Manufacturing your own pet foods This guide covers the manufacturing of pet food with particular emphasis on the domestic production of pet food and treats in your own home - for example, home-made dog biscuits. Before you start manufacturing any pet food please contact your local trading standards service for advice as feed businesses, including all pet food manufacturers, must not operate without being registered or approved (as appropriate) with their local authority - usually the trading standards service. Additionally, EU regulations require that the Animal and Plant Health Agency (APHA - formerly the Animal Health and Veterinary Laboratories Agency), as the competent authority, approves manufacturing plants where pet food uses or incorporates products of animal origin - for example, eggs, meat, milk, butter, honey. This includes premises manufacturing pet food in domestic houses even if using products of animal origin deemed fit for human consumption. The pet food must be labelled with mandatory labelling requirements, which are sometimes still referred to as a 'statutory statement'. In the guide What is a pet food? Manufacturing pet food Local authority registration or approval AHVLA approval for products incorporating products of animal origin Labelling Guidance on the manufacture of safe pet foods Penalties Key legislation What is a pet food? A pet food is any product produced by a pet food manufacturer (even if produced in your own home) - whether processed, partially processed or unprocessed - intended to be ingested by pet animals after placing on the market. Usually pet food is in the form of a coarse mix, kibbles / biscuits, or as a wet food in tins or pouches, but it also includes, for example, dog cakes and other similar treats. Std56 02/15
Manufacturing pet food The pet food industry is highly regulated (see 'Key legislation' below), and this legislation applies equally to what can be described as commercial pet food manufacture on an industrial scale and to smaller scale manufacturers, perhaps in a person's private home. Legislation on animal feed is at European Union (EU) level (rather than coming from the UK) and the overarching principle is that animal feed, including pet food, must be produced in hygienic conditions, and that the finished product is safe, is not harmful to animal or human health and is fully traceable. The main pieces of legislation to be considered in the manufacture of pet food, even in your own home, are described below. EU Regulation (EC) No 183/2005 laying down requirements for feed hygiene requires that feed safety and hygiene be considered at all stages of the production of pet food, wherever this may be carried out. The Regulation sets out the operating standards to which all pet food manufacturers must comply. The Regulation summarises the feed hygiene requirements in terms of: facilities and equipment personnel production quality control including Hazard Analysis Critical Control Points (HACCP - feed safety management system) storage and transport record-keeping, including traceability complaints and product recall All pet food manufacturers must also comply with EU Regulation (EC) No 767/2009 on the placing on the market and use of feed. This legislation covers matters such as: safety and marketing requirements - special regard should be given to the species and type of pet you are manufacturing food for stringent labelling, presentation and packaging requirements, including analytical declarations manufacturer responsibilities substantiation of any claims, including nutritional claims prohibition on the misleading of purchasers prohibition on making medicinal claims
This Regulation also transposes EU provisions on undesirable substances and particular nutritional purposes - for example: the maximum levels of various contaminants allowable in pet food (for example, arsenic, lead, dioxins and certain pesticides) certain substances that must not be used in feed Regulation (EC) No 1831/2003 on additives for use in animal nutrition contains provisions for the control of additives in pet food. These controls relate to the additives (including vitamins, colourants, flavourings, and binders) authorised for use in animal feed and covers matters such as: categorisation of feed additives authorisation of feed additives labelling and packaging of feed additives provisions relating to an EU register of additives EU Regulation (EC) No 1069/2009 laying down health rules as regards animal by-products and derived products not intended for human consumption relates to animal by-products - for example, material of animal origin comprising those parts of animals that are either deemed surplus to human consumption or are not normally consumed by people in the UK, and derived from animals inspected and passed as fit for human consumption prior to slaughter. It may also include products of animal origin - for example, eggs, milk, butter, honey, etc. Animal materials or animal products of this nature, which are not intended for human consumption, are classified as 'animal by-products' under this Regulation (usually category 3 ABP). Such material must be free of any transmissible disease, which therefore excludes material from dying, diseased or disabled animals. Approval by APHA is required for pet food manufacturers using category 3 ABP. This includes premises manufacturing pet food in domestic houses whether using meat fit for human consumption or category 3 ABP. Information and guidance on the applicable legislation can be found on the Food Standard Agency website (http://www.food.gov.uk/businessindustry/farmingfood/animalfeed/animalfeedlegislation/#.uqnzmprdwa o).
