Additive and contaminant limits across seven jurisdictions
This is the second piece in the cross-border-compliance series. Where the first looked at how regimes licence the product, this one looks at how they police what goes into the bag — the additive side (what you may deliberately add) and the contaminant side (what must not be there, or must stay beneath a ceiling). Seven jurisdictions are in scope: Korea, Japan, Canada, the UK (retained EU law), France, Saudi Arabia, and Thailand, plus the broader US framework (GRAS + 21 CFR 573) and China's positive-list model for context. Australia is deliberately excluded — the AU cluster in this repo is veterinary-drug registration (APVMA PUBCRIS), not pet-food additive/contaminant law, so presenting it here would be misleading.
Two patterns emerge immediately. Some regimes run a positive list (you may use only what is explicitly authorised); others run a negative / undesirable-substance regime (everything is permitted unless it is banned or exceeds a limit). In practice most jurisdictions do both at once.
Additives: authorisation before the market
The EU/UK model is the clearest statement of the authorisation principle. "feed additives" means "substances, micro-organisms or preparations, other than feed material and premixtures, which are intentionally added to feed or water in order to perform, in particular, one or more of the functions" set out in the law. Under Regulation (EC) No 1831/2003, "any person using or placing on the market that substance... shall ensure that any conditions or restrictions which have been imposed on the placing on the market, use and handling of" the additive are respected — in other words, an additive may only appear once it is authorised, and the authorised conditions bind the user. (This is retained EU law, assimilated into Great Britain; the source is the eur-lex text, retrieved via local chromium — first-hand statute.)
France applies the same EU additive law nationally, but the on-disk source is the French Ministry of Agriculture's "Alimentation animale" presentation rather than the CELEX text itself. The substantive points match the EU definition verbatim in French: "Les additifs sont des substances, microorganismes ou préparations délibérément ajoutés aux aliments pour animaux ou à l'eau afin d'influencer favorablement les caractéristiques de l'aliment." Critically, France carries a prohibition that is not an EU-additive authorisation question at all but a banned use: "Depuis le 1er janvier 2006, l'utilisation d'antibiotiques comme additifs dans l'alimentation des animaux en vue de favoriser leur croissance ou d'augmenter leur rendement est interdite." The use of antibiotics as growth-promoting feed additives has been prohibited in France since 1 January 2006. Note on sourcing: the FR topic is a government-page paraphrase flagged needs_review: true, not the first-hand statute — the clause is quoted verbatim from agriculture.gouv.fr, but readers should treat it as a national paraphrase of EU/retained law, not as independent primary text.
China runs the positive-list model most explicitly. China's feed additive positive list is the Catalogue of Feed Additives (饲料添加剂品种目录) — the 2013 edition was issued as Ministry of Agriculture Announcement No. 2045 — together with the Feed Additive Safe Use Rules. GB 13078-2017 is the feed hygiene standard, not the additive list. The Pet Feed Administrative Measures (MOA Announcement No. 20, 2018) require pet feed producers to observe the 饲料添加剂品种目录 and prohibit producing pet food with any substance outside the 饲料原料目录/饲料添加剂品种目录; the same ban applies to sellers. A caveat worth stating plainly: the available corpus does not contain the catalogue's item-level entries, so specific additive permissions or maximum-use levels could not be verified from project sources.
The US splits the question across two authorities. FDA's Generally Recognized as Safe (GRAS) program for animal food under 21 CFR 570 and 21 CFR 582 establishes categories of substances permitted in pet food; GRAS status applies "when substance is generally recognized among qualified experts as safe under intended use conditions," and a manufacturer may self-affirm under 21 CFR 570.30 or use the voluntary GRN program (started 1997), from which FDA may issue a "no questions letter." Separately, 21 CFR 573 lists food additives permitted in animal feed and drinking water — the parsed corpus holds 69 sections — including antioxidants (573.380 ethoxyquin), amino-acid supplements (573.980 taurine), and preservatives (573.700 sodium nitrite). For any substance appearing in both 21 CFR 573 and 21 CFR 582, the additive-specific listing governs. (These US topics are prose summaries flagged needs_review: true; figures below are quoted verbatim from them.)
Contaminants: what must not be there
Korea's Feed Management Act draws the prohibited-feed line directly: makers, importers and sellers "may not manufacture, import, sell, or use as raw material any feed" that contains "harmful substances above the tolerance limit" or "veterinary drugs above the tolerance limit," or feed "contaminated by pathogens or markedly decayed/altered." The scope and tolerance limits for harmful substances and vet drugs "are set by Ministerial notice," and the MAFRA Minister "may limit the content of specific components in feed." This is first-hand statute (law.go.kr JSON).
Canada defines a "contaminant" as "any micro-organism, chemical substance, extraneous material or other substance that may present a risk of harm," including anything "not permitted under these Regulations or that does not comply with any limits or levels provided." "Medicated feed" means "a mixed feed that contains a medicating ingredient" — a veterinary-drug framing rather than an additive ceiling. First-hand server-rendered regulation text.
Saudi Arabia's Feed Act gives the broadest contaminant definition of the set: a "Contaminant" is "any substance – chemical (e.g.: heavy metals, dioxin, and pesticides) physical (e.g.: foreign objects, or insects) microbial (e.g.: Salmonella, Colon Bacteria), or aflatoxin and other." The Act imposes a duty to "comply with the maximum limits for feed additives as laid down in this Regulation," and SFDA "shall adopt maximum limits for feed additives." Medicated or growth-promoting feed ingredients "shall only" be used "by licensed" establishments using "only approved medications" and "only approved feed additives." (First-hand SFDA PDF, English translation — note the Act sets the framework; numeric limits live in SFDA technical standards.)
