FEDIAF, the European petfood industry association, represents 450 petfood companies affiliated with national petfood associations and serves 62 million pet owning households in the European Union (EU). Its chief concerns are petfood quality, safety, hygiene, nutrition and providing appropriate consumer information.

Numerous food and farm feed safety incidents in the past (BSE, dioxin, avian influenza and various contaminants) have led to some 80 different European Union (EU) laws on BSE/TSE, general food law, feed and food hygiene, official controls, contaminants and feed additives. Petfood is regulated under the same EU laws as farm feed and administered by the same EU and national health services, but there are some significant differences. To name just two: Petfood is not part of the human food chain and we feed pets, not for cost efficient food production, but for a long and healthy life.

Three major projects

Currently, three major legislative projects are in the law making process:

• The review of the Animal By-Products Regulation 1774/2002/EC, which sets forth the permitted use of animal protein, not intended for human consumption, by various sectors.
• The proposal for a regulation on the use of feed, which will set new labeling and claims rules.
• The implementation of the requirements for reapproving additives already authorized for use in animal feed and petfood.

Because many EU laws have further improved feed and food safety since the initial 774/2002/EC, the declared aim of the EU is to achieve simplification, to cut red tape and place greater responsibilities on companies. The new rules will also review the list of permitted petfood ingredients, define an “end point” from which processed products (including petfood) will no longer be subject to the regulation’s rules and possibly review processing methods according to innovation.

The process has just started and the complete rewrite of the regulation which now has a staggering 178 detailed pages will in all likelihood not be fully applicable before 2011. However, the new law will maintain the longstanding FEDIAF voluntary policy to use only surpluses from the human food chain derived from animals passed as fit for human consumption.

Label functions

Labeling and claims rules for farm feed and petfood in the EU date from 1979, with some amendments over the years, and will now be completely rewritten. Labeling has three main functions:

• Official control,
• Providing consumer information and
• Marketing.

To strike the right balance according the principle of proportionality was the legislator’s challenge, and FEDIAF underlined in the negotiations that it is essential that labeling requirements are understandable by the average pet owner, who, contrary to the farmer, is often not knowledgeable in animal nutrition

FEDIAF estimated that seemingly insignificant label changes would cost the European industry € 355 million (US$470 million) annually. The legislator will adopt a balanced text avoiding most of these costs.

The new regulation, which is close to adoption, includes balanced rules and will avoid most of the above costs, but will require some label changes (new rules on labeling additives, new analytical tolerances and pending details on ingredient listings). With adoption expected in May/June 2009 and full application in June 2010, it will be basically impossible to adapt petfood labels within this tight deadline and efforts are being undertaken to obtain a longer transition period.

The EU will embark on a science based reassessment of all currently permitted feed additives. This includes vital vitamins, trace elements, amino acids, colours and technological additives which have been used by industry for decades and thereby have proven their safety and efficacy. Nevertheless, and because the EU does not apply the generally recognized as safe (GRAS)  principle, a scientific dossier for each single substance must be submitted by November 2010 at the latest, otherwise the additive will be delisted and no longer permitted in the EU. While additives must be safe, producers and users will be faced by an enormous and costly workload for the reassessment. FEDIAF endeavours to achieve a simplified procedure for petfood additives and an extension of the cut off deadline November 2010.