Changes

===Introduction===

==Introduction==

In the European Union, pet food labelling is mainly governed by Regulation (EC) No 767/2009 on the Marketing and Use of Feed. This Regulation sets out the rules for feed designed for both food-producing and non-food producing animals, including requirements for labelling, packaging and product claims. Regulation 767/2009 also provides a framework for the establishment and labelling of feed intended for particular nutritional purposes (dietetic feeds).  

In the European Union, pet food labelling is mainly governed by Regulation (EC) No 767/2009 on the Marketing and Use of Feed. This Regulation sets out the rules for feed designed for both food-producing and non-food producing animals, including requirements for labelling, packaging and product claims. Regulation 767/2009 also provides a framework for the establishment and labelling of feed intended for particular nutritional purposes (dietetic feeds).  

 

== Definitions ==

=== Definitions ===

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

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

'''(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. <br>

'''(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. <br>

Definition (i) does not provide any recommendation for nutrient levels that would be appropriate for a feed to be considered ‘complete’.  FEDIAF’s Nutritional Guidelines list on [http://www.fediaf.org/self-regulation/nutrition/ minimum recommended nutrient levels] for commercial pet foods can be used as a guidance document to determine whether or not a pet food is complete for healthy dogs and cats.

Definition (i) does not provide any recommendation for nutrient levels that would be appropriate for a feed to be considered ‘complete’ - [http://www.fediaf.org/self-regulation/nutrition/ FEDIAF’s Nutritional Guidelines] list  minimum recommended nutrient levels for commercial pet foods and can be used as a guidance document to determine whether or not a pet food is complete for healthy dogs and cats.

=== Mandatory Declarations ===

== Mandatory Labelling Requirements ==

An example of a European label (in this case from the UK) is shown in Figure X. On the label, mandatory declarations should be easily identified and not obscured by any other information. The mandatory labelling particulars, sometimes referred to as the statutory statement, must be given in their entirety set in a prominent place on the packaging or label (Regulation 767/2009 Article 14). Mandatory information must be provided in at least one of the official languages of the Member States in which it is sold.

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

:'''2. Name and address of the feed business operator (company) responsible for the labelling.'''

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

:'''3. Approval or registration number(s), or, if not available, the address of the manufacturing plant.'''

*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.

::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.  

*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.  

====Batch Number====

:'''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.   

::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.   

====Net Quantity====

:'''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).   

::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)<ref>Directive 2009/34/EC of the European Parliament and of the CounciL of 23 April 2009 relating to common provisions for both measuring instruments and methods of metrological control OJ L106, 28/04/2009, p. 7-24.</ref>.   

====Minimum Storage Life====

:'''6. Minimum Storage Life'''

This may also be called an expiry date and requires a DD/MM/YYYY.

::This may also be called an expiry date and requires a DD/MM/YYYY.  

Animal species or category of animals for which the compound feed is intended E.g. adult cat, puppy etc.  

====Directions for Use====

:'''7. Animal species or category of animals for which the compound feed is intended'''

In practice these consist mainly of the feeding instructions, but it is not specified by law what is [[Feeding Guides - Nutrition|required as a minimum]]. This can also include storage instructions, especially once a pack is opened.

::E.g. adult cat, puppy etc.  

This is the list of feed materials (see details below).  

::In practice these consist mainly of the [[Feeding Guides - Nutrition|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.

This is the nutrient content of the feed. In Europe, the typical or proximate analysis has to be declared (see details below).  

::This is the list of feed materials ([[EU Pet Food Labels#Composition = List of Feed Materials|see details below]]).  

====Additives (see details below)====

::This is the nutrient content of the feed. In Europe, the typical or proximate analysis has to be declared ([[EU Pet Food Labels#Analytical Constituents|see details below]]).

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

::([[EU Pet Food Labels#Additives|see details below]])===

=== Derogation ===

== Derogation ==

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

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

*‘best before date’,  

*‘best before date’,  

   

   

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

== Composition = List of Feed Materials ==

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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<ref name="Burger">2. Burger IH. '''Reading a petfood label'''. Journal of Small Animal Practice 1993; 34: 189-191.</ref>. 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<ref name="Burger">2. Burger IH. '''Reading a petfood label'''. Journal of Small Animal Practice 1993; 34: 189-191.</ref>. 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).  

=== Analytical Constituents ===

== Analytical Constituents ==

Regulation 767/2009 requires that under “Analytical Constituents” of both complete and complementary feeds the typical analysis of nutrients must be declared. In Europe, the typical (proximate) analysis has to be declared. This is the typical nutrient level obtained by considering the results of analysis of several samples. In other words, the typical analysis gives the nutrient levels found in the actual food. The declaration of the following nutrients is mandatory for pet foods for dogs and cats:

Regulation 767/2009 requires that under “Analytical Constituents” of both complete and complementary feeds the typical analysis of nutrients must be declared. In Europe, the typical (proximate) analysis has to be declared. This is the typical nutrient level obtained by considering the results of analysis of several samples. In other words, the typical analysis gives the nutrient levels found in the actual food. The declaration of the following nutrients is mandatory for pet foods for dogs and cats:

* Crude Protein

:* Crude Protein

* Crude oils and fats

:* Crude oils and fats

* Crude fibre

:* Crude fibre

* Crude ash*

:* Crude ash*

* Moisture if >14%

:* Moisture if >14%

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”.

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".

