Pet food produced after 1 Sep 2019 may continue using the labels prepared under previous feed regulation, attached with additional labels until 1 Mar 2020. Thereafter, all pet food circulated in China shall conform to the “Rules on the Labeling of Pet Food” and MoARA will take necessary supervisory activities accordingly.
On 2 Sep 2019, the Chinese Ministry of Agricultural and Rural Affairs (MoARA) issued the Announcement 210 of 2019 to offer a 6-month extension for the transition between earlier and new labeling requirements for pet food. These measures were taken at the request of pet food producers, who were previously ordered to attach new labels on pet food produced after 1 Sep 2019. MoARA realized the large stocks of old labels and agreed that the old labels attached with additional labels can be allowed for pet food produced prior to 1 Mar 2020. Thereafter, MoARA will take necessary supervisory activities against pet food labels.
Feed and Pet Food Regulations
On 27 April 2018, MoARA promulgated 6 ministerial regulation regarding the importation, production, hygienic standard and labeling requirements on pet food, which separated pet food from the overall feed management. The product name, nutrient composition, guaranteed value, beneficial claims and overall layout should comply with the “Rules on the Labeling of Pet Food”.
Additional Labels Attached
The attached labels should meet the following requirements:
- The product generic name should comply with the “Rules on the Labeling of Pet Food”;
- The guaranteed value of feed ingredient not yet included in the old label but required by the “Rules on the Labeling of Pet Food” should be included;
- The attachment should be labeled with the phrase” This product conforms to the Rules on the Labeling of Pet Food ”;
- The additional labels should be attached at the prominent place of the product/old label and the font size of the product generic name in the attachment should be at least as big as that in the old label;
Statutory Classification and the Generic Names
The MoARA’s regulation explicitly classified pet food into formula pet food (staple food), pet additive premix(nutritive supplement) and other pet food(treats chews) and only the generic names specified in the “Rules on the Labeling of Pet Food” can be recognized as the statutory product name.
The generic names should also indicate the applicable pet species (cat/dog breed and size) and life stage (infancy, adult, senility, pregnancy and lactation), if not the product will be recognized applicable to all breeds and life stage by default.
If amino acids, vitamins minerals, trace elements, enzymes and other nutritive additive was used in a pet additive premix, the generic name can be added with the additive accordingly.
If a pet food was used for specific pathological and physiological conditions, the word “prescriptive” must be added into its generic name and product label should be added with the phrase “Please use under the instruction of a licensed veterinarian” and the applicable pathological and physiological conditions should also be specified. So far, only 19 typical phrases of pathological and physical conditions and major nutritional characteristics can be used directly. Prescriptive pet food for other conditions will be required for additional supporting information such as scientific data or formula composition to prove the effectiveness and a new phrase can be placed.
In order to offer better transparency to consumers and promote China’s pet food market, the labeling rules put forward higher demands on content structure, ingredient/additive naming, nutrition index and beneficial claims.
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