Local authority registration or approval EU Regulation (EC) No 183/2005 laying down requirements for feed hygiene requires feed businesses to be approved or registered with their local authority, as appropriate (see how to apply for approval or registration on the Food Standards Agency website (http://www.food.gov.uk/businessindustry/farmingfood/animalfeed/animalfeedlegislation/approvregfeedgui dance)). This applies to all pet food manufacturers regardless of scale. All pet food manufacturers need to apply for registration or approval with their local authority under EU Regulation (EC) No 183/2005 and must not operate without such registration / approval. Please see the attached form for application for registration / approval on page 7. EU Regulation (EC) No 183/2005 contains various conditions that pet food manufacturers have to comply with. The requirements of annex II (PDF 1.1MB) (http://www.businesscompanion.info/~/media/businesscompanion/in-depth-guide-attachments/pdf-attachments/feed-hygienefor-transporters-andhauliers_all_183_2005_annex2_dec13.ashx?la=en) of the Regulation must be complied with in relation to all pet food manufacture. Registration with your local authority is free. If approval is required then a fee is payable. APHA approval for products incorporating products of animal origin If the manufacture of pet food, even in your own home, includes ingredients from products of animal origin and even if these products are fit for human consumption - for example, using ingredients bought direct from a supermarket - then APHA approval is required (in addition to local authority registration or approval). This arises from the fact that once the decision is made to use human foodstuffs containing products of animal origin in the manufacture of pet food, then this material becomes a category 3 animal by-product (ABP). APHA approval as a pet food plant is always required to handle such ABP. In order for such approval to be granted in, for example, a domestic home, strict separation of the pet food ingredients from food still intended for human consumption must be achieved at all stages of processing in order to ensure both human and animal health. Such separation may be achieved by having totally separate facilities - for
example, a dedicated kitchen, work area and storage area - or by strict time separation with a fully documented clean-down programme. Hazards need to be controlled by a documented HACCP plan supplemented by prerequisite programmes. A requirement of APHA approval is an ongoing microbiological testing regime for salmonella and enterobacteriaceae. This must be completed at a UKAS-accredited laboratory in accordance with ISO 17025 for ABP purposes. A list of compliant laboratories can be found on the UKAS website (http://www.ukas.org/testing/singlesearch.asp). Further guidance on pet food manufacture containing ABP can be found on the GOV.UK website (https://www.gov.uk/using-animal-by-productsto-make-pet-food). Labelling Pet food must be labelled with both the general mandatory labelling requirements and specific mandatory labelling requirements as required by EU Regulation (EC) No 767/2009 on the placing on the market and use of feed. Detailed information on the labelling requirements and labelling presentation of pet food can be found in 'The retail sale of pet food' (http://www.derbyshire.gov.uk/images/std20_tcm44-90298.pdf). Guidance on the manufacture of safe pet foods The European Commission has formally recognised the FEDIAF (Fédération Européenne de l'industrie des Aliments pour Animaux Familiers - also known as the European Pet Food Industry Federation) Guide to Good Practice for the Manufacture of Safe Pet Foods (http://www.fediaf.org/self-regulation/safety/). The main aim of this document is to provide guidance to ensure that pet food is fit and safe for the purpose of feeding pets, whilst at the same time meeting the relevant requirements of European legislation. The guide covers the production, storage and distribution of pet food manufactured in Europe as well as third country imports into the EU but should not be used as a replacement for the national regulatory requirements. Penalties Failure to comply with these requirements is a criminal offence. The maximum penalty on conviction is an unlimited fine and/or two years' imprisonment.
Key legislation EU Regulation (EC) No 1831/2003 (http://eur-lex.europa.eu/legal- content/en/txt/?qid=1423589488623&uri=celex:02003r1831-20100901) on additives for use in animal nutrition Feed (Hygiene and Enforcement) (England) Regulations 2005 (http://www.legislation.gov.uk/uksi/2005/3280/contents/made) EU Regulation (EC) No 183/2005 (http://eur-lex.europa.eu/legal- content/en/txt/?qid=1423589603506&uri=celex:02005r0183-20120916) laying down requirements for feed hygiene EU Regulation (EC) No 767/2009 (http://eur-lex.europa.eu/legal- content/en/txt/?qid=1423589686052&uri=celex:02009r0767-20100901) on the placing on the market and use of feed EU Regulation (EC) No 1069/2009 (http://eur-lex.europa.eu/legal- content/en/txt/?qid=1423589757884&uri=celex:02009r1069-20140101) laying down health rules as regards animal by-products and derived products not intended for human consumption (Animal byproducts Regulation) Animal Feed (England) Regulations 2010 (http://www.legislation.gov.uk/uksi/2010/2503/contents/made) EU Regulation (EU) No 142/2011 (http://eur-lex.europa.eu/legal- content/en/txt/?qid=1423589824504&uri=celex:02011r0142-20140715) implementing Regulation (EC) No 1069/2009 and Directive 97/78/EC Animal By-Products (Enforcement) (England) Regulations 2013 (http://www.legislation.gov.uk/uksi/2013/2952/contents/made) Where can I get further help? For further details or clarification contact Derbyshire Trading Standards at: Chatsworth Hall Chesterfield Road Matlock Derbyshire DE4 3FW Telephone: Businesses Call Derbyshire 01629 533190 Consumers Citizens Advice consumer helpline 03454 040506 Fax: 01629 536197 Website: www.derbyshire.gov.uk/tradingstandards
We want everyone to be able to understand us. On request, we will arrange: Language interpreters, including for sign language Translation of written materials into other languages Materials in large print, on tape or in Braille. To ensure that you are looking at the most up-to-date version of this leaflet, please visit our website at http://www.derbyshire.gov.uk/images/std56_tcm44-244521.pdf or telephone us on 01629 536166.
