Pet food production
Whereas the market for pet food used to be quite manageable, today a much broader range of products is in demand. This is mainly due to the changed position of pets in society and the increased awareness of pet owners for the nutrition of their animals.
If you want to produce and market a pet food, you initially face a multitude of legal requirements and it is often difficult to know how to get started.
To help you get started, we have put together an information sheet with explanations, the most important regulations and a checklist for you. You can find this at the end of this page under Downloads.
Before the start of production of pet food
In order to be able to distribute (market) feed for pets, the first step is to register your activity with the Federal Office for Food Safety (BAES). In terms of feed law, this is a registration in accordance with the Feed Hygiene Ordinance. If you use meat or animal by-products in your products, you must also register with the veterinary authority responsible for you (official veterinarian).
While the notification to the BAES is a formal act (description of your activity in a pre-prepared form; thereafter, you will receive a fee estimate based on your information and will be subject to the control of the BAES), the official veterinarian will inspect your premises on site and, if the requirements for animal by-products are met, will issue an operating license. After these formal legal points, nothing more stands in the way of the actual production.
As a feed producer, however, you are required to follow the principles of the HACCP concept (Hazard Analysis and Critical Control Points) during production. This requires you to look in advance at the individual production steps your product goes through and consider where there may be potential risks of contamination (e.g. with salmonella or chemicals), how you can identify these and what measures you will take if the worst comes to the worst.
Ongoing controls on pet food production
Another important point is the self-monitoring of products and raw materials (analyses for undesirable substances, such as heavy metals), which you are legally obliged to carry out on a regular basis. It should be noted here that the analysis parameters are highly dependent on the matrix in question. It is known that especially in the field of chewing articles (e.g. pig ears, dried meat pieces etc.) contaminations with Salmonella and Enterobacteriaceae occur increasingly and here microbiological examinations are important. The examination of at least these two groups of germs is mandatory for the production of products from or with animal by-products. In the case of plant components, on the other hand, analyses for pesticides, mycotoxins, heavy metals or botanical contaminants are often relevant.
Proper labeling must be ensured for the finished product, as there are clear legal regulations and criteria that must be met for this as well.
As a feed manufacturer, you are subject to regular inspections by the Federal Office and - if meat and animal by-products are processed - by the official veterinarian. Therefore, in the event of an inspection, you should be able to demonstrate the above-mentioned self-monitoring and correct labeling in order to avoid complaints.
Important legal texts (no claim to completeness)
EU-wide valid legal texts:
- VO(EG) 178/2002 (General principles/requirements for food-incl. feed)
- VO(EG) 1069/2009 (Regulation on animal by-products)
- VO(EU) 749/2011 (Hygiene rules for animal by-products)
- VO(EU) 68/2013 (Catalogue of straight feeding stuffs)
- Directive 2002/32/EC (Undesirable substances)
- Regulation (EC) 767/2009 (Labelling of feed)
- VO(EU) 2020/354 (dietetic feed)
- RL 82/475/EEC (Category Labelling for Petfood)
- VO(EC) 999/2001(BSE/TSE)
- VO(EG) 396/2005 (pesticides)
- VO(EG) 1831/2003 (additives)
- VO(EG) 183/2005 (feed hygiene)
In addition in Austria:
- FeedstuffsAct 1999 as amended from time to time
- Feed Regulation 2010 in the respective valid version
The above-mentioned EU legal texts can be found, in their consolidated form, here.
The Austrian legal texts listed above can be found here.
Information and data sheets for notification to the BAES can be found here.
From a purely legal point of view, there is no distinction between farm animal feed and pet food, with the exception of deviating labeling regulations. The main difference is the intended use in the form of feeding to animals that are not used for food production. When using feed additives, it must also be taken into account that not all additives are approved for all target animal species.
As defined in Regulation (EC) 178/2002, feed means "substances or products, including additives, whether processed, partially processed or unprocessed" intended for oral animal feeding.
In general, a distinction is made between straight feed (= feed materials) and compound feed (e.g. complete feed and supplementary feed). In addition, there are feed additives and premixes. Veterinary medicinal products are not subject to feed law.
Feed law is regulated nationally by the Feed Act 1999 and the associated Feed Regulation 2010. The Act and the Ordinance regulate, in particular, the responsibility of the authorities, the rights and obligations of both the control bodies and the feed businesses, national deviations from EU law and possible sanctions in the event of a breach of feed law provisions. Substantive provisions are found almost exclusively in the relevant EU legal texts, with the essential requirements for use and placing on the market summarized in Regulation (EC) 767/2009. A feed may only be placed on the market and used if it complies with the national and EU legal rules; above all, it must be safe and have no harmful effects on animals, humans or the environment.
