How to read a dog and cat food label: a guide to Regulation (EC) No 767/2009

Read a pet food label in a fixed order: first the type of feed (complete or complementary) and the species it is intended for, then the composition, the additives, the analytical constituents and the directions for use. All of these come from Regulation (EC) No 767/2009, which sets out across the European Union what must appear on the label of any feed, pet food included.¹ Knowing that order lets you work out in a few minutes what a product actually is and what it is for.

Does an online product description count as "labelling"?

Yes. The Regulation defines labelling broadly: attributing words, particulars, trade marks, brand names, pictorial matter or symbols to a feed by placing that information on any medium, such as packaging, a container, a notice, a label, a document "or the Internet".¹ It also separately defines the "label" (the description on the package itself) and "presentation" (the shape, appearance and packaging of the feed).¹

When feed is sold at a distance, the mandatory particulars must be available before the contract is concluded, and some of them (such as the batch number and net quantity) at the latest on delivery.¹ In practice, a product description on a website is subject to the same rules as the print on the bag.

Where should you start?

With the type of feed. Article 15 requires the label to state whether the product is a "feed material", a "complete feed" or a "complementary feed".¹ These terms are strictly defined:

• complete feed means compound feed which, by reason of its composition, is sufficient for a daily ration;¹
• complementary feed means compound feed which has a high content of certain substances but which, by reason of its composition, is sufficient for a daily ration only if used in combination with other feed.¹

For cats and dogs this distinction is compulsory; only for other pets may the shorter term "compound feed" be used instead.¹ So if a dog food says "complementary feed", it is not intended to be the animal's entire diet on its own.

The second thing to check is the species or category of animal the compound feed is intended for, which is also a mandatory particular.¹ A food labelled for cats need not meet a dog's needs, and vice versa.

How do you read the composition?

The list of feed materials appears under the heading "composition". Feed materials are listed in descending order by weight, calculated on the moisture content of the compound feed.¹ The first item is present in the largest amount, and each following one in a smaller amount.

A few rules help avoid misunderstandings:

• Percentages are not always given. The list "may include" the percentage by weight, but it does not have to.¹
• Highlighted ingredients need a percentage. If the label emphasises the presence of a feed material in words, pictures or graphics, its name and percentage by weight must be given.¹ If the pack shows a fish and talks about fish, the composition should say how much there is.
• Categories instead of names. In feed for non-food-producing animals, the specific name of a feed material may be replaced by the name of the category it belongs to.¹ That is why pet food compositions can contain general category terms rather than the name of a single raw material.

Practical guidance on how to phrase such descriptions (for example, what it means to highlight an ingredient in the product name) is given in the Code of Good Labelling Practice for Pet Food drawn up by FEDIAF, the European pet food industry federation.³ The Code is a self-regulatory tool: it helps interpret the law but does not replace it.³

What are "additives", and why do some have numbers?

Under the heading "additives", the label lists feed additives: substances, micro-organisms or preparations intentionally added to feed for specific purposes.¹² Additives fall into categories: technological, sensory, nutritional, zootechnical, and coccidiostats and histomonostats.² Within each category there are functional groups; zootechnical additives include, for example, "digestibility enhancers" and "gut flora stabilisers".²

In dog and cat food, some additives must be listed in detail: with their specific name or identification number, the amount added, and the name of the functional group or category. This applies, among others, to every additive in the "zootechnical additives" category and to additives for which a maximum content is set for at least one non-food-producing animal.¹

Preservatives, antioxidants, colourants and flavouring substances are treated differently: only the functional group has to be stated, and the person responsible for labelling discloses the details to the purchaser on request.¹ An additive's identification number can be looked up in the public European Union Register of Feed Additives maintained by the European Commission.⁴² We explain how to do that step by step in a separate article on the feed additives register.

What do the analytical constituents tell you?

Under the heading "analytical constituents", a complete feed for dogs and cats declares four values: crude protein, crude fibre, crude fat and crude ash.¹ The same set applies to complementary feed for dogs and cats, except mineral feed, which declares calcium, sodium and phosphorus instead.¹

Two things are worth keeping in mind. First, analytical constituents are the declared content of certain fractions in the finished food, not a list of raw materials: "crude ash" is not something added to the food but one of the four mandatory items in that declaration. Second, the label must also state the moisture content when it exceeds the thresholds set in Annex I; for most feed that threshold is 14%.¹ When comparing dry and wet foods, allow for the difference in moisture, because the same protein percentage means something different in a food with a lot of water and one with little.

