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==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<ref name = "Regulation 767">Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 1831/2003 and repealing Council Directive 79/373/EEC ... OJ. L229, 1/09/2009, p. 1-28. </ref>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<ref name = "Regulation 767" />, 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>
'''(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. <br>
'''(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. <br>
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.
Definition (i) does not provide any recommendation for nutrient levels that would be appropriate for a feed to be considered ‘complete’ - FEDIAF’s<ref>FEDIAF website: http://www.fediaf.org/ accessed May 2017</ref> [http://www.fediaf.org/self-regulation/nutrition/ 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 Declarations ==
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<ref>Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 1831/2003 and repealing Council Directive 79/373/EEC ... OJ. L229, 1/09/2009, p. 1-28.</ref>). Mandatory information must be provided in at least one of the official languages of the Member States in which it is sold.
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<ref name = "Regulation 767" />). Mandatory information must be provided in at least one of the official languages of the Member States in which it is sold.
== Mandatory Labelling Requirements ==
== 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:
Articles 15 to 20 state that the following particulars have to be declared in the '''statutory section''' of a pet food label:
:'''1. Complete Feed or Complementary Feed'''
:'''1. Complete Feed or Complementary Feed'''
:'''12. Additional Labelling Requirement'''
:'''12. Additional Labelling Requirement'''
::Pet food has an additional labelling requirement in Regulation 767/2009<ref>15. Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 1831/2003 and repealing Council Directive 79/373/EEC ... OJ. L229, 1/09/2009, p. 1-28.</ref>, 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 single feed material. (See[[Common Ingredients Used In Pet Food]]).
::Pet food has an additional labelling requirement in Regulation 767/2009<ref name = "Regulation 767" />, 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 single feed material. (See [[Common Ingredients Used In Pet Food]]).
== Derogation ==
== Derogation ==
*‘name and address of the feed business operator responsible for labelling’, and
*‘name and address of the feed business operator responsible for labelling’, and
*‘approval, registration number or address of manufacturing plant’.
*‘approval, registration number or address of manufacturing plant’.
In such cases it shall be pointed out in the statutory section where these particulars appear.
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 ==
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!colspan="1" bgcolor="#97C7F7"|Table 1 - List of [[Common Ingredients Used In Pet Food|ingredient categories]]:
!colspan="4" bgcolor="#97C7F7"|Table 1 - List of ingredient categories:
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!align="left" width="100%"|1. Meat and animal derivatives
!colspan="2" align="left" width="50%"|1. Meat and animal derivatives
!colspan="2" align="left" width="50%"|11. Minerals
|-
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!align="left" width="100%"|2. Milk and milk derivatives
!colspan="2" align="left" width="50%"|2. Milk and milk derivatives
!colspan="2" align="left" width="50%"|12. Various sugars
|-
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!align="left" width="100%"|3. Egg and egg derivatives
!colspan="2" align="left" width="50%"|3. Egg and egg derivatives
!colspan="2" align="left" width="50%"|13. Fruit
|-
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!align="left" width="100%"|4. Oils and fats
!colspan="2" align="left" width="50%"|4. Oils and fats
!colspan="2" align="left" width="50%"|14. Nuts
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!align="left" width="100%"|5. Yeasts
!colspan="2" align="left" width="50%"|5. Yeasts
!colspan="2" align="left" width="50%"|15. Seeds
|-
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!align="left" width="100%"|6. Fish and fish derivatives
!colspan="2" align="left" width="50%"|6. Fish and fish derivatives
!colspan="2" align="left" width="50%"|16. Algae
|-
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!align="left" width="100%"|7. Cereals
!colspan="2" align="left" width="50%"|7. Cereals
!colspan="2" align="left" width="50%"|17. Molluscs and crustaceans
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!align="left" width="100%"|8. Vegetables
!colspan="2" align="left" width="50%"|8. Vegetables
!colspan="2" align="left" width="50%"|18. Insects
|-
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!align="left" width="100%"|9. Derivatives of vegetable origin
!colspan="2" align="left" width="50%"|9. Derivatives of vegetable origin
!colspan="2" align="left" width="50%"|19. Bakery products
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!align="left" width="100%"|10. Vegetable and protein extracts
!colspan="2" align="left" width="50%"|10. Vegetable and protein extracts
!colspan="2" align="left" width="50%"|
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!align="left" width="100%"|11. Minerals
!colspan="4" align="center" |
|-
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!align="left" width="100%"|13. Fruit
!colspan="4" align="center" |
|-
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!align="left" width="100%"|14. Nuts
!colspan="4" align="center" bgcolor="#97C7F7"|Table 2 - Categories (1-4) and examples of functional groups of additives.
