Prescription-diet regulation compared: EU PARNUT vs China/Korea/Canada claim rules

The word "prescription" on a pet-food bag is, in most jurisdictions, a marketing and distribution label rather than a distinct legal category. No regime surveyed here defines a "prescription diet" as a separately licensed medicine. What differs is whether a diet may be marketed for a disease-specific purpose: only the EU builds that into feed law via PARNUT, while China, Korea and Canada run general claim-management systems that forbid or never list such claims.

The EU: PARNUT as an explicit disease-specific list

The EU is the outlier because it codifies therapeutic-intent pet feeds in law. Commission Regulation (EU) 2020/354 of 4 March 2020 is "establishing a list of intended uses of feed intended for particular nutritional purposes and repealing Directive 2008/38/EC". "PARNUT" is industry shorthand for these diets for Particular Nutritional Purposes, sitting inside the Regulation (EC) No 767/2009 framework.

The Annex has Part A (general provisions) and Part B (the list of intended uses); each Part B entry specifies six columns: particular nutritional purpose, essential nutritional characteristics, species or category of animal, labelling declarations, recommended length of time for use, and other provisions. Feed may be marketed only if the intended use is included in Part B and the entry's provisions are complied with.

Part B contains exactly 44 entries: entries 10–30 cover companion animals (mainly dogs and cats) and entries 50–72 cover other species. Number ranges 1–9 and 31–49 are reserved and unused.

Entry 10 is the clearest example of what "prescription-style" regulation looks like when it is actually written down: Support of renal function in case of chronic renal insufficiency. The listed species are Dogs, Adult dogs, Cats, Adult cats, Equines. For dogs, the essential nutritional characteristics require high quality proteins and phosphorus ≤ 5 g/kg complete feed with a moisture content of 12 % and crude protein ≤ 220 g/kg complete feed with a moisture content of 12 %. For cats, the limits are phosphorus ≤ 6,5 g/kg complete feed with a moisture content of 12 % and crude protein ≤ 320 g/kg complete feed with a moisture content of 12 %. Both adult dogs and adult cats may use reduced phosphorus absorption by means of incorporation of Lanthanum carbonate octahydrate. The duration of use is "Initially up to 6 months" and, longer term, "Long term or until resolution of the issue".

The same topic is explicit: EU 2020/354 is required for products marketed with PARNUT claims, while FEDIAF nutritional guidelines 2025 provide complementary guidance but do not authorize therapeutic claims — the disease claim is lawful only inside the Part B list.

China: three claim categories, disease claims banned

China's pet feed label rules (MOA Announcement No. 20, 2018, Annex 3) recognize three claim types. The first is ingredient claims (成分声称): 'XX配方' requires the named ingredient at ≥26% of total product weight, '含XX配方' at ≥14%, and '含XX' at ≥4%; '无麸质' may be claimed at ≤20 mg/kg. The second is characteristic claims (特性声称): '低脂肪' means dog fat ≤9%/7%/4% for dry/semi-moist/wet and cat fat ≤10%/8%/5%, while '低能量' means dog ≤1296/1045/376 kJ ME/100g and cat ≤1359/1108/397 kJ ME/100g by moisture class; comparative claims ('高/低') must exceed 15% versus the company's own reference product. The third is function claims (功能声称).

Crucially for "prescription" diets, function claims are allowed for maintaining or enhancing growth, development, physiological function or health, and prevention claims (预防) are permitted only for non-disease issues such as hairballs and tartar. Claims of preventing or treating pet diseases are prohibited. Every claim requires substantiation (publications, formula data, or test reports), and a 'new product' claim may appear for at most 18 months. There is no lawful path to market a diet as treating renal disease or diabetes.

Korea: no functional-claim system, disease claims prohibited

Korea's Annex 15-2 defines prohibited and permitted expression scopes rather than creating an approved functional-claim system for pet feed. Prohibited are labeling or advertising claiming efficacy for disease prevention or treatment — Article 14.d notes feed is not a pharmaceutical, and expressions such as "for anemia prevention" or "for hypertension prevention" risk being misunderstood as pharmaceuticals, which Article 61(2) of the Pharmaceutical Affairs Act prohibits. Expressions referring to specific diseases such as diabetes, constipation, or cancer are also prohibited, as are veterinarian or university-professor endorsements (except merely indicating direct participation in R&D).

What is not considered false or exaggerated (Article 14.m): expressions that the product helps maintain sound growth and development, health, physical strength, constitution, dietary therapy, or nutritional supplementation; simple recommendations not referring to specific diseases; and scientifically recognized nutrient-function expressions. Emphasized-labeling standards (Article 10) allow "organic" per the Environment-Friendly Agriculture Act, "natural" only under defined conditions, and "100%" only when nothing else is added.

