The EU established new requirements for indicating the organic production of pet food, reflecting the increasing demand for organic products, as well as the role of the pet food sector in achieving the goals of the European Green Deal. Regulation (EU) 2023/2419 was published in the EU Official Journal on the 27th of October and it the majority of the obligations set out in it are already applicable.
The Regulation supplements Regulation (EU) 2018/848 on organic production and labelling of organic products and introduces specific requirements in relation to pet food when using terms referring to organic production, such as “organic,” “eco”, or “bio”. Strict requirements apply for using the terms in the sales description and using the organic production logo of the European Union, and slightly less strict requirements for using the terms only in the list of ingredients.
Sales description and the EU organic production logo: Terms referring to organic production can only be used in the sales description, and the EU organic production logo can only be applied if:
- At least 95 % of the agricultural ingredients of the product by weight are organic, and
- The pet food complies with a detailed list of production and processing requirements for organic products as detailed in Regulation (EU) 2018/848, such as compliance with the principles of good manufacturing practice, and carrying out the preparation of organic and non-organic products separately either in time or space.
List of ingredients: Besides these requirements, the terms can be used in the list of ingredients (but only in the list of ingredients) if:
- Less than 95% of the agricultural ingredients of the product by weight are organic and comply with the production rules set out in Regulation (EU) 2018/848,
- Only feed additives and processing aids authorized are used, and the pet food complies with the detailed production rules and processing techniques set out in Regulation (EU) 2018/848.
Special requirements for ingredients stemming from hunting or fishing: If the food contains ingredients stemming from hunting or fishing, additional requirements apply. Terms referring to organic production can only be used in both the sales description and in the list of ingredients if:
- The main ingredient is a product of hunting or fishing,
- The terms are clearly related in the sales description to the organic ingredient other than the main ingredient,
- All other agricultural ingredients are organic,
- Only authorized feed additives and processing aids are used in the processing, and the pet food complies with the detailed production rules set out in Regulation (EU) 2018/848.
In all cases it shall be indicated in the list of ingredients which ones are organic, and generally, the total percentage of organic ingredients in proportion to the total quantity of agricultural ingredients. In terms of formatting, all the information, as well as the “organic”, “bio”, and “eco” terms, shall appear in the same colour and identical size and style of lettering as the other indications in the list of ingredients.
These requirements serve as an important step in combatting greenwashing, as they further specify the quality of organic products in case of pet food. As the legislative requirements are becoming stricter, it is becoming increasingly important for companies to pay attention to how they communicate their sustainability-related performance. For legal advice tailored to your needs, our team of green regulation experts are eager to assist you.
