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How should complementary feed for dogs and cats be labelled in the EU? Learn about mandatory particulars, additive declarations and claims.
Correct feed labelling for dogs and cats starts long before text is arranged on the packaging. It begins with three questions: what is the product's legal classification, what is the regulatory status of its ingredients, and which declarations follow from the formulation?
Many products marketed as “pet supplements” fall within the legal category of complementary feed. Their presentation and labelling are governed primarily by Regulation (EC) No 767/2009 on the placing on the market and use of feed.
This distinction matters. “Dog supplement” may be familiar consumer language, but it is not a separate product category under EU feed law and does not replace the mandatory designation of the feed type. This guide focuses on complementary feed for dogs and cats placed on the EU market.
If you are developing the product itself, read our guide to launching your own pet supplement brand.
Regulation (EC) No 767/2009 defines compound feed as a mixture of at least two feed materials, with or without feed additives, intended for oral animal feeding. Complementary feed is compound feed with a high content of certain substances that can meet the requirements of a daily ration only when used with other feed.
In practice, this category can include powders, blends of oils, pastes and liquids given to dogs and cats alongside their usual diet. However, a single oil classified as a feed material does not become complementary feed simply because it is marketed as a supplement.
The legal classification follows from composition, function and intended use. It is not determined by the packaging format or marketing name.
The main framework is Regulation (EC) No 767/2009. It covers responsibility for labelling, mandatory particulars, composition, additives, claims and product presentation.
If the formulation contains feed additives, Regulation (EC) No 1831/2003 and the conditions of the individual additive authorisations must also be considered.
The FEDIAF Code of Good Labelling Practice for Pet Food provides practical guidance for applying the rules. It does not replace legislation. The European Commission identifies the code within the framework established by Regulation 767/2009 on its feed marketing page.
This question is particularly important in contract manufacturing.
Under Article 12 of Regulation 767/2009, the person responsible for labelling must ensure that the required particulars are present and substantively accurate. This is the feed business operator who first places the feed on the market or, where applicable, the operator under whose name or business name it is marketed.
A contract manufacturer may prepare the label text, but outsourcing that task does not automatically transfer the brand owner's regulatory responsibilities. Other operators also have obligations within the activities they control.
The final review therefore needs to cover the formulation and ingredient documentation as well as the artwork.
The exact requirements depend on the product, formulation and additives used. For a typical complementary feed for dogs or cats, the following areas need to be checked.
The label must identify the correct feed type, such as “complementary feed”. Annex II permits the expression “pet food” in English pet feed designations, allowing wording such as “complementary pet food for dogs”.
The designation should make the product category clear to both the purchaser and the competent authority.
Compound feed must identify the species or categories of animals for which it is intended. A generic statement such as “for animals” is unlikely to describe a product intended specifically for adult dogs or cats adequately.
Feeding instructions are part of product safety. They must indicate the intended purpose and explain how to use the product. Where required, they must also specify the maximum quantity.
This is particularly important when complementary feed contains additives above the maximum levels fixed for complete feed. Annex II requires instructions stating the maximum quantity per animal per day, as a proportion of the daily ration, or relative to complete feed, so that the relevant limits in the daily ration are respected.
The feeding rate should therefore be derived from the formulation rather than decided during the artwork stage.
Feed materials should be listed under the heading “Composition”, generally in descending order by weight. For pet food, the legislation permits category names to replace individual feed material names in specified circumstances.
Where a feed material is emphasised in words, pictures or graphics, its name and percentage by weight must be indicated. For example, prominently featuring salmon on the front of the pack has consequences for the composition declaration; it is not merely a creative choice.
The “Additives” section follows different rules from the composition list. For feed intended for non-food-producing animals, the detailed requirements are set out in Annex VII.
The starting point includes additives for which a maximum content is set for at least one non-food-producing animal, zootechnical additives, and coccidiostats and histomonostats. The annex also covers additives whose use level exceeds the recommended maximum content established in the authorising act.
The declaration must reflect the applicable specific name and/or identification number, quantity and functional group or category, following the annex and the authorisation.
There are permitted simplifications for certain groups, including preservatives and antioxidants. Additives emphasised in words or graphics must be declared in accordance with point 1 or 2 of Annex VII, Chapter I, as applicable. For vitamins, the annex allows, under its conditions, the total amount guaranteed throughout the shelf life to be declared under “Analytical constituents” instead of the added amount under “Additives”.
This is why additive declarations should not be assembled from trade names on supplier invoices. They need to be based on the ingredient's regulatory documentation.
This distinction is a frequent source of problems in pet health formulations. Feed materials and feed additives operate under different legal frameworks. Their presence in the same powder, capsule or liquid does not mean that they can be used or declared in the same way.
