The short answer
That one paragraph compresses the whole system. Pet food is regulated not as food but as compound feed for non-food-producing animals, and its labelling rules sit in Regulation (EC) No 767/2009, supported by the additives, feed-hygiene and animal by-products rules.Reg (EC) No 767/2009 · Reg (EC) No 1831/2003 · Reg (EC) No 183/2005 · Reg (EC) No 1069/2009
The same rulebook applies to all of Europe’s 400-plus pet food companies and its €29.4 billion in annual salesFEDIAF, Facts & Figures 2025 — the regulation does not scale its demands to your company’s size. This guide lists every mandatory particular with a pinpoint citation, so you can verify each one at the source. For the regulation itself in plain English, see Regulation (EC) No 767/2009, explained.
What must appear on an EU pet food label?
Two lists stack on top of each other. Article 15 sets the particulars required on all feed; Article 17 adds more for compound feed — which nearly every commercial pet food is. Together they require:
- Type of feed. The words “complete feed” or “complementary feed” (for milk replacers, “complete milk replacer” or “complementary milk replacer”; for pet animals other than cats and dogs, “compound feed” may be used).Reg (EC) No 767/2009, Art. 15(a)
- The person responsible for labelling. Name or business name and address of the feed business operator responsible for the labelling — the brand owner or importer, not necessarily the factory.Art. 15(b)
- Approval number. The establishment’s approval number, where it has one.Art. 15(c)
- Batch or lot reference. The traceability anchor for complaints and recalls.Art. 15(d)
- Net quantity. In units of mass for solid products, mass or volume for liquids. Separate metrology law governs how large the figures must be printed.Art. 15(e) · Dir 76/211/EEC, Annex I
- Additives. Added feed additives declared under the heading “additives”, following the rules for pet food in Annex VII, Chapter I.Art. 15(f) · Annex VII, Ch. I
- Moisture. Declared where it exceeds the thresholds in Annex I — for most pet food, 14 %.Art. 15(g) · Annex I, pt 6
- Species. The species or categories of animals the feed is intended for.Art. 17(1)(a)
- Feeding instructions. Instructions for proper use, indicating the purpose the feed is intended for.Art. 17(1)(b)
- Producer particulars. Where the producer is not the person responsible for the labelling: the producer’s name and address, or an approval or identification number.Art. 17(1)(c)
- Best-before date. The minimum storage life — covered in its own section below.Art. 17(1)(d)
- Composition. The feed materials, under the heading “Composition”, in descending order by weight. Pet food may declare permitted categories instead of individual materials, and an ingredient emphasised on the pack (“with chicken”) must carry its percentage.Art. 17(1)(e) · Art. 17(2)
- Analytical constituents. The declared nutrient levels — covered in its own section below.Art. 17(1)(f) · Annex VII, Ch. II
- A contact for questions. Pet food labels must carry a free telephone number or other appropriate means for buyers to ask about the additives used and about feed materials declared by category.Art. 19
Three cross-cutting rules sit over that list. The particulars must be presented conspicuously, legibly and indelibly, in the required language of each market — see below.Art. 14(1) Nothing on the label, mandatory or voluntary, may mislead the user as to what the feed is or does.Art. 11(1) And “dietetic” pet food marketed for a particular nutritional purpose must match an authorised intended use and carry additional particulars of its own.Art. 18 · Reg (EU) 2020/354
One more distinction before the sections below: single-material products — a bag of dried sprats, a plain chew with nothing added — are feed materials rather than compound feed. They skip the Article 17 additions but carry their own declaration rules, and the EU Catalogue of feed materials standardises the names they may use.Art. 16 · Reg (EU) No 68/2013
For presentation conventions on top of the legal minimum, the industry’s reference document is the FEDIAF Code of Good Labelling Practice for Pet Food (see its chapter on mandatory labelling information). We cite it by name only — it is not law, and whether it binds you is covered in the companion guide.
Complete vs complementary pet food — what’s the legal difference?
The regulation defines both terms. A complete feed is a compound feed which, on its own, is sufficient for a daily ration. A complementary feed has a high content of certain substances and covers the daily ration only in combination with other feed; a mineral feed is a complementary feed with at least 40 % crude ash.Reg (EC) No 767/2009, Art. 3(2)
The distinction is not marketing copy — it is a mandatory particular. One of the two designations must appear on the pack,Art. 15(a) and it drives the feeding instructions: a complementary feed’s instructions must make clear how it combines into the daily ration, including any maximum inclusion.Art. 17(1)(b) · Annex II, pt 4 Most treats, toppers and mixers are legally complementary feed — a chew sold “just as a treat” carries the same labelling duties as a complete kibble.
Getting the designation wrong is a substantive error, not a wording preference: labelling a product “complete” is a nutritional-adequacy claim the recipe must actually meet. In practice, adequacy for cats and dogs is commonly assessed against the FEDIAF Nutritional Guidelines — again an industry reference we cite by name, not law.
What are analytical constituents?