Japan's Pet Food Safety Act empowers the Ministers to set ingredient "specifications (成分につき規格)" and prohibits selling feed that does not conform; manufacturers/importers "may... prohibit" pet feed "containing, or suspected of containing, a harmful substance" or "contaminated by, or suspected of contamination by, a pathogenic microorganism." First-hand Japanese statute.
Mycotoxin and microbial data — folded in, not spun out
Coverage of mycotoxins and microbes is uneven across these seven, so rather than a separate article this material sits alongside the additive/contaminant line. The one hard numeric mycotoxin limit verified in the corpus is the US FDA aflatoxin action level. Under Compliance Policy Guide Sec. 683.100, "the action level for pets (dogs, cats, rabbits, etc.) OF ALL AGES is 20 ppb total aflatoxins" in corn, peanut products, cottonseed meal, other ingredients and complete pet food — there is no separate, higher puppy/kitten level. For contrast, livestock levels run higher: 300 ppb (corn/peanut products for finishing feedlot beef cattle), 200 ppb (corn/peanut for finishing swine), 100 ppb (corn/peanut for breeding beef cattle, breeding swine, mature poultry), with 20 ppb reserved for immature, dairy and unknown-use animals. The CPG also records that in 1998, 2005, 2011 and 2013 aflatoxin contamination of dog and cat food caused illness and recalls; the 2005 event was the Diamond Pet Foods recall, with at least 76 dogs believed to have died.
Beyond the US, mycotoxin/microbial material is mostly definitional rather than numeric. Saudi's contaminant definition explicitly names "aflatoxin," "Salmonella" and "Colon Bacteria." Canada's contaminant definition is built around the "micro-organism" concept. Japan prohibits feed "contaminated by... a pathogenic microorganism." This is the honest shape of the data: only the US supplies a verified numeric aflatoxin ceiling; the other regimes frame the hazard (microbe, aflatoxin) in their contaminant definitions but leave the numbers to subordinate standards not present in this corpus.
Thailand's contribution is also a contaminant-boundary story, but an animal-health one: "Importation of poultry meal, poultry by-products meal and feather meal as raw materials for animal feed or of animal feed containing poultry meal, poultry by-product meal and feather meal ingredients from a country with suspected outbreak of highly pathogenic avian influenza (HPAI) or an outbreak reported by the World Organization for Animal Health (OIE) within 12 months of the last HP AI outbreak is prohibited," and BSE-risk cattle-derived feed "must comply with the rules and conditions notified by the DG of the DLD." "Especially controlled animal feeds" (meat meal, meat and bone meal, poultry meal and others) "require to have a production facility audit and approval prior to importation." Sourcing caveat: the Thai primary statute (Animal Feed Control Act B.E. 2558 / 2015) was unreachable for direct extraction; these claims are verbatim substrings of the DLD AFVC official report on disk, which reproduces the DLD's own B.E. 2560 (2017) notifications. Treat as first-hand DLD provenance, not as the primary Act.
What this map does and does not show
Seven regimes, two logics. The additive side is dominated by prior-authorisation (EU/UK, France, China positive list, US GRAS/573). The contaminant side is dominated by banned-substance and ceiling language, with most numeric ceilings delegated to subordinate ministerial standards. The mycotoxin and microbial layer is real but thin: a verified 20 ppb aflatoxin action level for US pet food of all ages, plus definitional mentions of aflatoxin and Salmonella elsewhere, and little else numeric.
Two requested source topics were not on disk and therefore contribute nothing here: eu_reg_1831_2003_article_6_categories_functional_groups (the EU additive functional-group categories) and fda_oasis_refusals_chemical_contaminants_mycotoxins_histamine_2026 (refusal-line data). Their absence is why this article does not enumerate EU functional groups or US import-refusal figures.
Sources
All factual claims are verbatim substrings of the topic files named in frontmatter. First-handness by jurisdiction:
- Korea —
KR_FEED_ADDITIVES_CONTAMINANTS: first-hand statute (law.go.kr DRF JSON, Act Arts 14–15). - Japan —
JP_FEED_ADDITIVES_CONTAMINANTS: first-hand statute (e-Gov lawid 420AC0000000083, Tokyo relay). - Canada —
CA_FEED_ADDITIVES_CONTAMINANTS: first-hand regulation (SOR/2024-132, server-rendered). - UK —
UK_FEED_ADDITIVES_CONTAMINANTS: first-hand regulation (eur-lex CELEX 32003R1831 / 32011R0574, retained EU law). - France —
FR_FEED_ADDITIVES_CONTAMINANTS: paraphrase of government page (agriculture.gouv.fr,needs_review: true); French clauses quoted verbatim but not primary statute. - Saudi Arabia —
SA_FEED_ADDITIVES_CONTAMINANTS: first-hand regulation (SFDA Feed Act PDF, English translation). - Thailand —
TH_FEED_ADDITIVES_CONTAMINANTS: first-hand DLD provenance via official report reproducing B.E. 2560 notifications; primary statute was blocked (needs_review: true). - China —
CN_pet_food_additives_positive_list: prose summary (needs_review: true); no item-level entries verified. - US GRAS —
FDA_GRAS_main_program_overview: prose summary (needs_review: true). - US 21 CFR 573 —
ECFR_pet_food_additive_CFR573: prose summary (needs_review: true). - US aflatoxin CPG —
ECFR_pet_food_aflatoxin_CPG_555: prose summary (needs_review: true); 20 ppb figure verbatim.
Missing on disk (no contribution): eu_reg_1831_2003_article_6_categories_functional_groups, fda_oasis_refusals_chemical_contaminants_mycotoxins_histamine_2026.
Excluded by design: Australia — the AU cluster here is veterinary-drug registration (APVMA PUBCRIS), not pet-food additive/contaminant law.