Regulation (EC) No 767/2009, explained

EUR-Lex gives you the regulation’s full text; old briefing PDFs give you its history. Neither gives you a working understanding: what it actually demands of a pet food label, who it makes responsible, and what happens when it is ignored. That is this guide. Every claim below carries its citation, so you can step from any sentence here to the regulation’s own words.

What is Regulation (EC) No 767/2009?

Adopted on 13 July 2009 and applying since 1 September 2010, the regulation governs the placing on the market and use of feed in the EU — farm feed and pet food alike. Pet food sits squarely inside it: a dog or cat food is, legally, compound feed for a non-food-producing animal.Reg (EC) No 767/2009, Arts. 1–3

Before it, feed labelling was scattered across directives dating back to the 1970s, transposed differently in each Member State. The regulation consolidated seven of them — including Directive 79/373/EEC on compound feedingstuffs and Directive 96/25/EC on feed materials — into one directly applicable text: the same words are law in every Member State, with no national transposition in between.

It does not stand alone. Additives and their declaration rules come from the feed-additives regulation; establishment registration and approval from the feed-hygiene regulation; the rules for animal by-products — which pet food is made from — from the by-products regulation and its implementing rules; the enforcement machinery from the Official Controls Regulation.Reg (EC) No 1831/2003 · Reg (EC) No 183/2005 · Reg (EC) No 1069/2009 · Reg (EU) No 142/2011 · Reg (EU) 2017/625 The regulation’s technical annexes — tolerances and declaration tables included — were overhauled wholesale in 2017, so pre-2017 copies are out of date.Reg (EU) 2017/2279

For labelling, the part that matters is Chapter 4: Articles 11 to 25.

Who is responsible for the label?

The regulation names one accountable party: the person responsible for the labelling — the feed business operator who first places the feed on the EU market or, where applicable, the one under whose name or business name the feed is marketed.Reg (EC) No 767/2009, Art. 12

Three consequences follow. A private-label brand owner is responsible for the label carrying its name — outsourcing manufacture does not outsource the duty. An importer becomes responsible on first placement — the overseas factory’s record is irrelevant to an EU inspector. And operators further down the chain are not free of duties either: they must not supply feed they know, or should know, fails the rules.Art. 12

What the regulation requires on the label

Chapter 4 works as a stack: general principles, then mandatory lists, then specific regimes.

• No misleading. Labelling and presentation must not mislead the user — about what the feed is, what it contains, or what it does. This binds voluntary claims and design as much as the mandatory particulars.Art. 11(1)
• Presentation and language. The mandatory particulars must appear in their entirety, conspicuously, legibly and indelibly, in at least an official language of the Member State or region where the product is sold.Art. 14(1)
• General particulars for all feed. The type of feed, the person responsible, the establishment approval number, a batch or lot reference, the net quantity, an “additives” declaration, and moisture where relevant.Art. 15
• Feed materials. Sold as such, feed materials carry their own declaration rules — and the EU Catalogue of feed materials standardises their names.Art. 16 · Art. 24 · Reg (EU) No 68/2013
• Compound feed — i.e. pet food. Adds the target species, feeding instructions, producer particulars, the best-before date, the “Composition” list in descending order by weight, and the analytical constituents.Art. 17(1)
• Dietetic feed. Feed for a particular nutritional purpose may only be marketed as such for an authorised intended use, and carries the qualifier “dietetic” plus its own additional particulars.Arts. 9–10, 18 · Reg (EU) 2020/354
• Pet food’s own article. Pet food labels must offer a free telephone number or equivalent so buyers can ask about additives and category-declared ingredients.Art. 19
• Voluntary labelling and packaging. Voluntary particulars are permitted but held to the same no-misleading standard; packaging must be sealed, with listed exceptions.Arts. 22–23

For the particular-by-particular version — what each item must literally say on a pet food pack — see EU pet food label requirements.

