About the Author:

Lin Fang(https://www.linkedin.com/in/fang-lin-fiona/) 

Regulatory Analyst, Agrochemical Department

Aside from disease treatment and prevention effect, pet food producers can display beneficial claims neighboring the product name with appropriate illustration through ingredient, product characteristic and function aspects. These claims will require supporting documentation, including openly published literature, textbook, formula composition and test data. Some of the claim phrases are very similar and easily confused, thus discussed in the next paragraph.

1) Claims of Feed Ingredients

a) Feed material

If a pet food claimed to contain specific feed material, the material name and its percentage should be displayed on the ingredient list along with the category name, then the name of the material and percentage should be included between brackets after the category name. The percentages of dehydrated vegetables, fruits, meat and fish can be claimed after water-recovery calculation by using different parameters. If the water-recovery calculation was involved, all dehydrated materials used should be calculated simultaneously.

There are 3 types of claim phrases which may be used depending on the percentage of the feed material(s) :

·Formula of single or multiple feed material(s): the percentage of one feed material should be greater than 26% and neither of the materials claimed should be lower than 3%;

·Formula containing single or multiple feed material(s): the percentage of (at least one) feed material should be greater than 14% and none of the materials claimed should be lower than 3%;

·Containing single or multiple feed material(s): the percentage of (at least one) feed material must be greater than 4% and none of the materials claimed should be lower than 3%;

b) Characteristic Ingredient

If a feed material, compounded flavor or flavor enhancer can give the product a specific flavor, the flavor can be claimed. If the percentage of the feed material is less than 4%, but the feed material can offer the pet food a specific feature, the product can claim to contain the feed material. The nutritive additive and other additives that offer the product a specific feature can also be claimed and the guaranteed value of the nutritive additive or the percentage of the other additive should be labeled.

c) XXX-Free and Comparative Claims

Pet food can also claim to be free of specific ingredients by using the phrase “XXX-free” or “without XXX”, yet such claim can only be made targeting existing feed materials and/or additives. If the glutenous ingredient in pet food is less than 20mg/g, the product can be claimed as “gluten-free”.

If comparative phrases such as “high-protein” or “low-sugar” were used, other products derived from the same product by the company should be specified for reference purposes, and the percentage increase or reduction of the element should be validated through the formula and should be higher than 15%.

2) Product Features

It is not uncommon to see descriptive phrases such as “natural”, “fresh”, “low-fat”, “new” “upgraded”, ”XXXX International standard” and” AFFCO certification” on product labels. Nevertheless, these claims must meet a number of requirements, including processing method, nutritional composition and additional supporting documents or test data.

a) “Nature”

In the case all feed materials and additives used in pet food were unprocessed and obtained using non-chemical methods, or if only the physical method, hot-working, extraction, purification, hydrolyzation, enzymolysis, formation, fermentation or fumigation were used, then pet food can be claimed as “natural” or “natural food”. If only the vitamins, amino acids, minerals used were chemically synthesized, the product can also claim to be natural food, but the chemical synthesized should be added into the claim. If two or more chemically synthesized vitamins, amino acids, minerals were used, the category name can be used in the claim. If specific materials or additives were non-chemically synthesized, a special claim on the ingredient may be placed accordingly.

 b). “Fresh”

If the feed material used in the product goes only through refrigeration (this does not include cooking, drying and frozen processes), without including sodium chloride, preservatives and other similar additives, the feed material may be claimed as “Fresh”.

c). “Low-fat” and “Low-calorie”

The “low-fat” and “Low-calorie” dog/cat food should be supported by verifiable data:

d). “New product”, “Upgraded formula” and “Upgraded product” and “Conforming with international standards”

Such claims can be placed on product labels for up to 18 months and should be provided with sufficient evidence. If the pet food claimed to comply with international standard or have obtained a certification from an overseas government/organization, the company should be ready to submit test reports or additional supporting documents upon request.

3. Product Function

If the feed material or additive used in the pet food or a nutritive element in the feed material/additive has a particular function such as growth reinforcement, development, physiological function and animal health, a function claim can be made. If so, the corresponding percentage of the relevant feed material/additive should be mentioned on the “Product Composition” or “Guaranteed Values” part of the label. If the pet food has a preventive effect on non-disease problems such as hair bulb or tartar accumulation, the function claim can be made by using the phrase “XXX-prevention”.

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