FOREIGN AGRICULTURAL SERVICE
U.S. MISSION TO THE EUROPEAN UNION

Last update:  July 19, 2007

Home  |  A-Z Index   |  Mission |  Staff  |  FAS Offices in the EU  |  Euro Exchange Rates

Exporter Guides  |  Finding EU Legislation  |  Links to EU & US Websites  |  Tips for Travelers 

  Pet Food

EU Pet food Legislation

All pet food imported from the U.S. into the European Union has to meet requirements relating mainly to health and labeling aspects.  These requirements are generally harmonized throughout the 27 EU member states but they are scattered over different pieces of EU legislation.
 

bullet

Petfood Certification Requirements

bullet

Petfood Ingredient Requirements

bullet

Petfood Labeling Requirements

bullet

Genetically Modified Feed

bullet

New Requirements

bullet

Info on Member State Requirements

 Current Requirements: Certificates, Ingredients, Labeling

 Pet Food Certification Requirements

Health Certificates and APHIS Establishment Inspection

A health certificate has to accompany each individual pet food shipment containing product of animal origin.  Following the implementation of the EU animal by-products regulation 1774/2002, new certificates have been introduced on June 15, 2004.  The animal health and/or public health certificates signed by Animal and Plant Health Inspection Service officials serve as a guarantee that individual lots or shipments of products meet EU health requirements. Establishments that wish to export to the EU have to request inspection of an APHIS field office  and get an APHIS approval number for export to the EU.  APHIS veterinary services will endorse certificates after facilities have been officially approved as compliant with animal by-products regulation 1774/2002.  This approval number will also be put on the certificate.  A statement guaranteeing that SRM’s (specified risk materials) have been removed needs to be added to the certificate.  As a number of issues related to the implementation of regulation 1774/2002 are still unresolved, exporters are advised to regularly check the APHIS website.

The APHIS website provides Specimen Health Certificates for:

- Animal by-products for the manufacture of pet food
- Digests for pet food flavoring
- Dog chews
- Pet food other than canned
- Canned pet food
-
Raw or raw animal by-products to be fed to fur animals

Additional information can also be obtained from the APHIS headquarters:

ANIMAL AND PLANT HEALTH INSPECTION SERVICE
National Center for Import and Export
Technical Trade Services
Animal Products Staff Import/Export Animals Staff
Tel: (301) 734 8364
Fax: (301) 734 8226

  Pet food Ingredient Requirements

A. Authorized Ingredients and Additives

In the EU, there is no positive list of ingredients that can be used in pet food. All additives authorized for use in petfood are included in the Community Register for Feed Additives.

B. Prohibited Waste

Several ingredients are prohibited in feed.  For a long time, several types of industrial and household waste have been prohibited.  These ingredients are listed in Decision 2004/217/EC, and have not been an issue for the pet food industry.

C. Animal By-Products

European Parliament and Council Regulation 1774/2002 establishes the health rules concerning animal by-products not intended for human consumption and replaces Directive 90/667/EEC.  This regulation as well as the TSE regulation was developed in response to the BSE crisis and is part of the EU's strategy to eradicate food-borne crises.  The animal by-products regulation covers all animal products not intended for human consumption, and as such covers both products for technical uses and animal by-products used in the production of feeds and pet food.  This regulation requires that animal by-products used in the production of feeds and pet food be derived from the carcasses of animal declared fit for human consumption following veterinary inspection (category 3 products in the regulation).  Provisions include a ban on intra-species recycling and fallen stock and restrictions on yellow grease.  Certain categories of pet food have to be denatured with specified substances.  Pet food plants have to be dedicated to production of product fit for human consumption. Petfood containing animal by-products have to be labeled "Not for human consumption" as required by the health certificates provided under the section "Health Certificates and APHIS Establishment Inspection. " More...

