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What claims can pet food brands use in the EU? Learn the rules, the boundary between physiology and treatment, and the evidence required.
In pet health, the greatest regulatory problems often arise not from the formulation but from what a brand says about the product's effects.
A product may have a sound formula and correctly declared ingredients, yet create regulatory risk through a single sentence on the front label, an online product description or an advertisement suggesting treatment of a disease.
Claims should therefore be developed alongside the formula and documentation, rather than added by marketing at the end.
In practice, a claim is a statement or form of presentation that attributes particular properties, functions or benefits to a product.
It may appear as:
Compliance therefore extends beyond the physical label.
Article 13 of Regulation (EC) No 767/2009 permits particular attention to be drawn to the presence or absence of a substance, a specific nutritional characteristic or process, or a related function.
The conditions matter: a claim must be objective, verifiable by the competent authorities and understandable to the feed user.
The person responsible for labelling must also hold scientific substantiation and provide the relevant evidence when requested by the competent authority. That substantiation must be available when the feed is placed on the market.
Claims are therefore assessed on more than wording. They need support in the actual product.
The central rule is that feed must not be presented as preventing, treating or curing disease, subject to the exceptions provided by law.
The distinction between a functional statement and a therapeutic one is therefore crucial.
A lower-risk direction: “supports the maintenance of normal joint condition”.
A high-risk direction: “treats joint degeneration”.
A lower-risk direction: “supports normal digestive function”.
A high-risk direction: “treats diarrhoea”.
A lower-risk direction: “supports natural immune mechanisms”.
A high-risk direction: “prevents infections”.
The important qualification is that the word “supports” does not automatically make a claim lawful.
When assessing the boundary with medicinal presentation, also consider Article 4 of Regulation (EU) 2019/6: the definition of a veterinary medicinal product includes substances presented as having properties for treating or preventing disease in animals.
This is one of the most common mistakes in the sector. A brand takes an impermissible therapeutic message and replaces “treats” with “supports”. The problem may remain.
For example, “supports the treatment of arthritis” still refers to treatment of a disease. Similarly, “supports the fight against infection” may suggest a therapeutic function even without the word “treats”.
Authorities assess the overall meaning of the communication, not an isolated verb.
To substantiate a claim, assess at least:
A claim should not be developed independently of the formula.
If a study reports an effect with 500 mg of a particular extract, while the finished product supplies 20 mg of another extract with different standardisation, citing that publication alone is insufficient.
This matters particularly for ingredients with extensive scientific documentation. Research on an ingredient in a particular model does not mean that every product containing it can adopt the publication's full language.
Consider whether:
This is often where a formal substantiation dossier becomes necessary.
FoodUP can review a claim together with the formula, dose and evidence base. The assessment covers both the wording and whether the particular product can substantiate it.
Contact: team@foodup.com.pl.
If you are still selecting a product model, read: Private label, white label or your own formula?.
A scientific paper addresses a research question. A label or advertisement serves a commercial purpose. These are different contexts.
A study may describe effects on parameters associated with disease, but directly transferring its language to a label may create an impermissible medicinal claim.
The literature should substantiate a lawful claim, rather than supply the most striking sentence from an abstract.
Risk is not limited to physiological claims. Statements such as:
must also be true and verifiable.
A declared standardisation requires supporting documentation. For a “free from X” statement, assess whether it could mislead and whether it is adequately supported throughout the supply chain.
Regulation 767/2009 defines labelling broadly, including information associated with feed in advertising and on the internet.
The same principles should guide:
Removing a problematic claim from the label is insufficient if it remains on the product page.
A robust process includes eight steps:
This makes claims part of the regulatory process rather than incidental marketing wording.
Particular care is needed with direct references to:
Brands can communicate product benefits, but must remain within the applicable legal framework.
No. The overall meaning matters. “Supports the treatment of disease” still refers to a therapeutic function.
Scientific evidence may be used, but its presentation must be assessed within the full communication. Citing a study does not automatically permit a medicinal claim for a feed product.
Yes, but it must not create an impression that the finished product has properties unsupported by its formula, dose and scientific evidence.
Yes. Online presentation and distance selling are subject to requirements on accuracy and impermissible medicinal properties.
Not necessarily. The evidence needed depends on the claim, its novelty and whether existing knowledge can be applied to the specific product. A well-constructed dossier based on literature, formulation and dose may be sufficient in some cases. In others, original data will be more important.
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