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 important to recognise that this does not indicate ash was added to the food. 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 important to recognise that this does not indicate ash was added to the food. It is also permitted to call “ash”, “incinerated residue” or “inorganic matter”.

=== Additives ===

== Additives ==

Within the EU, Regulation (EC) No 1831/2003 on additives for use in animal nutrition provides for 4 categories of additives (1-4), each of which contain functional groups (Table 2). More categories may be added over time. Vitamins and trace elements are considered additives and, therefore, are not listed under composition.

Within the EU, Regulation (EC) No 1831/2003 on additives for use in animal nutrition provides for 4 categories of additives (1-4), each of which contain functional groups (Table 2). More categories may be added over time. Vitamins and trace elements are considered additives and, therefore, are not listed under composition.

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!colspan="2" bgcolor="#97C7F7"|Table 2 - Categories (1-4) and examples of functional groups of additives.

!colspan="2" bgcolor="#97C7F7"|Table 2 - Categories (1-4) and examples of functional groups of additives.

==== Which Additives Must Be Declared on the Label? ====

=== Which Additives Must Be Declared on the Label? ===

According to Regulation 767/2009, the following additives have to be declared if added by the manufacturer:

According to Regulation 767/2009, the following additives have to be declared if added by the manufacturer:

::* Any other additive if its presence is emphasized on the label, whether in words, picture or graphic.

::* Any other additive if its presence is emphasized on the label, whether in words, picture or graphic.

==== 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, 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.

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.

=== Particular Nutritional Purposes (PARNUT) ===

== Particular Nutritional Purposes (PARNUT) ==

'''PARNUT''' = Feeding stuffs for '''PAR'''ticular '''NUT'''ritional purposes

'''PARNUT''' = Feeding stuffs for '''PAR'''ticular '''NUT'''ritional purposes

==== What are Particular Nutritional Purposes? ====

=== What are Particular Nutritional Purposes? ===

A '''Particular Nutritional Purpose''' is intended to '''meet the specific nutritional needs of animals whose process of assimilation, absorption or metabolism is, or could be, temporarily or irreversibly impaired and who can, therefore, benefit from a feed that is adapted to the specific needs generated by their condition'''. The objective of the PARNUT legislation is to fill the gap between the legislation for feed for healthy animals, for which health claims are not permitted, and the legislation on medicated feed.

A '''Particular Nutritional Purpose''' is intended to '''meet the specific nutritional needs of animals whose process of assimilation, absorption or metabolism is, or could be, temporarily or irreversibly impaired and who can, therefore, benefit from a feed that is adapted to the specific needs generated by their condition'''. The objective of the PARNUT legislation is to fill the gap between the legislation for feed for healthy animals, for which health claims are not permitted, and the legislation on medicated feed.

The term ‘dietetic pet food’ (and its official translations) is the only term to be used to indicate that a product falls under this legislation. These label declarations apply in addition to rules already in place for regular pet food products.

The term ‘dietetic pet food’ (and its official translations) is the only term to be used to indicate that a product falls under this legislation. These label declarations apply in addition to rules already in place for regular pet food products.

==== Directive 2008/38/EC ====

=== Directive 2008/38/EC ===

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.

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.

==== How is it Decided Whether a Condition is a Nutritional Purpose and is Included in Directive 2008/38/EC? ====

=== How is it Decided Whether a Condition is a Nutritional Purpose and is Included in Directive 2008/38/EC? ===

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  

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  

#the indication matches the definition of PARNUT and  

#the indication matches the definition of PARNUT and  

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=== Claims ===

== Claims ==

Regulation 767/2009 states that the labelling and the presentation of feed shall not mislead the user, in particular:

Regulation 767/2009 states that the labelling and the presentation of feed shall not mislead the user, in particular:

Regulation 767/2009 provides for industry to develop Codes of Good Practice to encourage both self-regulation in areas where regulation is top-level or non-existent, and to help promote a “level playing-field” approach within the EU. To that end, FEDIAF have developed a Code of Good Labelling Practice for Pet Food Labelling that provides more detailed guidance on claims and claim substantiation, including the definition of specific terms such as “fresh”, “natural” etc. The Code also contains a layman’s section where the key elements of pet food labelling, and the legal requirements behind them, are explained. The current version of the Code was recognised by the EU Commission in 2011.

Regulation 767/2009 provides for industry to develop Codes of Good Practice to encourage both self-regulation in areas where regulation is top-level or non-existent, and to help promote a “level playing-field” approach within the EU. To that end, FEDIAF have developed a Code of Good Labelling Practice for Pet Food Labelling that provides more detailed guidance on claims and claim substantiation, including the definition of specific terms such as “fresh”, “natural” etc. The Code also contains a layman’s section where the key elements of pet food labelling, and the legal requirements behind them, are explained. The current version of the Code was recognised by the EU Commission in 2011.

=== Useful Websites ===

== Useful Websites ==

General:

General:

*[http://ec.europa.eu/food/safety/animal-feed/index_en.htm European Animal Feed Safety]

*[http://ec.europa.eu/food/safety/animal-feed/index_en.htm European Animal Feed Safety]

*[http://www.fediaf.org/self-regulation/labelling/ FEDIAF code of good labelling practice for pet food]

*[http://www.fediaf.org/self-regulation/labelling/ FEDIAF code of good labelling practice for pet food]

===References===

==References==

<references />

<references />

[[Category:To Do - Nutrition]]

[[Category:To Do - Nutrition]]

[[Category:Pet Food Labels]]

[[Category:Pet Food Labels]]