This will affect all pet food that is currently on sale in the UK and Europe - and may have significant commercial implications for all pet food businesses within the next 12 months.
You may be aware that new European legislation has been published that will affect how pet food is described: on-pack (labelling / Packaging) and off-pack (websites, advertising, POS etc).
Fediaf represents the national pet food industry association across the EU and are developing a code of practice. Only a draft is currently available. If you would like a copy of the draft - please email us. Please note, these notes are only guidance and should be read in conjunction with the relevant EU and national legislation. Any revised labels and changes should be submitted to your Trading Standards office in the usual way for approval.
There was a PFMA meeting in London on Monday 19th October, where the details were discussed. It is with great thanks to the PFMA and Fediaf that from that meeting we aim to share some of the key points and changes that are going to apply to your on-pack and off-pack communications if you sell pet food in the UK or EU.
Timescales
There are still some discussion taking place on some finer details, and a definitive document outlining the changes in legislation is expected April 2010. The new legislation will be applied from 1st September 2010. Early implementation is fine if you find an opportune time to change your packaging before September 2010. It is also suggested that any existing packaging and label stock can be used up reasonably, as long as you are able to demonstrate you have a plan in place for rolling out the new packaging into the market.
Label Checklist.
To help you amend your labels, there is a label checklist to guide you through the process.
What are the changes?
The full Fediaf code document should be consulted. Most changes relate to the information that appears within the statutory box.
To help, there is a mock-up of how the changes might affect a label, comparing old with new (download). In addition, the key changes are detailed below.
1. Composition (replacing ingredients)
Any list of feed materials must be headed 'composition' (and listed in descending order as usual).
Eg. Composition: chicken meal, rice, barley etc
2. Additives.
Any additive with a maximum limit for any species must be declared, even if it is a dog food, and the maximum limit relates to another animal.
The list of such additives with maximum limits which must be listed are found in Annex 9 (page 49-51) of the FEDIAF code.
If any of these ingredients are added to your diet, they must be listed, together with their added level in the diet.
When declaring the list of additives, they must be classified into one of the following functional groups or categories:
| Categories | Functional Groups |
| Technological additives | Preservatives; antioxidants, emulsifiers, stabilisers; thickeners; gelling agents; binders acidity regulators etc. |
| Sensory additives | Colourants; flavourings |
| Nutritional additives | Vitamins, minerals, trace elements, amino acids etc |
| Zootechnical additives | Digestibility enhancers |
| Coccidiostats & histomonostats | . |
NB: Pet Food benefits from a derogation relating to preservatives, antioxidants and colourants - in that only the functional group needs to be declared (and not the specific colourant, preservative or antioxidant).
Eg - A label might read:
Additives per Kg: colourants, preservatives, antioxidants. Nutritional additives: Vitamin D2 xy IU, Vitamin A xt IU etc.
i.e. The detail and type of colourant, preservative and antioxidant does not need to be declared
3. Analytical constituents (previously analysis or typical analysis)
This is the part of the label that advises the customer the analysis of the food. You must declare: Protein, oil, fibres, ash and moisture (if >14%).
The new terms for declaring these analytical constituents are:
- Protein or Crude Protein
- Crude Fibres (Must be plural)
- Crude oils and Fats or fat content
- Crude ash or incinerated residue or organic matter.
Vitamin and Mineral declaration of the final food does not need to be declared, but can be done so voluntarily, and must be valid for the duration of the best before date. Declared levels are also subject to tolerances, currently set by Feeding Stuff Regs 2005, but these tolerances may be reviewed by the April 2010 deadline.
If you do choose to list the Vitamin levels under 'Analytical Constituents', you will see different values, as vitamin levels in the finished product will be different to the vitamin levels declared under additives. This is because vitamins are lost during the manufacturing process. They may also be higher due to the occurrence of background vitamins present in the raw materials.
Voluntarily, you can also declare other nutrients (eg Taurine, calcium, phosphorus, magnesium) - all of which will be subjected to testing and verification if declared.
4. Other details required on the label:
a. Batch number - Printed on the packaging by the manufacturer at point of manufacture
b. Best Before Date - Printed on the packaging by the manufacturer at point of manufacture
c. Manufacturer Approval Number. Pre-printed on the packaging with the design, or printed on the packaging by the manufacturer at point of manufacture.
d. Name of business, address and contact details (tel no or email address)
e. Feeding guide
f. Storage details (i.e. store in a cool dry place)
g. Ensure a supply of clean, fresh water is always available.
h. If you choose to declare the Vitamins under analytical constituents - you will need to state: Vitamins guaranteed until best before date.
5. Accuracy of claims
The brand is responsible for labelling of their product.
Photography / imagery of ingredients on pack must be accurate and proportionate to the quality and inclusion of ingredients in the formulation
If you have any questions relating to the implications of the new code, or require any further details of how this will affect your brand, then please do email us directly. We will do our best to help you!