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!align="left" width="100%"|15. Seeds
!colspan="2" align="left" width="50%" bgcolor="#D9EAFA"|<i>1) Technological Additives</i>
!colspan="2" align="left" width="50%" bgcolor="#D9EAFA"|<i>3) Nutritional Additives</i>
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!align="left" width="100%"|16. Algae
!width="5%"|
!align="left" width="45%"|a. Preservatives
!width="5%"|
!align="left" width="45%"|a. Vitamins, pro-vitamins and chemically well-defined substances having a similar effect
|-
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!align="left" width="100%"|17. Molluscs and crustaceans
!width="5%"|
!align="left" width="45%"|b. Antioxidants
!width="5%"|
!align="left" width="45%"|b. Compounds of trace elements
|-
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!align="left" width="100%"|18. Insects
!width="5%"|
!align="left" width="45%"|c. Emulsifiers
!width="5%"|
!align="left" width="45%"|c. Amino acids, their salts and analogues
|-
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!align="left" width="100%"|19. Bakery products
!width="5%"|
!align="left" width="45%"|d. Stabilisers
!width="5%"|
!align="left" width="45%"|d. Urea and its derivatives
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!width="5%"|
!align="left" width="45%"|e. Thickeners
!colspan="2" align="left" width="50%" bgcolor="#D9EAFA"|<i>4) Zootechnical Additives</i>
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!width="5%"|
!align="left" width="45%"|f. Gelling agents
!width="5%"|
!align="left" width="45%"|a. Digestibility enhancers
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!width="5%"|
!align="left" width="45%"|e. Binders
!width="5%"|
!align="left" width="45%"|b. Gut flora stabilisers
|-
!colspan="2" align="left" width="50%" bgcolor="#D9EAFA"|<i>2) Sensory Additives</i>
!width="5%"|
!align="left" width="45%"|c. Coccidiostats and histomonostats
|-
!width="5%"|
!align="left" width="45%"|a. Colourants
!width="5%"|
!align="left" width="45%"|d. Other zootechnical additives
|-
!width="5%"|
!align="left" width="45%"|b. Flavouring compounds
!width="5%"|
!align="left" width="45%"|
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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).
[[Common Ingredients Used In Pet Food|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">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<ref name = "Regulation 767" /> requires that under “Analytical Constituents” of both <u><i>complete and complementary feeds</i></u> 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
== 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<ref name="Regulation 1831">Regulation (EC) No 1831/2003 of the European Parliament and of the Council of 22 September 2003 on additives for use in animal nutrition. OJ. L 268, 18/10/2003 p. 29-43.</ref> 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? ===
=== 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<ref name = "Regulation 767" />, 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 where a maximum content is set for any kind of target species (see [http://ec.europa.eu/food/safety/animal-feed/feed-additives/eu-register_en 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:
:* Additives belonging to the categories:
::* Zootechnical additives
:::* Zootechnical additives
::* Coccidiostats & histomonostats
:::* 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: ===
=== 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<ref name="Regulation 1831" /> as amended, E numbers are being replaced with new identification numbers.
