By Pure Majesty Pets Editorial Team

A useful label has to pass two tests at once: it must allow the manufacturer to substantiate each statement and give the retailer enough information to decide whether the product belongs on a physical or digital shelf. In the European Union, that review begins with product classification and ends with consistency between packaging, sales listings and supporting records. This guide proposes five checks that manufacturers and retailers can carry out together.

Define the category and market before writing

The word supplement is a commercial description, not a uniform legal classification. Depending on its composition, intended use and claims, a dog product may be marketed as complementary feed, a feed material or under another regulated category. The team should first establish the applicable category and countries of sale. That decision determines the mandatory particulars, language, declaration of relevant additives and types of claims permitted.

The same wording should not be transferred automatically from one market to another. A manufacturer preparing an EU version needs to review Regulation (EC) No 767/2009 and the relevant additive authorisations. A retailer should request the version intended for the country of sale, rather than a global label that mixes requirements or expressions from different jurisdictions.

Keep mandatory information in one controlled source

Regulation (EC) No 767/2009 requires labelling to be legible and not misleading. Depending on the feed category, mandatory particulars include the type of feed, identification of the operator responsible for labelling, the batch reference, net quantity and the applicable declarations of composition, additives and analytical constituents. For pet food, Article 19 also requires a free telephone number or another appropriate means of communication through which buyers can request additional information.

The online product listing belongs within the same control process. In distance selling, much of the mandatory information must be available before the buyer concludes the purchase. The manufacturer should maintain an approved master product sheet and provide the retailer with digital copy drawn from that source. The retailer can then compare the product name, serving directions, net weight, ingredients and warnings across the listing, packaging and commercial documents.

Separate the marketing promise from a substantiated claim

Article 13 of Regulation (EC) No 767/2009 permits claims about the presence or absence of a substance, a nutritional characteristic or a related function, provided that the claim is objective, verifiable by the authorities and understandable to the user. The person responsible for labelling must have scientific substantiation available when the feed is placed on the market. Claims that feed prevents, treats or cures disease are prohibited, subject to the exceptions expressly provided in the legislation.

In practice, each claim should be linked to specific supporting evidence. A general phrase such as digestive support still requires a clear account of the composition, intended function and available evidence. A promise such as eliminates dermatitis moves into disease-treatment territory that is incompatible with an ordinary complementary-feed claim. The manufacturer should be able to supply a substantiation file; the retailer should avoid turning cautious manufacturer wording into a stronger promise on the sales page.

Check ingredients and additives without embellishment

Regulation (EC) No 1831/2003 establishes a common authorisation procedure for feed additives. An authorisation may specify the animal species or category and conditions of use, including limits where applicable. The Union register and the relevant authorisation acts are therefore practical checks: the presence of a substance in other products does not establish that it may be used as an additive for any purpose or at any quantity.

Ethical labelling starts with accuracy. A name used in marketing should reflect the substance’s actual status. Declared amounts should come from the approved formulation, and terms such as patented, clinical or veterinary should not imply validation that does not exist. A longer ingredient list does not establish greater effectiveness. For the retailer, a defensible product is one whose manufacturer can explain every line without changing terminology between packaging, technical specifications and advertising.

Build a shared manufacturer and retailer file

A version-controlled product information package helps prevent discrepancies. It does not need to be lengthy, but it should make it possible to reconstruct what was approved, why and for which country. These five checks provide a practical starting point before adding a product to the range.

Use warning signs to make timely decisions

Retailers do not have to repeat the manufacturer’s entire regulatory assessment. They can, however, pause a listing when a concern remains unanswered: an undefined category, missing serving directions, ingredient names that change between documents, a cure claim, unavailable substantiation or an online listing that makes stronger claims than the packaging. The aim is to request a coherent file before presenting the product to customers.

For manufacturers, the same checks can reduce late corrections. When regulatory, commercial and e-commerce teams work from one controlled source, they limit discrepancies between formulation, claims, artwork and sales channels. Retailers then receive information they can explain to buyers and update without improvisation.

References

Regulation (EC) No 767/2009 on the placing on the market and use of feed, particularly Articles 11, 13 and 15–19. EUR-Lex. Source

European Commission. Feed marketing. Source

Regulation (EC) No 1831/2003 on additives for use in animal nutrition. EUR-Lex. Source

FEDIAF. Code of Good Labelling Practice for Pet Food. Source

Author note

Pure Majesty Pets Editorial Team represents a dog-wellness brand. This commercial affiliation is disclosed. This article provides general information and does not replace product- and market-specific legal or regulatory advice.

For more information about dog supplement ingredients and label transparency, visit: Pure Majesty Pets.