Claims: what you may and may not say

Article 13 draws the boundary. You may draw attention to the presence or absence of a substance, a nutritional characteristic or process, or a particular function — provided the claim is objective, verifiable by the competent authorities and understandable to the buyer, and you can produce scientific substantiation on request.Reg (EC) No 767/2009, Art. 13(1)–(2)

The hard line: labelling may not claim that a feed will prevent, treat or cure a disease.Art. 13(3)(a) Health-adjacent positioning has two lawful routes — a substantiated functional claim, or a “dietetic” product matching an authorised particular nutritional purpose.Art. 18 · Reg (EU) 2020/354 Overstep, and the product risks classification as a veterinary medicinal product by presentation — a different legal regime entirely.Reg (EU) 2019/6, Art. 4(1)

From 27 September 2026 an extra layer applies to environmental claims: generic green claims such as “eco” or “climate neutral” without recognised substantiation are banned under the Empowering Consumers Directive.Dir (EU) 2024/825

Tolerances: how exact must declared values be?

Declared values — the analytical constituents above all — are enforceable numbers. Annex IV sets the permitted tolerances: constituent by constituent, how far an official laboratory’s measurement may deviate from the label’s declaration before the declaration is non-compliant.Reg (EC) No 767/2009, Annex IV The annex was replaced in full in the 2017 overhaul, so tolerance figures quoted from older copies are wrong.Reg (EU) 2017/2279

We deliberately quote no tolerance figures here: the values are banded per constituent and per declared level, and reading them off the consolidated annex for your specific declaration is the only safe way to use them.

Is the FEDIAF Code mandatory?

No. The FEDIAF Code of Good Labelling Practice for Pet Food is a self-regulatory code drawn up by the European pet food federation under the regulation’s provisions for Community codes of good labelling practice,Reg (EC) No 767/2009, Arts. 25–26 and its revised edition has been endorsed by the European Commission and the Member States. It is the operational reference most authorities and manufacturers work with — covering, among other topics, mandatory labelling information and voluntary claims.FEDIAF, Code of Good Labelling Practice for Pet Food

But endorsement is not legislation. Following the Code is voluntary, it cannot relax anything the regulation requires, and compliance is ultimately judged against the regulation. Treat the Code as the practice layer and the regulation as the law — where they seem to diverge, the regulation wins. (We cite the Code by name and section topic only and quote none of its text; the document is available from FEDIAF directly.)

How it’s enforced

The regulation sets no EU-level fines. Member States define the penalties, which must be “effective, proportionate and dissuasive”, and enforce them through national feed authorities under the EU official-controls framework.Reg (EC) No 767/2009, Art. 31 · Reg (EU) 2017/625 Real outcomes range from corrective orders and forced re-labelling to sales blocks, market withdrawal and fines under national law.

Cross-border, problem products surface in the EU’s Alert and Cooperation Network: 5,250 notifications in 2024, up 12 % year on year — and within the feed network, labelling issues account for roughly one reported case in ten.European Commission, ACN annual report 2024 A labelling failure is rarely a safety catastrophe; it is the slow, expensive kind of failure — the border hold, the delisting, the reprint, the missed launch window.

Checklist: am I affected?

• You manufacture pet food sold in any EU Member State — yes, for every market you sell into.
• You own a private-label brand made by a contract manufacturer — yes: your name on the pack makes you the person responsible for the labelling.Art. 12
• You import pet food into the EU — yes: first placement on the market makes you responsible, whatever the origin country’s rules said.Art. 12
• You sell online into other EU markets — yes: distance selling is still placing on the market, and each destination market’s language rules apply.Reg (EC) No 767/2009 · Art. 14(1)
• You distribute or retail without touching the label — the primary duty sits upstream, but you must not knowingly supply non-compliant feed.Art. 12
• You sell only in Great Britain — the same rulebook, inherited: the regulation lives on as assimilated UK law, with divergence emerging over time; Northern Ireland stays aligned with the EU version.
• You prepare food for your own pets — no: the regulation bites on placing feed on the market, not on home feeding.