The following issues covered have practical consequences for the U.S. petfood exports to the EU:

  • Fit for human consumption: all ingredients used for the manufacture of petfood have to be "fit for human consumption" according to EU standards.  Only animals declared healthy after ante- and post-mortem examination qualify as ingredients for petfood.  Fallen stock is banned.

  • Registration:  pet food and rendering plants have to be registered by and approved by the "third country competent authority", in this case APHIS, as complying with EU requirements.  EU requirements include regular inspection by the competent authority, mandatory record keeping and salmonella and enterobacteriacea testing.  Only products from companies on the approved establishments list can pass border control into the EU.

  • Segregation:  plants manufacturing and storing pet food are not allowed to manufacture and store animal by-products that do not fulfill EU pet food requirements.

  • Raw pet food:  has to be labeled "pet food only"

  • Denaturing:  raw material for the manufacture of pet food has to be marked permanently by charcoal. 

D. Specified Risk Materials

U.S. Petfood certificates currently have to include a statement certifying that SRMs (specified risk materials) have been removed.  The Commission has prolonged this transitional measure until July 2007.  The two year extension is designed for the Commission to continue its attempt to reach an agreement at international level (OIE) on the determination of BSE status of countries on the basis of risk.  The decision on the final BSE category will determine whether the U.S. will have to continue to remove SRM’s from pet food. 

  Pet food Labeling Requirements

  A. General Requirements

General labeling requirements for pet food are established in Council Directive 79/373/EEC.  In addition, labeling requirements for petfood containing additives are included in article 16 of Directive 70/524/EEC.  These rules remain in force despite the new EU regulation on additives on feedingstuffs (Regulation 1831/2003) that required the establishment of a Community Register of Feed Additives.

The general rules allow multi-language labels but at the same time requires that the label be at least in the language of the country in which the product is sold.  In practice, countries apply the following language requirements:
 

Austria: German
Belgium:  Dutch AND French, German recommended
Czech Republic: Czech
Denmark:  Danish
Estonia: Estonian
Finland:  Finnish
France:  French
Germany & Austria:  German
Greece:  Greek
Hungary: Hungarian
Italy:  Italian
Latvia: Latvian

Lithuania: Lithuanian
Luxembourg:  French OR German (or regional language Luxemburgian)
Malta: English OR Maltese OR Italian
Netherlands:  Dutch
Poland: Polish
Portugal:  Portuguese
Slovakia: Slovak
Slovenia: Slovene
Spain:  Spanish
Sweden:  Swedish
U.K. & Ireland:  British English


Detailed requirements:

Compulsory Information

Listing of the following information is compulsory. It shall be shown in a space on the packaging, on the container or on a label attached to it.

  • Description of the petfood and the species or category of animal for which the petfood is intended. e.g. "Complete feedingstuff for cats". Definitions of "complete feedingstuffs", "complementary feedingstuffs" and "mineral feedingstuffs" are given below.

"Complete feedingstuff or "complete petfood": Mixture that is sufficient for a daily ration because of its composition. In other EU languages:

"Kompletními krmivy" (Czech)
"Fuldfoder" (Danish)

"Volledig diervoeder" or "volledig samengesteld voeder" (Dutch)

"Täissööt" (Estonian)
"Täysrehu" (Finnish)
"Aliment complet" (French)

"Alleinfuttermittel" (German)
"πλήρεις τροφές
" (Greek)
"Mangime completo" (Italian)
"Teljes értékű takarmányok" (Hungarian)

"Kompleksā barība" (Latvian)
"Visaverčiai pašarai" (Lithuanian)
"Għalf sħiħ" (Maltese)
"Alimento completo" (Portuguese)
"Mieszanki paszowe pełnoporcjowe" (Polish)
"Kompletné krmivá" (Slovak)
"Popolne krmne mešanice" (Slovene)
"Pienso completo" or "Alimento completo" (Spanish)
"Helfoder" (Swedish)
 