=== Derogations ===
=== Derogations ===
== Particular Nutritional Purposes (PARNUT) ==
== Particular Nutritional Purposes (PARNUT) ==
'''PARNUT''' = Feeding stuffs for '''PAR'''ticular '''NUT'''ritional purposes
<center>'''PARNUT''' = Feeding stuffs for '''PAR'''ticular '''NUT'''ritional purposes</center>
Articles 9 & 10 of Regulation 767/2009<ref name = "Regulation 767" /> provide the basis for feeding stuffs intended for particular nutritional purposes, in other words [[Legal Definitions of Pet Food#Therapeutic/Dietetic Pet Food|''‘dietetic (pet) foods’'']]. Feed intended for particular nutritional purposes may only be marketed as such if the intended use (PARNUT indication) is included in the list of intended uses published in Directive 2008/38/EC<ref name="Directive 2008/38">Commission Directive 2008/38/EC of 5 March 2008 establishing a list of intended uses of animal feedingstuffs for particular nutritional purposes. OJ. L 62, 06 March 2008 p. 9-22</ref>, which establishes a list of intended uses of animal feeding stuffs for particular nutritional purposes.
=== What are Particular Nutritional Purposes? ===
=== What are Particular Nutritional Purposes? ===
=== 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<ref name="Directive 2008/38" /> 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.
<center>
<center>
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 4.
<center>
=== How is it Decided Whether a Condition is a Nutritional Purpose and is Included in Directive 2008/38/EC<ref name="Directive 2008/38" />? ===
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!colspan="2" bgcolor="#97C7F7"|Table 4. List of Particular Nutritional Purposes for Dogs and Cats.
!colspan="2" bgcolor="#97C7F7"|Table 4. List of Particular Nutritional Purposes for Dogs and Cats.
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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
#a diet with the proposed essential characteristics has a beneficial effect on the specific condition.
== Claims ==
== Claims ==
Regulation 767/2009 states that the labelling and the presentation of feed shall not mislead the user, in particular:
Regulation 767/2009 <ref name = "Regulation 767" />states that the labelling and the presentation of feed shall not mislead the user, in particular:
'''a.''' As to the intended use or characteristics of the feed, in particular, the nature, method of manufacture or production, properties, etc. (article 11).<br>
'''a.''' As to the intended use or characteristics of the feed, in particular, the nature, method of manufacture or production, properties, etc. (article 11).<br>
'''b.''' By attributing to the feed effects or characteristics that it does not possess or by suggesting that it possesses special characteristics when in fact all similar feeds possess such characteristics (article 11);<br>
'''b.''' By attributing to the feed effects or characteristics that it does not possess or by suggesting that it possesses special characteristics when in fact all similar feeds possess such characteristics (article 11);<br>
'''c.''' By claiming that it will prevent, treat or cure a disease (article 13). Such claims are considered medicinal and imply that the product is a medicinal drug and should comply with all regulations governing veterinary medicines.<br>
'''c.''' By claiming that it will prevent, treat or cure a disease (article 13). Such claims are considered medicinal and imply that the product is a medicinal drug and should comply with all regulations governing veterinary medicines.<br>
'''d.''' By claiming that it has particular nutritional purpose (PARNUT), but is not included in the list of permitted PARNUTS published in Directive 2008/38/EC (table 5) (article 13).<br>
'''d.''' By claiming that it has particular nutritional purpose (PARNUT), but is not included in the list of permitted PARNUTS published in Directive 2008/38/EC<ref name="Directive 2008/38" /> (table 5) (article 13).<br>
Any claim referring to the product must be substantiated, must not confuse or mislead purchasers and must not denigrate other pet foods.
Any claim referring to the product must be substantiated, must not confuse or mislead purchasers and must not denigrate other pet foods.
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 <ref name = "Regulation 767" />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 ==
*[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] accessed May 2017
*[http://eur-lex.europa.eu/advanced-search-form.html?qid=1440682264654&action=update Specific Legislation]
*[http://eur-lex.europa.eu/advanced-search-form.html?qid=1440682264654&action=update Search for specific legislation] accessed May 2017
*[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] accessed May 2017
==References==
==References==
|date = May 2017
|date = May 2017
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{{Mars Petcare}}
[[Category:To Do - Nutrition]]
[[Category:To Do - Nutrition]]
[[Category:Pet Food Labels]]
[[Category:Pet Food Labels]]