Regulatory status affects:
Any uncertainty should be resolved before the final label is prepared, ideally before the ingredient is ordered.
For “complementary feed - other” intended for dogs and cats, Annex VII requires declarations of:
Mineral feed has a different set of mandatory analytical particulars: calcium, sodium and phosphorus. The standard declaration for other complementary feed cannot simply be copied across.
Where substances that are also sensory or nutritional additives are declared under “Analytical constituents”, the rules on declaring their total amount must be observed. The section should therefore be built around the actual product classification and formulation.
The obligation to declare moisture also needs to be checked. Under Annex I, unless another level is specified in Annex V or the Catalogue of feed materials, moisture must be stated when it exceeds 14% for “other feed”. Different thresholds apply to mineral feed and certain compound feeds containing a high proportion of milk products.
This is particularly relevant to pastes, liquids and other moist formats. Listing the four basic analytical constituents does not necessarily complete the mandatory declarations.
The general mandatory particulars include net quantity, the batch or lot reference, and the details of the person responsible for labelling. Article 17 also sets out the minimum storage life declaration for compound feed.
Shelf life should not be treated as an arbitrary marketing decision. The regulation links it to the period during which the responsible operator guarantees that the feed retains its declared properties under appropriate storage conditions.
Two opposite mistakes are common: omitting relevant identification details, or adding every number found in the manufacturer's documents.
The legislation distinguishes between the details of the person responsible for labelling, the relevant approval number where available and applicable, and manufacturer identification where the manufacturer is not the person responsible for labelling.
This part of the label should reflect the actual supply chain and the roles of the businesses involved.
Article 19 introduces an additional pet food requirement: a free telephone number or another appropriate means of communication must be provided so purchasers can obtain further information about additives and feed materials declared by category.
The contact channel therefore serves a regulatory transparency function as well as customer service.
Mandatory information must be conspicuous, clearly legible, indelible and identifiable. Article 14 requires it to be provided in the official language, or at least one official language, of the Member State or region where the product is placed on the market.
For a brand selling in several countries, this means preparing the appropriate local label versions. An English-language website does not replace a required local-language product label.
The greatest risk is often on the front of the pack rather than in the ingredient list.
Article 13 allows claims relating to certain nutritional characteristics, processes or functions, but requires them to be objective, verifiable and understandable. Scientific substantiation must already be available when the feed is placed on the market.
At the same time, feed labelling and presentation must not claim to prevent, treat or cure a disease, subject to the specific exceptions laid down in the legislation.
A correct composition panel therefore does not make a medicinal claim elsewhere on the packaging acceptable.
The regulation defines labelling more broadly than the physical label. It includes information attributed to feed online and in advertising.
For distance selling, Article 11(3) requires most mandatory particulars to be available before the contract is concluded. Specified exceptions, including the batch reference and minimum storage life information, may be supplied no later than delivery. An unreadable photograph of the packaging does not provide an adequate substitute for the necessary information.
Before launch, compare:
Correcting the packaging achieves little if the next social media post makes a claim that could not lawfully appear on it.
The day before 10,000 packs go to print is a poor time to start.
The practical sequence is: formulation → ingredient classification → regulatory text → artwork → final artwork review → printing.
Preparing the label alongside the formulation and supporting documents makes it possible to resolve problems before they generate avoidable costs.
FoodUP reviews labels together with the formulation and ingredient documentation. This allows the review to address whether the declarations reflect the actual product, as well as how they are worded in the artwork.
If you are still selecting a manufacturing approach, read our comparison of private label, white label and a proprietary formulation.
Contact team@foodup.com.pl with your label artwork, quantitative formulation and ingredient documentation. Include the target species and intended market so the review scope can be established.
It is not a separate legal category under EU feed law. It may be used colloquially in the market, but the mandatory designation must reflect the product's actual feed classification, such as complementary feed.
The manufacturer's obligations depend on its role. Regulation 767/2009 identifies the person responsible for labelling and requires that person to ensure that information is complete and substantively accurate. Outsourcing production should not be treated as automatically transferring all regulatory responsibility to the manufacturer.
Not in the same way. Annex VII specifies which additives must be declared and when simplifications are permitted. The individual additive authorisation may impose additional requirements.
That wording is not automatically compliant or non-compliant. The full claim, product, species, feeding rate and supporting evidence need to be assessed. Article 13 permits claims concerning support or protection of physiological conditions, subject to its requirements and restrictions.
Yes. Product pages and advertising are subject to feed labelling and presentation rules. Most mandatory particulars must be available before purchase, subject to the exceptions in Article 11(3). Online content should therefore be reviewed together with the physical label.
Maciej Jaskólski, MPharm is a pharmacist and founder of FoodUP Consulting. He combines experience in product development, quality and regulatory affairs with practical work on supplement and pet health launches.
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