"Complementary feedingstuff or "complementary petfood": Mixture which has a high content of certain substances. Because of its composition this is only sufficient for a daily ration if used in combination with other feedingstuffs. In other EU languages:

"Doplňkovými krmivy" (Czech)
"Tilskudsfoder" (Danish)
"Aanvullend diervoeder" or "aanvullend samengesteld voeder" (Dutch)
"Täiendsööt" (Estonian)
"Täydennysrehu" (Finnish)
"Aliment complémentaire" (French)
"Ergänzungsfuttermittel" (German)
"συμπληρωματικές ζωοτροφές" (Greek)
"Mangime complementare" (Italian)
"Kiegészítő takarmányok" (Hungarian)


"Papildu barība" (Latvian)
"Pašarų papildai" (Lithuanian)
"Għalf kumplimentari" (Maltese)
"Alimento complementar" (Portuguese)
"Mieszanki paszowe uzupełniające" (Polish)
"Doplnkové krmivá" (Slovak)
"Dopolnilne krmne mešanice" (Slovene)
"Pienso complementario" or "Alimento complementario" (Spanish)
"Kompletteringsfoder" (Swedish)
 

"Mineral Feedingstuff": Complementary feedingstuffs composed mainly of minerals and containing at least 40 % crude ash. In other EU languages:

"Minerálními krmivy" (Czech)
"Mineralsk foder" (Danish)
"Mineraalmengsel" (Dutch)
"Mineraalsööt" (Estonian)
"Kivennäisrehu" (Finnish)
"Aliment minéral" (French)
"Mineralfuttermittel" (German)
"ανόργανες τροφές" (Greek)
"Mangime minerale" (Italian)
"Ásványi takarmányok" (Hungarian)

"Minerālbarība" (Latvian)
"Mineraliniai pašarai" (Lithuanian)
"Għalf minerali" (Maltese)
"Alimento mineral" (Portuguese)
"Mieszanki mineralne" (Polish)
"Minerálne krmivá" (Slovak)
"Mineralne mešanice" (Slovene)
"Pienso mineral" or "Alimento mineral" (Spanish)
"Mineralfoder" (Swedish)

 
  • Directions for proper use

  • Listing of all ingredients indicating the amount contained or in descending order by weight

Or
Listing of the ingredient categories, whereby the following category indications may be used: meat and animal derivatives, milk and milk derivatives, eggs and egg derivatives, oils and fats, yeasts, fish and fish derivatives, cereals, vegetables, derivatives of vegetable origin, vegetable protein extracts, minerals, various sugars, fruit, nuts, seeds, algae, molluscs and crustaceans, insects, bakery products
  • Listing of additives.

It is compulsory to list antioxidants, colorants and preservatives using respectively the words "with antioxidant", "Colorant" or "colored with", "preservative" or "preserved with" followed by the specific name of the additive provided in the list of approved additives or, under certain conditions followed by "EC additives". It is also compulsory to label the presence of vitamins E, A and D and copper and their levels. Labeling of other trace elements and vitamins including their levels may be done, provided the levels can be determined by valid scientific methods of analysis. Labeling of other additives from the approved list such as aromatic and appetizing substances, emulsifiers, stabilizers, thickeners and gelling agents, acidity regulators is optional.

In case Copper, Selenium, vitamin A & D are added, the manufacturer/dealer has to be registered and the registration number has to be mentioned on the label.

All "technical proteins", such as yeasts need to be listed.

  • Claims:

The labeling of petfood may also draw attention by a specific declaration to the presence or low content of one or more ingredients, which are essential for characterizing the petfood. In such a case, the minimum or maximum content, expressed in terms of percentage by weight of the ingredient(s) incorporated, shall be clearly indicated:

* either next to the declaration drawing special attention to the ingredient.

* or in the ingredient list by mentioning the name of the ingredient or ingredient category and the corresponding percentage(s) by weight.

