down in that Part of Annex I (columns 2 to 6). The PARNUTs currently approved for dogs and cats are listed in table 5.

Feeds intended for particular nutritional purposes shall be marketed only if their intended uses are included in Part B of Annex I to this Directive and if they fulfil the other provisions laid down in that Part of Annex I (columns 2 to 6). The PARNUTs currently approved for dogs and cats are listed in table 5.

The Commission may update the list of intended uses set out in Directive 2008/38/EC by adding an intended use, withdrawing an intended use or by adding, removing or changing the conditions associated with a particular intended use. In order to add a new nutritional purpose or modify an existing PARNUT, a dossier must be introduced to the EU Commission, showing sufficient scientific data to support that 1) the indication matches the definition of PARNUT and 2) a diet with the proposed essential characteristics has a beneficial effect on the specific condition.

The Commission may update the list of intended uses set out in Directive 2008/38/EC by adding an intended use, withdrawing an intended use or by adding, removing or changing the conditions associated with a particular intended use. In order to add a new nutritional purpose or modify an existing PARNUT, a dossier must be introduced to the EU Commission, showing sufficient scientific data to support that 1) the indication matches the definition of PARNUT and 2) a diet with the proposed essential characteristics has a beneficial effect on the specific condition.

TABLE 4

[[File:Table 4 - Pet Food Labels Nutrition Page.png|thumb|600px|left|Table 4 - List of Particular Nutritional Purposes for Dogs and Cats]]

=== Useful Websites ===

=== Useful Websites ===

General:

General:

== USA ==

== USA ==

Table 6. Elements legally required on pet food labels in the United States of America and Canada.

Table 6. Elements legally required on pet food labels in the United States of America and Canada.

Optional declarations on the – principal display panel (PDP) are the brand name, the manufacturer’s name, and claims in words, pictures or graphics (such as the product vignette, bursts and flags).

 

 

 

Optional declarations on the –principal display panel (PDP) are the brand name, the manufacturer’s name, and claims in words, pictures or graphics (such as the product vignette, bursts and flags).

=== Principal Display Panel ===

=== Principal Display Panel ===

The principal display panel is the part of a label that is most likely to be displayed to customers at retail facilities. It is a primary means of attracting the consumer’s attention to a product and is usually used to communicate important information about the product.

The principal display panel is the part of a label that is most likely to be displayed to customers at retail facilities. It is a primary means of attracting the consumer’s attention to a product and is usually used to communicate important information about the product.

==== Product Identity ====

==== Product Identity ====

Beside the product name, which is legally required, the product identity can also include the manufacturer’s name, a brand name or both. It is not mandatory to include the manufacturer’s name as part of the product identity on the principal display panel, but the name and address of the manufacturer (or distributor, when the product is manufactured for another party) must appear somewhere on the label. The product name often contains some description of the food and is subject to AAFCO regulations about composition of ingredients such as the percentage rules.

Beside the product name, which is legally required, the product identity can also include the manufacturer’s name, a brand name or both. It is not mandatory to include the manufacturer’s name as part of the product identity on the principal display panel, but the name and address of the manufacturer (or distributor, when the product is manufactured for another party) must appear somewhere on the label. The product name often contains some description of the food and is subject to AAFCO regulations about composition of ingredients such as the percentage rules.

==== Percentage Rules ====

==== Percentage Rules ====

as lamb meal or lamb liver) make up at least 25 % of total weight of all ingredients. For wet foods the water added during processing may be excluded from the percentage calculation, but never be less than 10% of the total product (AAFCO). An ingredient less than 25% but that comprises at least 3% of the formulation (exclusive of water for processing) may be indicated in the name or elsewhere on the label only in conjunction with words such as "with" or "contains," and must fall below maximum type size requirements to avoid overemphasis of minor ingredients.

as lamb meal or lamb liver) make up at least 25 % of total weight of all ingredients. For wet foods the water added during processing may be excluded from the percentage calculation, but never be less than 10% of the total product (AAFCO). An ingredient less than 25% but that comprises at least 3% of the formulation (exclusive of water for processing) may be indicated in the name or elsewhere on the label only in conjunction with words such as "with" or "contains," and must fall below maximum type size requirements to avoid overemphasis of minor ingredients.

==== Intended Species ====

==== Intended Species ====

The words “dog food” or “cat food” or similar terms must appear conspicuously on the principal display panel of pet foods. It must identify the animal for which the product is intended, so that it is clear that the product is not intended for humans.

The words “dog food” or “cat food” or similar terms must appear conspicuously on the principal display panel of pet foods. It must identify the animal for which the product is intended, so that it is clear that the product is not intended for humans.

==== Net Weight ====

==== Net Weight ====

Unlike pet food labels in the EU, where the typical analysis of nutrients has to be declared, in the United States minimum / maximum guarantees are declared on pet food labels (Table 7). It is important to recognize that these percentages generally indicate the “worst case” levels for these nutrients in the food. Although the guarantees do not reflect the exact or typical amounts of these nutrients, this method of declaration provides a sound means of verification and enforcement by regulators. The maximum moisture content in pet foods cannot exceed 78%, except in products labelled as a stew, gravy, broth, juice, milk replacer or similar terms.

Unlike pet food labels in the EU, where the typical analysis of nutrients has to be declared, in the United States minimum / maximum guarantees are declared on pet food labels (Table 7). It is important to recognize that these percentages generally indicate the “worst case” levels for these nutrients in the food. Although the guarantees do not reflect the exact or typical amounts of these nutrients, this method of declaration provides a sound means of verification and enforcement by regulators. The maximum moisture content in pet foods cannot exceed 78%, except in products labelled as a stew, gravy, broth, juice, milk replacer or similar terms.