What else must be on the label?

Besides the type of feed, composition, additives and analytical constituents, Articles 15 and 17 require, among other things:¹

• the name or business name and address of the feed business operator responsible for labelling;
• the establishment approval number, where available;
• the batch or lot reference number;
• the net quantity;
• directions for proper use indicating the purpose for which the feed is intended;
• the minimum storage life ("best before…", or "use before…" for highly perishable feed).

Pet food has one more requirement: the label must give a free telephone number or other appropriate means of communication so that the purchaser can obtain information, beyond the mandatory particulars, on the feed additives and on feed materials designated by category.¹ That is a good place to ask about details missing from the pack.

All mandatory particulars must be given in full in a conspicuous place, clearly legible and indelible, in at least one official language of the Member State or region where the feed is marketed, and must not be obscured by other information.¹

What can a label promise, and what can it not?

The labelling and presentation of feed must not mislead the user, for example as to its composition, properties or the species it is intended for, or by attributing to the feed effects or characteristics it does not possess.¹ Nor may a label suggest that a feed has special characteristics when all similar feeds have them.¹

Claims are allowed, but with conditions: they must be objective, verifiable by the competent authorities and understandable by the user, and the person responsible for labelling must provide scientific substantiation on request.¹ Claims concerning the optimisation of nutrition and the support or protection of physiological conditions are allowed.¹

The line is clear. Article 13(3)(a) states that labelling or presentation shall not claim that a feed "will prevent, treat or cure a disease" (except for authorised coccidiostats and histomonostats).¹

So if a pet food description promises an effect on a disease, something is wrong, either with the product or with the description. Questions about an animal's health are always best taken to a veterinarian.

What does "dietetic" on a label mean?

The word "dietetic" is reserved for feed intended for particular nutritional purposes.¹ Such a label must also carry the particulars laid down for that intended use in the EU list, and a recommendation to seek the opinion of a nutrition expert or a veterinarian before use or before extending the period of use.¹ A feed may not claim to satisfy a particular nutritional purpose on the list unless it meets the requirements set out there.¹

Step by step: reading a label in five minutes

1. Type of feed and species. Complete or complementary? For a dog, cat, puppy or kitten?¹
2. Directions for use. What is the feed for, and how should it be fed?¹
3. Composition. What is at the top? Do highlighted ingredients have a percentage?¹
4. Additives. Are there zootechnical additives, and what are their identification numbers? You can check the number in the EU Register.¹⁴
5. Analytical constituents and moisture. How much protein, fat, fibre and ash, and at what water content?¹
6. Operator, batch, date, contact. Who is responsible for labelling, when is it best used by, and where can you get more information?¹
7. Claims. Are they objective and understandable? Do they promise an effect on a disease?¹

A label cannot tell you whether a food suits a particular animal, its age, body weight, activity or state of health. That assessment is best made together with a veterinarian.

FAQ

What is the difference between complete and complementary pet food?

A complete feed is, by reason of its composition, sufficient for a daily ration. A complementary feed is sufficient for a daily ration only if used in combination with other feed. The type of feed is a mandatory label particular.¹

Does the order of the composition list mean anything?

Yes. Feed materials are listed under the heading "composition" in descending order by weight, so the first item is the one present in the largest amount.¹

What do the analytical constituents on the label mean?

They are the declared contents of crude protein, crude fibre, crude fat and crude ash. For dog and cat food this set is mandatory; it is not a list of the ingredients the food is made from.¹

Can a pet food label promise an effect on a disease?

No. Regulation 767/2009 excludes claims that a feed acts on a disease (apart from a narrow exception for coccidiostats and histomonostats). Such promises belong to medicinal products, not feed.¹

Where can I find information that is not on the label?

A pet food label must give a free telephone number or another appropriate means of communication for further information on the feed additives and on feed materials designated by category.¹

Sources

1. Regulation (EC) No 767/2009 on the placing on the market and use of feed (consolidated), Arts 3, 11, 13, 14, 15, 17, 18, 19, Annexes I and VII — https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02009R0767-20181226 2. Regulation (EC) No 1831/2003 on additives for use in animal nutrition (consolidated), Art. 6 and Annex I — https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02003R1831-20210327 3. FEDIAF — Code of Good Labelling Practice for Pet Food — https://europeanpetfood.org/self-regulation/labelling/ 4. European Commission — Feed additives (EU Register) — https://food.ec.europa.eu/food-safety/animal-feed/feed-additives_en