Analytical constituents are the declared nutrient levels of the product. For compound pet food the mandatory declarations are crude protein, crude fibres, crude oils and fats, and crude ash, under the heading “analytical constituents” — plus moisture where it must be declared.Reg (EC) No 767/2009, Art. 17(1)(f) · Annex VII, Ch. II
A recurring confusion: added vitamins and trace elements do not belong under “analytical constituents” — they are additives, declared under the “additives” heading with their own rules.Art. 15(f) · Annex VII, Ch. I The two blocks answer different questions: what the food measurably contains, versus what was deliberately added to it.
The figures are enforceable, not decorative: official laboratories test against them, and Annex IV sets the permitted tolerances a measured value may deviate by before the declaration is non-compliant.Annex IV
If your team — or your supplier, or your US consultant — speaks AAFCO, the terms translate, but the logic differs:
| On an EU label | On a US label | The difference |
|---|---|---|
| Analytical constituents | Guaranteed analysis | The EU declares levels, held within the Annex IV tolerances; the US guarantees minima and maxima. |
| Best before (minimum storage life) | Best by | Mandatory for EU compound feed, in a prescribed date form. |
| Batch or lot reference | Lot number | An explicit mandatory particular in the EU. |
| Composition (feed materials) | Ingredient statement | EU: descending order by weight, with permitted category names for pet food. |
A US-drafted label ported to the EU usually fails on exactly these lines: a “Guaranteed Analysis” heading instead of “analytical constituents”, “best by” instead of “best before”, an ingredient statement that ignores the EU composition rules.
Which languages must the label be in?
The mandatory particulars must appear at least in an official language, or one of the official languages, of the Member State or region where the product is placed on the market.Reg (EC) No 767/2009, Art. 14(1) The EU has 24 official languages and several Member States have more than one — a pack sold in Belgium, for instance, must satisfy the language of its region of sale.
Multi-market sellers handle this in one of two ways: a multilingual pack carrying every target market’s language, or market-specific label versions. Both are lawful, and both must keep every mandatory particular complete in each required language — translating only the front of pack does not comply.Art. 14(1) The practical constraint is space: every added language multiplies the mandatory block, and the particulars must stay conspicuous and legible in all of them.
Two practical notes. Language is one of the most common failure points for imported products: a compliant recipe with an English-only label is still a non-compliant label in most of the EU. And post-Brexit, Great Britain runs the inherited version of the same rulebook in assimilated law with English labelling, while Northern Ireland remains aligned with the EU rules.
Do pet food labels need a best-before date?
Yes. Compound feed — which includes essentially all commercial pet food — must state its minimum storage life.Reg (EC) No 767/2009, Art. 17(1)(d) The regulation prescribes the form of the indication, distinguishing highly perishable feed (“use before”) from other feed (“best before”), each followed by the date.Annex II, pt 2 One storage life is indicated for the product as a whole.Art. 3(2)
If your artwork template descends from a US label, check this line twice: “best by” is not the prescribed form, and a missing or mis-formatted date is one of the simplest blockers an inspector can find. Note too that the date and the batch reference are often ink-jetted at packing rather than set in the artwork — the legibility and indelibility requirements apply to the printed result, not to the design file.Art. 14(1)
What happens if a label is non-compliant?
Enforcement is national. Member States must lay down penalties that are “effective, proportionate and dissuasive”, and their feed authorities police labelling through the EU official-controls system.Reg (EC) No 767/2009, Art. 31 · Reg (EU) 2017/625 In practice the ladder runs from correction orders and re-labelling demands to sales blocks, withdrawal from the market and fines — plus the quieter commercial penalties: retailer delistings, border holds, and a launch window lost while the artwork goes around again.
The risk is not theoretical. The EU’s Alert and Cooperation Network — which includes RASFF, the rapid alert system — logged 5,250 notifications in 2024, up 12 % on the previous year; within the feed network, labelling issues account for roughly one reported case in ten.European Commission, ACN annual report 2024
And the bar moves twice in one year. From 27 September 2026, generic environmental claims (“eco”, “climate neutral”) without recognised substantiation are banned under the Empowering Consumers Directive.Dir (EU) 2024/825 From 12 August 2026, the Packaging and Packaging Waste Regulation begins to apply, pushing nearly every EU pack through a redesign cycle in the years that follow.Reg (EU) 2025/40 Every redesign is a fresh chance to introduce — or to catch — a labelling error.
How do I check a label against all of this?
You have three honest options. Check it yourself against the lists above — entirely doable if you keep the citations at hand and repeat the exercise for every market and every artwork revision. Commission a consultancy review — thorough, but priced per label per market, days to weeks slow, and restarted by each revision. Or use the tool this guide comes from: Nutrivo checks a pet food label against its encoded rules for each market you select and returns a verdict in minutes, every finding citing the article it comes from — the same pinpoint citations used on this page — and where its coverage of a market is incomplete, it says INCOMPLETE rather than guessing. Whichever route you take, verify against the source, not against a blog post — this page included.