Labeling may not be misleading, in particular by attributing to the feedingstuff effects or properties that it does not possess or by suggesting that it possesses special characteristics when in fact all similar feedingstuffs possess such characteristics. Claims that the feedingstuff will prevent, treat or cure a disease are prohibited.

  • Declaration of analytical constituents

Indication of the moisture content is compulsory if it exceeds:

* 5 pct in the case of mineral feedingstuffs containing no organic substances.
* 10 pct in the case of mineral feedingstuffs containing organic substances.
* 14 pct in the case of other compound feedingstuffs.
In other cases, declaration of the moisture content is optional.

Indication of the ash content of non-mineral feedingstuffs is optional. It has to be below 2.2 pct. Declaration of ash content is compulsory in mineral feedingstuffs.
Compulsory declaration of crude protein, crude fiber, crude ash, crude oils and fats in complete and complementary dog and catfood.
Compulsory declaration of calcium, phosphorus and sodium in complementary mineral feedingstuffs for all species.

  • The name or business name and the address or registered place of business of the person responsible for the information on the label.

  • Container Contents

The net quantity expressed in units of mass (kg or g) in the case of solid products, and in units of mass (kg or g) or volume (l, cl, ml) in the case of liquid products. Metric units are compulsory. Metric and imperial units may be used on the same label.

To benefit from free movement within the EU, it is advisable to apply the voluntary standard on the maximum tolerable error between the actual content and the quantity indicated on the label, and on the size of the figures indicating the quantity. A small "e" of at least 3 mm on the label may be used to guarantee that the actual content corresponds to the quantity indicated. The size of the figures indicating the quantity depends on the nominal quantity: nominal quantity greater than 1000 g or 100 cl: at least 6 mm high; greater than 200 g/20 cl but less than 1000 g/100 cl: at least 4 mm; greater than 50 g/5 cl but less than 200 g/20 cl: at least 3 mm; less than 50 g/2 cl: 2 mm. The size is followed by the unit of measurement.

Manufacturers may decide to mark the net quantity outside the space on the packaging, on the container or label where all other compulsory information is provided. In that case, an indication shall be given of where this information appears.

  • The shelf life is indicated by the words "Use before..." followed by the date (day, month and year) in the case of microbiologically highly perishable petfood or "Best before.." followed by the date (month and year) in the case of other petfood.

Manufacturers may decide to mark the shelf life outside the space on the packaging, on the container or label where all other compulsory information is provided. In that case, an indication shall be given of where this information appears.

  • The batch reference number

Manufacturers may decide to mark the batch reference number outside the space on the packaging, on the container or label where all other compulsory information is provided. In that case, an indication shall be given of where this information appears.

 

  • Optional Information

In addition to the compulsory information mentioned above, only the following information may be put in the space on the packaging, on the container or on a label attached to it:

  • Identification mark or trade mark of the person responsible for the information on the label

  • The name or business name and the address or registered place of business of the manufacturer, if this is not the person responsible for the information on the label

  • The country of production or manufacture

  • The price of the product

  • The description or trade name of the product

  • An indication of the processing the petfood has undergone

  • In petfoods for which the above specified compulsory analytical constituent declaration does not apply, an analytical declaration of ingredients is optional

  • The date of manufacture to be indicated as follows:
    "manufactured...[days, months or year(s)] before the minimum storage life expiry date indicated"

  B. Requirements for Petfood for Particular Nutritional Purposes

Council Directive 93/74/EEC on petfood for particular nutritional purposes covers e.g. cat and dogfood intended for animals with insufficient renal or liver functions. In addition to the general labeling requirements, specific labeling information is provided:

  • Compulsory Information

  • The expression "dietetic" together with the description of the petfood.

