The central reference, for pet food sold in Europe, is Regulation (EC) No 767/2009 on the placing on the market and use of feed. This text sets out the general principles: information must be truthful, verifiable, understandable and not misleading; mandatory particulars must be shown in a visible, legible way and must not be hidden by other graphic elements; the operator responsible for the labelling must be able to substantiate the accuracy of what is declared. The European Commission also refers to the FEDIAF Code of Good Practice as an operational reference for a harmonised application of the rules in pet food.
The first point is the correct identification of the product. The type of feed must appear on the label: “complete feed” or “complementary feed”. Complete feed is feed which, by composition, is sufficient by itself to satisfy the daily ration; complementary feed, instead, has a high content of certain substances but, on its own, does not cover daily needs and must therefore be given together with other feeds. For pets other than dogs and cats, the wording “compound feed” can also be used, but for dogs and cats the distinction between complete and complementary remains the clearest reference.
Alongside the designation, the regulation requires a set of mandatory particulars: the name or business name and address of the operator responsible, any approval number of the establishment where applicable, the batch number, net quantity and, in the cases provided for, moisture content. Moisture must be declared when it exceeds 14% in other feeds, a threshold which in pet food in practice coincides with the practical distinction between dry products and wet or semi-moist products. Instructions for use for complementary feeds, especially when they contain additives above the maximum levels provided for complete feed, must state precisely the maximum quantity to be given in order to avoid exceedances in the daily ration.
A central point is composition. In pet food, the ingredient list appears under “composition” and can be presented in two ways: by using feed material categories, such as “meat and animal derivatives”, “cereals”, “derivatives of vegetable origin”, “oils and fats”, “minerals”, or by declaring individual feed materials, such as dehydrated chicken, maize, chicken fat, beet pulp, and so on. FEDIAF guidelines clarify that, for pet food products, feed materials may be indicated in descending order by weight at the time of formulation or with the quantitative indication of their content. This is a far from neutral choice, because it directly affects the technical readability of the label and the consistency between recipe, documentation and product positioning.
On this point it is important to avoid one of the most frequent ambiguities. The presence of a generic category does not necessarily mean lower quality, but a different declaration method permitted by the regulatory framework. At the same time, if the label highlights a specific feed material, its presence must be supported by a consistent declaration of the percentage. FEDIAF gives a very clear example: if the product refers to carrots, the label can state “carrots (4%)”, or “dried carrots (0.45%, equivalent to 4% carrots)”.
Immediately after come the analytical constituents. For dogs and cats, in complete feed and in non-mineral complementary feed, at least crude protein, crude oils and fats, crude fibre and crude ash must be declared; if moisture exceeds 14%, that must also be indicated. In pet food it is permitted to replace some more “laboratory-style” wordings with more readable terms: “crude protein” can become “protein”, “crude oils and fats” can become “fat content” or “fats”, and “crude ash” can be replaced by “incineration residue” or “inorganic matter”. “Ash”, therefore, is not an added ingredient: it represents the mineral residue that remains after product analysis.
For mineral complementary feeds, the set of analytical constituents changes: calcium, sodium and phosphorus must be declared. This serves to distinguish products that are not intended to be used as a complete food, but as mineral supplementation of the ration. Here too, the initial classification of the product has direct consequences on what must appear on the label.
The “additives” section requires specific attention. In EU law, additives are not the same as ingredients: they are substances, micro-organisms or preparations intentionally added to perform a specific function, and they are governed by Regulation (EC) No 1831/2003. They may belong, for example, to the category of nutritional, technological, sensory or zootechnical additives; in pet food, the most frequent ones are vitamins, trace elements, preservatives, antioxidants, colourants and flavourings. On the label they must appear under “additives”, with the name and/or identification number, the function or functional group and, in the cases provided for, the quantity added.
A practical distinction is important here. If, for example, vitamin E is naturally present in feed materials and is also added as an additive, the value shown under “additives” indicates the amount added in the recipe; if instead the vitamin is declared among the analytical constituents, that value represents the total content in the finished product, considered at the end of the shelf life.
Another element to handle rigorously is the graphic presentation of mandatory information. The regulation does not require only that it is present, but also that it is placed in an evident position, shown in full, clearly legible and not obscured by other elements. In practice, the front of pack can enhance the product, but it cannot compress or marginalise legal information. This also applies when using a QR code: digital content can extend information, link to technical sheets, instructions or further details, but it cannot replace mandatory particulars, which must remain on the package.