[[File:Table 6 Pet Food Labels - Nutrition Page.png|thumb|600px|left|Table 6: Guaranteed Analysis]]

 

In addition to the above, a maximum percentage crude fat guarantee is required on any dog or cat food label bearing a "low fat" "lean," "less fat" or similar claim. Although a maximum

percentage ash* guarantee is not legally required in the United States, many pet food manufacturers include one on the labels of their foods. Guarantees for other nutrients may also be declared, the declaration of a nutrient is not mandatory unless its presence is highlighted elsewhere on the label, for example, "with taurine" would require a minimum percentage taurine guarantee. If these additional guarantees are for essential nutrients (e.g., taurine in cat foods),, they must be declared following the same terms and units of measure outlined in the AAFCO Nutrient Profiles. If the nutrients are not essential (e.g., taurine in dog foods), a disclaimer stating so must be asterisked to each nonessential nutrient.

In addition to the above, a maximum percentage crude fat guarantee is required on any dog or cat food label bearing a "low fat" "lean," "less fat" or similar claim. Although a maximum percentage ash* guarantee is not legally required in the United States, many pet food manufacturers include one on the labels of their foods. Guarantees for other nutrients may also be declared, the declaration of a nutrient is not mandatory unless its presence is highlighted elsewhere on the label, for example, "with taurine" would require a minimum percentage taurine guarantee. If these additional guarantees are for essential nutrients (e.g., taurine in cat foods),, they must be declared following the same terms and units of measure outlined in the AAFCO Nutrient Profiles. If the nutrients are not essential (e.g., [[Taurine - Nutrition|taurine]] in dog foods), a disclaimer stating so must be asterisked to each nonessential nutrient.

* Ash is the term used to define the inorganic material left after organic material has been burnt.

* Ash is the term used to define the inorganic material left after organic material has been burnt.

==== Feeding Guidelines ====

==== Feeding Guidelines ====

All "complete and balanced" pet foods must provide quantitative feeding directions for each life stage indicated in the nutritional adequacy statement, unless a more restricted life stage designation is more prominently indicated elsewhere. The feeding directions must at minimum state the amount of feed (e.g. cups) per given body weight dog or cat and the frequency of feeding, although especially on larger packaging, more detailed directions, often in tabular format, are typically provided..

All "complete and balanced" pet foods must provide quantitative feeding directions for each life stage indicated in the nutritional adequacy statement, unless a more restricted life stage designation is more prominently indicated elsewhere. The feeding directions must at minimum state the amount of feed (e.g. cups) per given body weight dog or cat and the frequency of feeding, although especially on larger packaging, more detailed directions, often in tabular format, are typically provided.

==== Name and address ====

==== Name and Address ====

The name and address of the guarantor, who may be the manufacturer, importer, or distributor must be stated on the label, on the information panel. Phrases as ‘distributed by...’, ‘manufactured for...’ or ‘imported by...’may indicate that a company other than the one selling the product has manufactured the pet food. This is a common practice with private label pet foods. Products that are imported must indicate the country of manufacture alongside the Guarantor Statement.

The name and address of the guarantor, who may be the manufacturer, importer, or distributor must be stated on the label, on the information panel. Phrases as ‘distributed by...’, ‘manufactured for...’ or ‘imported by...’may indicate that a company other than the one selling the product has manufactured the pet food. This is a common practice with private label pet foods. Products that are imported must indicate the country of manufacture alongside the Guarantor Statement.

Veterinary therapeutic foods, which are intended for use by or under the supervision or direction of a veterinarian, must be substantiated for nutritional adequacy by one of the above methods or its label must bear the "intermittent or supplemental" statement as required for all dog and cat foods. However, labels for these foods may bear the statement ‘use only as directed by your veterinarian’ in lieu of feeding directions. Technically, veterinary therapeutic foods are drugs as defined by FFDCA, and have not undergone the approval process as required by the law for drugs. However, FDA exercises enforcement discretion in not taking action against these products provided they meet [http://www.fda.gov/downloads/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/UCM318761.pdf FDA's guidelines].

Veterinary therapeutic foods, which are intended for use by or under the supervision or direction of a veterinarian, must be substantiated for nutritional adequacy by one of the above methods or its label must bear the "intermittent or supplemental" statement as required for all dog and cat foods. However, labels for these foods may bear the statement ‘use only as directed by your veterinarian’ in lieu of feeding directions. Technically, veterinary therapeutic foods are drugs as defined by FFDCA, and have not undergone the approval process as required by the law for drugs. However, FDA exercises enforcement discretion in not taking action against these products provided they meet [http://www.fda.gov/downloads/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/UCM318761.pdf FDA's guidelines].

==== Batch information ====

==== Batch Information ====

Information such as batch code and date of manufacture are also frequently found on pet food labels, and companies often use the ‘best before date’ or something similar to indicate the freshness date of the product. A method of traceability is also required and this information can be used to meet this need. Because of the need to continuously revise the code during production, this information is typically stamped on the label or elsewhere on the container (e.g., the bottom of the can), not necessarily in conjunction with either the principal display panel or the information panel.

Information such as batch code and date of manufacture are also frequently found on pet food labels, and companies often use the ‘best before date’ or something similar to indicate the freshness date of the product. A method of traceability is also required and this information can be used to meet this need. Because of the need to continuously revise the code during production, this information is typically stamped on the label or elsewhere on the container (e.g., the bottom of the can), not necessarily in conjunction with either the principal display panel or the information panel.

==References==

==References==

[[Category:To Do - Nutrition]]

[[Category:To Do - Nutrition]]