  • Particular nutritional purpose. For each of the particular nutritional purpose defined in Council Directive 94/39/EEC the corresponding:
    * indication of the essential nutritional characteristics
    * labeling declaration
    * recommended length of use
    * other provisions

The following particular nutritional uses are listed:

* Support of renal function in case of chronic renal insufficiency
* Dissolution of struvite stones
* Reduction of struvite stone recurrence
* Reduction of urate stone formation
* Reduction of oxalate stones formation
* Reduction of cystine stones formation
* Reduction of ingredient and nutrient intolerances
* Reduction of acute intestinal absorptive disorders
* Compensation for maldigestion
 

* Support of heart function in case of chronic cardiac insufficiency
* Regulation of glucose supply
* Support of liver function in case of chronic liver insufficiency
* Regulation of lipid metabolism in case of hyperlipidaemia
* Reduction of copper in the liver
* Reduction of excessive body weight
* Nutritional restoration, convalescence
* Support of skin function in case of dermatosis and excessive loss of hair
 
  • The indication: "It is recommended that a specialist’s (or in some cases veterinarian’s) opinion be sought before use"

  • Voluntary Information
  • A reference to a specific pathological condition if this corresponds to the particular nutritional purpose of the petfood

  • The labeling may highlight the presence or low level of certain analytical constituents essential for the description of the petfood. In this case, the minimum or maximum level of the analytical constituent expressed as percentage weight must be indicated in the list of declared analytical constituents.

  C. Other EU Requirements

Wooden pallets used to transport goods from the U.S. to the EU have to comply with measures adopted by the EU requiring the treatment and marking of all new and used coniferous mon-manufactured wood packing material originating in the U.S., Canada, China and Japan to prevent the introduction of pinewood nematode.  Information on the programs developed to comply with these measures is available from the APHIS website.

  Genetically Modified Feed

On April 18, 2004, the EU implemented the regulations on “Genetically Modified Food and Feed” (European Parliament and Council Regulation 1829/2003) and “Traceability and Labeling of Genetically Modified Organisms and the Traceability of Food and Feed Products produced from Genetically Modified Organisms” (European Parliament and Council Regulation 1830/2003).  These new regulations repeal three of the four regulations previously in force:  Regulation 1139/98 on the labeling of foodstuffs derived from Round-Up Ready soybeans and Novartis Bt-176 corn, Regulation 49/2000 on adventitious contamination and Regulation 50/2000 on genetically modified additives and flavorings.   

The new regulations set up an EU system to trace GMOs, introduce the labeling of GM feed, reinforce the existing labeling rules for GM food and establish an authorization procedure for GMOs in food and feed and their deliberate release into the environment.  Both regulations have two-year review clauses, which require the Commission to report on their implementation and make recommendations for changes, if appropriate.  Recommended changes must be approved by the Council and the European Parliament.  Commission Regulation 641/2004 lays down implementing rules for the authorization of GM food and feed under Regulation 1829/2003.  It clarifies what information and data have to be provided to support applications for the authorization of new GM food and feed and the notification of existing products.

For more information see our webpage on GMO's.

  New Requirements

Traceability / Hygiene

Traceability for all food and feeds produced and imported in the EU became mandatory on January 1, 2005.

New rules on Feed Hygiene entered into force on January 1, 2006 and also cover vegetable origin feed. The legislation introduces compulsory registration of all feed business operators by the competent authority, while feed businesses dealing with more sensitive substances continue to require approval. Feed can only be imported from operators included in the yet to be established list of EU approved third countries. The feed hygiene legislation introduces HACCP principles for the feed business operators other than at the level of primary production. It also provides for a European Union framework for guides to good practice in feed.

For more information see our webpage on Food Safety.

  Info on Member State Requirements

The current EU legislation requirements apply in the 27 EU Member States. However, member States may also demand that additional requirements be met or may have their own requirements in areas where EU harmonization has not been concluded yet. For example, by including fats and gelatin, the French list of SRM’s is more extensive than the EU list. For Member State specific information, please contact our Offices of Agricultural Affairs in the individual EU countries.

 


Home