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EU pet-food labelling under Regulation (EC) No 767/2009

Regulation (EC) No 767/2009 of 13 July 2009 governs the placing on the market and use of feed in the EU, and it is one of the core texts behind what a European pet-food label must carry. Two provisions matter most for pet food: Article 19 (additional mandatory labelling for pet food) and the Article 3 definitions of "complete feed" and "complementary feed."

Article 19 โ€” the pet-food-specific extra

On top of the general mandatory particulars in Articles 15, 16 and 17, Article 19 requires that on the label of pet food a free telephone number or other appropriate communication channel shall be indicated, enabling the purchaser to obtain, in addition to those particulars:

  • (a) the feed additives contained in the pet food; and
  • further details about those additives.

In other words, EU pet food must carry a way for a buyer to reach the responsible party and learn exactly which feed additives are present. This sits on top of Reg 1831/2003, which decides whether an additive may be used in pet food (it must be on the EU Register of Feed Additives); Article 19 decides whether additives actually used must be disclosed on the label.

Article 3 โ€” "complete" vs "complementary"

The regulation's definitions govern two everyday label claims:

  • "complete feed" means compound feed which, by reason of its composition, is sufficient for a daily ration.
  • "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.

A "complete" pet food is formulated to be the sole diet; a "complementary" one must be fed alongside other feed. Calling a complementary feed "complete" would be a labelling violation under this regulation.

Why it matters

For anyone comparing labels across borders: the EU's legal split between complete and complementary feed, plus the Article 19 additive-disclosure and free-contact requirements, is a distinctly European layer. Other jurisdictions (e.g. China's GB/T 31216/31217 "complete pet food" national standards, and AAFCO's "complete and balanced" framing) use parallel but separately-defined concepts โ€” see the companion articles on complete/complementary definitions and China's import registration.

Sources

  • eu_reg_767_2009_article_19_pet_food_labelling โ€” Reg 767/2009 Article 19 verbatim: free telephone / communication channel + feed-additive disclosure on pet-food labels; linkage to Reg 1831/2003.
  • label_claim_eu_complete_complementary_feed โ€” Article 3 definitions of "complete feed" and "complementary feed" (C1 verbatim from EUR-Lex).

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