In the case of the production of pet food and business transactions with other commercial enterprises (B2B), feed businesses require registration with the Federal Office for Food Safety (BAES). This does not apply to the sale of pet food to end consumers or pet owners (B2C). Furthermore, it should be noted that pet food using animal components (ABP = animal by-products) may only be produced if an approval as an ABP plant is also available. Approval as a TNP plant is granted by the competent veterinary authority. Due to the approval requirements, it is not possible to produce pet food using animal components (offal, meat, minced meat, etc.) for commercial purposes in a kitchen that is also used for food preparation for humans. Of course, this does not apply to the preparation of food for one's own pet.
Farms in Austria can register via the online portal of the Federal Office for Food Safety. The requirement of an approval according to the Feed Hygiene Regulation (EC) 183/2005 will hardly be encountered in practice, it is much more likely that due to the use of animal by-products an approval as an ABP farm according to Regulation (EC) 1069/2009 is required. For this, the veterinary authority of the regionally competent district administrative authorities must be contacted.
In Austria, the Federal Office for Food Safety (BAES) is responsible for controlling the placing on the market of feed, premixtures and additives, as well as for the approval and registration of commercial operations. For more information, check out the BAES website. The production of pet food using animal by-products is subject to control by the competent veterinary authority up to the final product (saleable goods) and is usually carried out by the official veterinarian.
AGES offers a comprehensive range of tests for all types of feed. The central contact for such private-sector orders is the Institute for Animal Nutrition and Feed. The range of our testing methods includes, among others, a number of nutrient-relevant (ingredients and additives), microbiological, molecular biological and microscopic parameters, as well as the detection of carry-over and contamination of feed with undesirable and prohibited substances. For analyses that are not possible at AGES, we maintain close cooperation with international partner laboratories.
In this case, it is also possible to have the feed analyzed at the Institute for Animal Nutrition and Feed of AGES. For information on ordering, sample shipment and processing, please visit our website(Feed Service & Safety - AGES) or use our online order form, which is available under Downloads. If you have any questions, please do not hesitate to contact us by e-mail(firstname.lastname@example.org) or by phone(+43 505 5533 216).
The designation of a product as a complete feed is only permissible if the feed in question meets all nutrient requirements in accordance with current requirement standards of the animal in question. This also applies to its content of certain ingredients, additives and composition. In Europe, the guideline of the European Pet Food Association(FEDIAF, Nutritional Guidelines) is often used as a reference for nutrient requirements.
However, other guidelines may also be used, provided they meet international standards and are traceable. In the case of supplementary feeds, it should be noted that these can only cover an animal's requirements in addition to other feeds. Complete and supplementary feeds are compound feeds, whereas straight feeds are only one component of a compound feed and are not suitable for completely meeting the animal's needs. Reward products or "treats" can be compound feeds or straight feeds (e.g., pig ears) and must be considered when measuring the total daily ration.
The greatest challenge for pet owners is BARF products (raw feeding), as it is usually difficult to estimate how much of the total requirement will be covered. Apart from the hygienic risks (salmonella) due to raw animal products, in such cases the sufficient supply of additives (trace elements, vitamins) is usually not considered enough.
It should be remembered that our pets also regularly change their eating habits. If the usual food is suddenly refused by your pet, this may be due to the recipe and may be caused by the change of a raw material component. If you suspect, based on appearance or odor, that the pet food is questionable or even spoiled, the first step would be to stop feeding it to your pet. If any health problems or symptoms occur, such as vomiting, diarrhea, fatigue, fever, breathing difficulties or cramps, it is advisable to consult a veterinarian.
If desired, the feed can be tested at the Institute for Animal Nutrition and Feed (AGES) for nutrient and additive content or microbiological quality. In the case of existing symptoms in your pet and the suspicion that the feed could be the cause, we also ask for this information or the assessment of the attending veterinarian to be able to offer the most targeted analysis possible. The narrower a suspicion can be narrowed down, the lower the costs for the analysis will usually be.
This claim is made very often, but is not true for commercial pet foods. Often, such claims are also based on misunderstandings with regard to the legally specified terms, such as "animal by-products". All components of a pet food must comply with feed law requirements and, in the case of animal products, come exclusively from animals fit for slaughter, from which food for humans is also obtained.
The pet food industry, under the supervision of the veterinary and feed control authorities, sets very strict hygiene and quality standards, often equivalent to those used in the production of food. As a general rule, in the case of animal products, only those in Category 3 may be processed into pet food. These are raw materials that are de facto of "food quality".
In practice, in addition to skeletal muscle (= meat), this often includes offal, which can no longer be marketed as food to the same extent as in earlier times, but which is a suitable and important source of nutrition for pets.
Your personal checklist for starting pet food production
- Notification or registration as a feed business with the Federal Office for Food Safety (BAES) on:
- Notification to the competent veterinary authority (magistrate or official veterinarian of the competent BH, if you use meat or animal by-products) on:
- The following production steps/sites could be entry points for contamination in my business (hazard analysis as an essential part of the HACCP principles):
- I would take the following steps in case of contamination:
- Which products do I use, where are the specific risks and which self-controls could be useful:
- My labels comply with the legal requirements
We wish you good luck in the production of your pet food!
Last updated: 10.10.2023