About the Author:

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

Regulatory Analyst, Agrochemical Department

In 2018, the Chinese Ministry of Agricultural and Rural Affairs (MOARA) issued 6 ministerial regulations regarding the importation, production, sanitary standard and labeling of pet food. All types of pet food circulating in China have been asked to comply with the label requirements starting 1 Sep 2019:

1.Administrative Measures for Pet Food;

2.Entry Criteria for the Production of Pet Food (Domestic producers);

3.Rules on the Labeling of Pet Food (“labeling requirements”);

4.Rules on the Sanitary Standard of Pet Food;

5.Application Material for the Production License of Formula Pet Food;

6.Application Material for the Production License of Pet Additive Premix (health supplement);

On the whole, pet food is independently regulated from the overall feed regulation system. Both products nonetheless share similarities in a number of issues: the production licensing on homemade products, registration of imported products (MoARA), inspection and quarantine supervision of imported feed materials and products (GACC registration overseas producers from sourcing origin approved), catalogue management of existing feed materials and additive and rigorous review of new feed materials and additives. As pet food is a type of public consumer good, product claims are individually specified in China’s pet food regulations. For example, the uses of phrases such as “fresh”, “natural”, “new formula”, “low-fat”, ”low-calorie” must be supported by substantial evidence including the use of raw materials, product composition, processing technology and metabolizable energy (ME) per unit weight, etc. To help pet food companies navigate the transition into upcoming labeling requirements, this two-installment article will introduce essentials of pet food labeling and offer practical advice on how to correctly use product claims while displaying their market competitiveness.

1. Preparing a Label: The Essentials

A pet food label must contain at least 11 elements, including: product name, composition, guaranteed analytical value of product, net content, storage condition, use instruction, caution, production date, expiry date, name and address of the producer (and Chinese importer), production/registration number and the number of executive quality standard (homemade products)/test report of quality re-inspection (imported products).

All pet food must be labeled with the phrase “This product conforms with Chinese Sanitary Standards of Pet Food”. The sanitary standard specified testing methods and 21 maximum limits for pet food contaminants; 8 inorganic and nitrogenous substances, 8 fungimycins, 1 natural plant toxin, 6 organic chlorides and 2 microbes. These limits are mandatory requirements for pet food and serve as a reference for MoARA’s market surveillance.

a) Pet Food Classification and Generic Names

China’s pet food regulation classifies pet food into formula pet food, pet additive premix (nutrition supplement) and other pet food, with only generic names recognized as product names.

b) Use Precaution and Prescription Pet Food

Pet food using animal-derived material should be labeled with the phrase “Shall not use to feed ruminant animals” and prescription pet food should also include the phrase “Please use under the instruction of a licensed veterinarian”. The labelling requirements specify 19 typical phrases for prescription pet food targeting different pathological and physiological conditions and major nutritional characteristics so producers may use these phrases directly. If the prescription pet food is used for other conditions and nutritional characteristics, the producer should provide additional supporting information such as scientific data or formula composition to prove the effectiveness and a new phrase should additionally be placed on the label.

c) Product Composition (Ingredient List)

Only feedstuffs included in the “Catalogue Of Feed Material” and feed additives included in the “Catalogue Of Feed Additive” can be used for pet food production, which should be listed on the “feed material” part and the “feed additive composition” part separately in descending order based on the amounts used.

Feed materials can be expressed in their specific ingredient names or category names. The specific ingredient name should be exactly consistent with names listed in the “Catalogue of Feed Material”.

Note that the category names usable for pet food labeling are not fully consistent with the classification in the “Catalogue of Feed Material” and their differences are as follows:

If a flavoring agent was compounded with animal hydrolysates included in the “Catalogue of Feed Materials”, it should be expressed as “pet food compounded flavor” or “flavor enhancer” in the “feed material” part of the ingredient list.

Feed additives should be included in the “feed additive composition” part with their specific names and antioxidants, colorants, flavoring agents, feed attractants can be expressed in their category name.

d). Guaranteed Values (of Product Analytical Composition) 

Guaranteed values mean the previously agreed-on quality commitment. Labeling requirements specify the minimum quality indicators which may be included:

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