Pet Food Labels - Nutrition

Introduction

A pet food label fulfils two main roles: 1) it is a document that delivers legally required information, which is important for control authorities and 2) it provides information to the purchaser about the product and the producing company.

Pet food differs from human food products in that the final consumer is not the purchaser. The information on the label is provided for pet owners, caretakers or veterinarians who may choose or recommend what the cat or dog is fed. The primary purpose of a label is to provide clear, accurate and honest information on the composition, characteristics and use of the pet food product. In many countries the information included on a pet food label and the way it appears are largely defined by legislation.

The following sections describe the way pet food is labelled in the European Union and in the United States. Specific pet food labelling legislation and guidelines also exist in many other countries around the world.

Europe

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 claims. Regulation 767/2009 also provides a framework for the establishment and labelling of feed intended for particular nutritional purposes (dietetic feeds).

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: (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. (d) Non-food producing animals: any animal that is fed, bred or kept but not used for human consumption, such as fur animals, pets and animals kept in laboratories, zoos or circuses. (i) Complete feed means a compound feed which, by reason of its composition, is sufficient for a daily ration. (j) Complementary feed means compound feed which has a high content of certain substances but which, by reason of its composition, is sufficient for a daily ration only if used in combination with other feeds. (s) Labelling means the attribution of any words, particulars, trademarks, brand name, pictorial matter or symbol to a feed by placing this information on any medium like packaging, container, notice, label, document, ring, collar or the internet referring to or accompanying such feed, including for advertising purposes. (t) Label means any tag, brand, mark, pictorial or descriptive matter, printed, stencilled, marked, embossed, impressed on, or attached to the packaging or the container, of feed. From definitions (c) and (d) of Article 3, companion animals such as horses, pet rabbits and (racing) pigeons are considered food-producing animals by the EU Commission and the national authorities of the EU Member States. 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 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. (link: http://www.fediaf.org/self-regulation/nutrition/)

Mandatory declarations

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 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 State in which it is sold.

Mandatory labelling requirements

Articles 15 to 20 state that the following particulars have to be declared in the statutory section of a pet food label: Complete feed or complementary feed 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 the food which it 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. Name and address of the feed business operator (company) responsible for the labelling. 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 that producer should be given. 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. 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 minimum storage life 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 In practice these consist mainly of the feeding instructions, but it is not specified by law what is required as a minimum (link to section on feeding guides). This can also include storage instructions, especially once a pack is opened. Composition This is the list of feed materials(see details below). Analytical constituents This is the nutrient content of the feed. In Europe, the typical or proximate analysis has to be declared (see details below). Additives(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 single feed material (link to section on ingredients in how pet food is made).

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.

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). Link to ingredients section in how pet food is made

Table 1: List of ingredient categories: 1. Meat and animal derivatives 2. Milk and milk derivatives 3. Egg and egg derivatives 4. Oils and fats 5. Yeasts 6. Fish and fish derivatives 7. Cereals 8. Vegetables 9. Derivatives of vegetable origin 10. Vegetable protein extracts 11. Minerals 12. Various sugars 13. Fruit 14. Nuts 15. Seeds 16. Algae 17. Molluscs and crustaceans 18. Insects 19. Bakery products

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:

• Crude Protein
• Crude oils and fats
• Crude fibre
• Crude ash*
• 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”.

In addition for pet food there is a derogation that permits “crude protein to be replaced by “protein” and “crude oils and fats” to be replaced by “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”.

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.

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:

• Additives where a maximum content is set for any kind of target species (see Register of additives for links to authorising legislation). This means that, for example, if an additive has a maximum inclusion level for calves, it has to be declared also on the label of cat foods, if added. This is because pet foods and livestock feed are regulated by the same legislation.
• Additives belonging to the categories
• Zootechnical additives
• Coccidiostats & histomonostats
• Additives belonging to the functional group ‘urea & derivatives’
• Any other additive if its presence is emphasized on the label, whether in words, picture or graphic.

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’.

• 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

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.