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Feed material or feed additive? Learn how to classify ingredients, use the EU Catalogue and register, and assess borderline botanical extracts.
From a formulation perspective, a substance may simply be an “ingredient”. In law, however, its status may determine whether the entire formula is viable.
Feed materials and feed additives are not interchangeable categories. They have different rules, documentation requirements and conditions of use.
This is particularly important in pet health products combining botanicals, extracts, vitamins, minerals, microorganisms, flavourings and technological carriers.
If you are developing a formula, also read: Your own pet supplement brand: from idea to shelf.
An ingredient's status affects:
Classification should therefore happen during R&D, before the packaging artwork is finalised.
Regulation (EC) No 767/2009 defines feed materials as products of vegetable or animal origin whose principal purpose is to meet animals' nutritional needs, in their natural state, fresh or preserved, and products derived from their industrial processing, together with organic or inorganic substances intended for oral animal feeding.
A material can be used on its own or in compound feed.
Examples may include oils, meals, hydrolysates, plant parts, products of their processing and certain mineral sources, provided they meet the applicable definition and legal status.
Regulation (EC) No 1831/2003 defines feed additives as substances, microorganisms or preparations, other than feed materials and premixtures, intentionally added to feed or water to perform one or more functions specified in that Regulation.
The categories include:
The key distinction is the EU authorisation system.
It is insufficient to say that a substance is safe. Check whether the particular substance or preparation is authorised for the intended use and under what conditions.
Feed material: the main reference points are nutritional purpose and the characteristics of the raw material.
Feed additive: the main reference point is a specific technological, sensory, nutritional or zootechnical function within the authorisation system.
In borderline cases, however, asking whether something “provides nutrition” is not enough.
The European Commission adopted Recommendation 2011/25/EU with guidelines distinguishing feed materials, feed additives, biocidal products and veterinary medicinal products.
Relevant considerations include:
No single characteristic resolves every case.
The EU Catalogue of feed materials is established by Commission Regulation (EU) No 68/2013, amended, among others, by Regulation 2022/1104.
It harmonises names, descriptions and processes for many materials.
It is not, however, an exhaustive list of every lawful feed material. Article 24 of Regulation 767/2009 also provides for a register of feed materials not listed in the Catalogue.
The practical question is therefore broader than “Is the ingredient in the Catalogue?”
Ask: “What are its status, description, process and function, and what supports placing it on the market as a feed material?”
A commercially attractive Catalogue name cannot simply be selected because it suits the marketing.
The actual material must comply with the relevant description and, where applicable, specified processes or characteristics.
Supplier documentation and the manufacturing process therefore matter as much as the trade name.
Plant extracts are a useful example of borderline ingredients.
The word “extract” tells us too little. Establish:
The more closely a product resembles an isolated or highly standardised substance performing a specific function, the more carefully the distinction between material and additive needs to be assessed.
This does not mean “high standardisation automatically equals additive”. Each case requires assessment of the whole product profile.
FoodUP can assess the classification of an ingredient or an entire formula before raw materials are ordered and the label is prepared.
Contact: team@foodup.com.pl.
If you are also considering your manufacturing model, read: Private label, white label or your own formula?.
DER describes the relationship between the quantity of starting material and the resulting extract. Standardisation describes a controlled content of specified constituents or markers.
Both matter for technology and quality, but neither should be the sole classification test.
Assess them together with the process, function and presentation of the ingredient.
Vitamins intentionally used to supplement nutrition commonly fall within the nutritional feed additive framework.
The generic name “vitamin E” is not enough. Check the specifically authorised substance or preparation, conditions of use and declaration requirements.
The same principle is relevant to trace elements, amino acids and microorganisms.
Do more than look for the ingredient's name in the EU Register of Feed Additives.
Verify:
Use the corresponding authorising act to confirm the conditions. This gives a meaningful basis for including the additive in a formula.
Marketing language can distort the ingredient's actual function.
If a substance is authorised as a flavouring, promoting it for a different biological function may raise questions about whether the intended use complies with the feed additive authorisation framework.
Marketing teams therefore need to understand both the ingredient's name and its regulatory status and function.
Before approving an ingredient, ask:
If the answers are unclear, regulatory review should be completed before the ingredient enters the final formulation.
For challenging ingredients, prepare a short decision record covering:
This is particularly useful when a product moves to another contract manufacturer or is inspected several years after launch.
“Feed grade” is useful commercial information, but does not replace an assessment of legal status.
Natural origin does not determine classification.
This is particularly risky. Lack of additive authorisation does not automatically permit reclassification as a feed material.
A product's presence on the market is not a source of law.
A mistaken decision at raw material level can affect:
Classification is therefore a practical product-development decision, not merely an academic exercise.
Not always. Regulation 767/2009 also provides for a register of materials not listed in the Catalogue. The specific ingredient's status must nevertheless be established and documented appropriately; registration alone does not replace that assessment.
No. Assessment depends on the process, composition, standardisation, function and intended use.
No. Check the specific authorisation, including target species and any minimum or maximum levels.
No. A specification and information on the preparation's actual composition are needed. A commercial preparation may contain an active constituent, carriers and other components with their own statuses.
No. DER is a technological and quantitative parameter. It may contribute to the extract's characterisation but does not determine its legal status on its own.
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