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Derbyshire County Council Health and Communities Trading Standards Division Chatsworth Hall Chesterfield Road Matlock Derbyshire DE4 3FW Application with a view to Registration or Approval under the EC Feed Hygiene Regulation (183/2005) To: Derbyshire County Council I am applying for the following premises to be registered/approved (delete as necessary) under the above legislation. The information required is set out below: Name or business name of the feed business to which this application relates: Name: Business Name: 2. Address and associated details of the premises where the activity requiring registration or approval is undertaken or to be undertaken: Address: Telephone No: Fax No: E-mail: 3. Activity or activities carried out on the premises (please see code and activity descriptions overleaf) Code: Activity: 4. Do you use a fossil fuel powered dryer to dry grain, please indicate; yes no. NB for office use only if applicant answered yes above please add R15 to the licence field
5. Applicant details: Name: Address (only complete if different to the address indicated in at 2 above): 6. Premises currently approved or registered under the Feeding Stuffs (Establishments and Intermediaries) Regulations 1999 (Please indicate below in the appropriate box if the business is currently approved or registered, and provide its approval/registration number) Registered Yes/No (delete as appropriate) Approved Yes/No (delete as appropriate) Approval/Registration Number (if available): Signature of Applicant: Date:
EU FEED HYGIENE REGULATION (183/2005) Approval and Registration activities Notes: Activity codes remain unchanged but the notes have been supplemented and examples of feed businesses included. References to manufacture and/ placing on the market refer to activities that take place on premises that both manufacture and place such products on the market (sell) and also those premises that do not manufacture but buy and sell products. A full list of authorised feed additives and their authorising Regulations can be found on the EU Register of feed additives: http://ec.europa.eu/food/food/animalnutrition/feedadditives/comm_register_feed_additives_1831-03.pdf A. Approval activities Code Activity description Notes Examples of feed business establishments 1 lik l t t th ti it A1 market of nutritional additives This includes: vitamins, pro-vitamins and chemically defined substances having a similar effect; compounds of trace elements; amino acids, their salts and analogues and urea and its derivatives, in accordance with Annex I of Regulation 1831/2003. Feed additive manufacturers producing nutritional additives. Businesses selling (but not manufacturing) such additives. 11
A2 A3 A4 A5 market of zootechnical additives: Digestibility enhancers, gut flora stabilisers and substances which favourably affect the environment. market of antioxidant additives with a maximum content in feeds specified in EU Regulation1831/2003. market of colorant additives: carotenoids and xanthophylls. market of proteins obtained from micro-organisms belonging to groups of bacteria, yeast, algae and lower fungi. This includes enzymes and microorganisms. At the time of writing, this may include propyl gallate, octyl gallate, dodecyl gallate, butylated hydroxyanisole (BHA), butylated hydroxytoluene (BHT), ethoxyquin, as authorized under Regulation 1831/2003 2. Feed additive manufacturers producing zootechnical additives. Businesses selling (but not manufacturing) such additives. Feed additive manufacturers producing antioxidant additives with maximum permitted levels. Businesses selling (but not manufacturing) such additives. These products are subject to maximum Feed additive manufacturers permitted levels set in accordance with producing carotenoids or Regulation 1831/2003. xanthophylls (such as anthaxanthin). Businesses selling (but not manufacturing) such additives. These products were previously covered by Council Directive 82/471/EEC on Certain Products (Bioproteins) which has been revoked. They are now considered to be feed materials. 12
A6 A7 market of co-products of the manufacture of amino acids by fermentation. market of premixtures containing vitamins A and D. These products were previously covered by Council Directive 82/471/EEC on Certain Products (Bioproteins) which has been revoked. They are now considered to be feed These products are subject to maximum Manufacturers producing permitted levels set in accordance with premixtures containing vitamins A Regulation 1831/2003. or D. Businesses selling (but not manufacturing) premixtures containing vitamins A or D. A8 market of premixtures containing copper and selenium. These products are subject to maximum Feed additive manufacturers permitted levels set in accordance with producing copper or selenium Regulation 1831/2003. additives. Businesses Selling (but not manufacturing) premixtures containing copper or selenium additives. 2 Many feed additives are subject to re-assessment and authorisation after November 2010 under Article 10 of Regulation 1831/2003. Their conditions of use or authorisation status may be subject to change. 13