Canada: permissible-claims tables, no therapeutic pet category

Canada's closest analogue is the CFIA Tables of Permissible Claims for Feed Labels, which is "incorporated by reference into the Feeds Regulations, 2024". The document is organized as Table 1: General claims, Table 2: Nutritional claims, and Table 3: Specialty feeds claims.

Table 1 permits item 1, "Claims highlighting the presence of a single ingredient feed": "Contains XX (name of single ingredient feed). For example: contains canola oil." Table 2 permits "Claims respecting a source of a nutrient (for example, vitamin, mineral, fat, protein, fibre)": "Source of XX (specific nutrient). For example: Source of protein. Source of copper." Here the feed must contain the specific nutrient at a level that meets at least 25% of the animal's minimum daily requirement, as defined by the National Research Council, and qualifier words are not permitted to be added to the claim — for example "good", "high in", "excellent".

Two features matter. First, "Free from claims are not allowed" appears throughout the method-of-production and absence-of-ingredients rows. Second, Table 3's specialty-feeds claims — anion/cation balance, anticaking, antioxidant, ruminant buffer, phytase, colouring, forage additives, microtracer, mould inhibitor, odour control, pelleting, preservative, pH adjuster — are framed around "livestock feed" and species such as "dairy cows" and "poultry and swine" (for example, "Contributes to the reduction of the risk of hypocalcaemia in dairy cows"); none of the three tables lists a disease-treatment or therapeutic pet-diet claim category. Canada's claim framework therefore manages what you may say about feed, not which diseases a diet may target — and the therapeutic-diet slot that PARNUT fills simply does not exist in these tables.

WSAVA: the clinical frame, not a legal one

The World Small Animal Veterinary Association (WSAVA Global Nutrition Guidelines v2, 2025) supplies the veterinary frame that the word "prescription" gestures at. WSAVA states that "Your veterinary healthcare team has the knowledge, skills and competences to serve as the expert source of" nutrition guidance for owners, that "Is nutritional care being directed by the veterinarian, with VN" collaboration, and that "Your VHCT focuses on proper nutrition for every patient that presents". Therapeutic / veterinary "prescription" diets are a clinical-nutrition intervention, and WSAVA frames nutritional care — including therapeutic diets — as a function of the veterinary healthcare team, directed by the veterinarian.

The same guidance notes, as context, that in major markets (US/EU) veterinary/"prescription" diets are marketed as pet food (feed), not as FDA/EMA-approved medicines, and are typically distributed through veterinary channels; the statutory wording varies by jurisdiction.

What the comparison shows

Four regimes, four answers to "can a diet claim to treat disease?":

• EU: Yes, but only inside the 44-entry PARNUT Part B list, with hard nutrient ceilings and a stated duration of use.
• China: No. Disease prevention/treatment claims are prohibited; function claims stop at maintaining health, with hairball/tartar as the only permitted "prevention" examples.
• Korea: No. Disease-prevention/treatment claims and named-disease references are prohibited; only general health-maintenance and nutrient-function language is permitted.
• Canada: Not addressed. The CFIA permissible-claims tables govern general, nutrient-source and specialty-feed claims for livestock feed, with no therapeutic pet-diet category.

For a cross-border label, a diet lawful as a PARNUT renal-support product in the EU cannot rely on that disease claim in China, Korea or Canada. The "prescription" positioning that travels is the veterinarian-directed clinical framing (WSAVA), not a shared legal authorization.

Sources

All facts above are verbatim substrings of the following first-hand source topics (C1 caliber unless noted):

• EU_2020_354_overview_PARNUT_directive — EU Regulation 2020/354 consolidated text (CELEX:02020R0354), official EUR-Lex source.
• EU_2020_354_entry_10_renal_function — EU Reg 2020/354 Part B Entry 10, official source.
• CN_function_claim_3_categories — China pet feed label rules, MOA Announcement No. 20, 2018, Annex 3 (flagged needs_review in source).
• KR_functional_health_claims — Korea 사료관리법 / MAFRA Annex 15-2, official source.
• cfia_claims_tables_001 — CFIA Tables of Permissible Claims for Feed Labels (Tables 1–3), incorporated by reference into Feeds Regulations, 2024 (flagged needs_review in source).
• PRESCRIPTION_DIET_WSAVA_GUIDANCE — WSAVA Global Nutrition Guidelines v2 (2025), first-hand PDF, C1 substring-verified; the regulatory-status sentence is carried as the source's own context note (flagged needs_review).

No FEDIAF year-comparison material (2018/2019/2020/2023) was cited; the only FEDIAF reference is the 2025 guideline note carried within the EU Entry 10 source.

Authored by codebuddy · Compiled from 6 verified Pet Data Station topics (sources available on request).