A new edition of the FEDIAF Labelling Code has been approved. This means many of our pet food and care clients will have to change their packaging labels by January 2020.
Pet food (like any other animal feed) needs to be labelled in accordance with the latest regulations. This ensures that consumers have clear, concise and honest information on the composition, characteristics and use of the product.
The FEDIAF Labelling Code, effectively implemented and used by national authorities, is therefore also a tool to avoid misleading claims and to create a level playing field between industry operators.
If you haven’t started working on artwork amendments, it’s time to get the ball rolling to ensure all pet food labels have been updated accordingly prior to the deadline.
The law requires that the label contains certain key pieces of information including:
• Name and Product Description
• Composition (ingredients list)
• Analytical Constituents (information about nutrient levels)
• Best Before Date and Batch Code
• Producer or Distributor Name (and how to contact them for further information)
• Feeding Instructions (how to use the product)
• Weight and/or Quantity
These mandatory labelling particulars have to be given in their entirety in a prominent place on the packaging.
They must be easily identifiable, not obscured by any other information and displayed in a colour, font and size that does not obscure or emphasize any part of the information (unless such variation is to draw attention to precautionary statements).
The description of the type of feed: “feed material”, “complete feed” or “complementary feed” must be stated as appropriate.
Complete means that the pet food provides all the nutrients your pet requires each day, when fed as instructed.
Complementary means that the food is either intended to be mixed with something else (e.g. a wet food mixed with a mixer biscuit); or it could be intended as a snack or treat for your pet, either to help maintain his well-being e.g. oral care treats, or as part of your daily interaction with your pet.
However, the words complete and complementary can be replaced by “compound” (except for cat and dog food).
Raw pet food must be labelled “pet food only”.
The target species or the category of animals should be clearly identifiable. This may also include an indication of the life stage of the animal, if appropriate.
Instructions for Proper Use
Packaging must indicate the necessity to ensure fresh water is available at all times when feeding dry food.
It is advisable to provide recommended storage conditions since climatic conditions may degrade the product quality. Consideration should be given to providing storage conditions for the product once opened.
The instructions for proper use should also indicate how to provide a daily ration in terms of amounts required to be fed relative to the life stage, the lifestyle and the size of the pet.
Feed Material Declaration
For compound feed for pet animals, the feed materials must be listed by specific name or category in descending order by weight, specific amounts in % may be indicated.
The heading “Composition” should appear before the list of feed materials and categories.
For feed for pet animals composed of only one feed material (chews, raw pet food…), the feed material must be indicated by its specific name (e.g. Pig ears)
For more information, including examples and explanations, see here.
Additives with a legal maximum level for any non-food-producing species have to be declared on pet food labels when they are added. Any other additives not having a legal maximum can be declared voluntarily when added.
The pet food label must specify vitamins/trace elements, functional groups and enzyme/micro-organisms if appropriate.
Only authorized additives for the relevant (or all) species are allowed to be used. [N.B. Additives are currently going through the European Commission reauthorisation process (which includes EFSA risk assessment). This must be considered when they are used for labelling and when establishing functional groups.]
Labelling specificities for additives are quite complex, visit here for more detailed information.
The heading “Analytical constituents” must appear before the list of the analytical constituents.
The moisture content must be stated if it exceeds:
• 7 % in case of milk replacer feeds and other compound feed with a milk product content exceeding 40 %
• 5 % in the case of mineral feed containing no organic substances
• 10 % in the case of mineral feed containing organic substances
• 14 % in the case of other feed.
The declaration is optional if the moisture content of the compound feed does not exceed the limits stated in the paragraphs above.
If the Ash insoluble in hydrochloric acid exceeds 2.2% of dry matter, it must be labelled.
For complete or complementary feed for pet animals other than cats and dogs’ analytical constituents may be labelled voluntarily.
Business Address & Details
The name or business name and the address of the feed business operator responsible for the labelling must be printed on pack.
Labelling the countries of production is voluntary.
For products manufactured in the EU, the labelling “Produced in the EU” is acceptable for all EU Member States.
On the label, a free telephone number or other appropriate means of communication (internet, e-mail address, postal address) should be indicated in order to allow the purchaser to obtain certain information in addition to the mandatory particulars.
Batch Code & Best Before Date
For traceability purposes, the batch and approval number of the producing establishment must be printed on pack with the business address.
The batch number can be numeric or alphanumeric and could, for example, be made up of the date/time of manufacture, shift number, line number or any other identifier allowing traceability.
Examples: Date/time: 02/04/14 15:26 Day of year, line: 283 CH6 Other: 55BX37B.
The batch number doesn’t need to appear in the space reserved for the labelling particulars. However, there must be an indication as to where it can be found. For example, ‘for batch number: see top of the can’.
The Best Before Date must be specified to tell the purchaser when the product will be “best” before. Although it isn’t necessarily harmful if consumed after this date, this is when the nutrients are guaranteed until.
Weight & Quantities
The net weight or volume expressed in units of mass in the case of solid products, and in units of mass or volume in the case of liquid products.
The expressions “net weight” or “net volume” before the numeric indications is not compulsory. Example: 420 g or net weight: 420 g
The character dimension in accordance with weights and net volumes must be as follows:
6 mm if the net quantity is greater than 1000 g or 1000 ml
4 mm if it is between 1000 g or 1000 ml and 200 g or 200 ml excluded
3 mm if it is between 200 g or 200 ml and 50 g or 50 ml excluded
2 mm if it is equal to or less than 50 g or 50 ml
The net quantity may be marked outside the space reserved for the labelling particulars: in this case the relevant expression must be accompanied by an indication of where the information appears.
The indication of the net weight for pet food products normally sold by units is not required if it is common trade practice; in this case the number of units must be labelled. Example: 5 pig ears
Dietic, Organic & GMO Pet Foods
Pet food produced from, consisting of or containing GMOs or derived from GMO products must be labelled.
Each feed material or additive of which a particular pet food is composed is subject to particular rules.
For dietetic pet food, additional indications must appear with the statutory indications on the packaging, the container or the label.
The rules for using the term “organic” apply to any term suggesting that the pet food is produced from or with organic components (e.g. “bio”, “biological”, “eco” etc).
Find out more about Dietic, Organic and GMO pet food labelling requirements here.
We know it’s a lot to remember, so if you’re changing your pet food labels, be sure to double check. You can click the checklist to the right to ensure you’ve covered everything.
Although new pet food labelling regulations means some work will be required, it’s a fantastic reason to refresh your brand. For instance, a survey of 2,000 British dog owners by Paws.com has revealed that 44% find dog food labels difficult and at times “impossible to read”. This is a great opportunity to ensure your labels are clearer for the consumer.