R. Registration activities Code Activity description Notes Examples of feed business establishments 3 R1 lik l h i i This includes preservatives, market of feed additives (other emulsifiers, stabilisers, thickeners, than those subject to approval). gelling agents, binders, anticaking agents, acidity regulators, antioxidants (not subject to a maximum permitted level), silage agents, denaturants, substances to control radionucleide contamination, colourants (except carotenoids and xanthophylls). Feed additive manufacturers producing technological or sensory additives. Businesses selling (but not manufacturing) technological or sensory feed additives. R2 market of premixtures (other than those subject to approval). This includes premixtures containing any feed additive excluding vitamins A a n d D and copper and selenium. Feed businesses producing or selling premixtures, other than those containing vitamins A and D, copper and selenium. Businesses selling (but not manufacturing) such premixtures. 14
R3 market of bioproteins ( certain products ) not subject to approval. This includes urea and its salts, ammonium salts, and certain killed yeasts cultivated on substrates of animal/ vegetable origin. R4 Manufacture of compound feedingstuffs (other than those subject to approval). This includes the manufacture of complete and complementary feeds, with or without additives. Feed manufacturing businesses which manufacture complete and complementary feeds with or without additives. R5 Placing on the market of compound feeds. Premises engaged in the buying and selling of compound feeds but not manufacturing such feeds. R6 Manufacture of pet foods. Includes the manufacture of complete and complementary feeds with or without additives. Pet food manufacturing businesses which manufacture complete and complementary feeds with or without additives. R7 market of feed materials. Feed materials are products which are intended as ingredients of compound feeds or which can be fed singly to animals. Businesses which manufacture (e.g. cereal or cereal based product and oils and fats for animal feed use). Branches of supermarkets involved in transferring human food to the feed chain. 15
R8 Transport of feed and feed products. Transport of feed and feed products by manufacturers own vehicles are covered by the approval/registration of the manufacturer s premises. Premises of businesses that transport feed materials, compound feed, feed additives and premixtures. R9 Storage of feed and feed products. Only covers premises not covered by another approval/registration activity relating to the manufacture or placing on the market of the products in question. In other words, it excludes storage facilities at a manufacturer s or transporter s premises. Feed storage premises. R10 (Farms) Mixing feeds, on farms, with additives and premixtures. This activity was subject to Farmers that buy-in additives and registration under previous legislation premixtures products (i.e. not (EC Directive 95/69 as implemented contained in a compound feed) and by the Feeding Stuffs (Establishment mix them with feeds (forage, silage, and Intermediaries) Regulations haylage, cereals etc.) Additives and 1999). premixtures may include vitamins, trace elements (e.g. copper, zinc), preservatives and urea. It can include dairy, beef, sheep and poultry farms. 16
R11 (Farms) R12 R13 (Farms) R14 (Farms) Mixing feeds, on farms, with compound feedingstuffs which contain additives. Food Businesses selling coproducts of the food industry which are destined as feed materials. Livestock farms (including fish farms) which do not mix feeds or mix feeds without additives. Arable farms growing or selling crops for feed. This activity was subject to Farmers that mix their own feeds registration under previous legislation on farm using bought in compound (EC Directive 95/69 as implemented feeds that contain additives such by the Feeding stuffs (Establishment as vitamins, trace elements etc. and Intermediaries) Regulations 1999). This includes the selling of feed materials which have been produced from the food and drink manufacturing process (e.g. wheat bran and brewers grains). Brewers, distillers, biofuel manufacturers, dairies and food manufacturers. Livestock farmers. It may include f a r m s making silage or haylage ( without u s i n g additives). Many fish farms may be included under this activity. Arable farmers (such as those growing cereals, wheat, barley or food crops, e.g. potatoes, for use as feed). 17