CHINA PET FOOD LABEL CLAIMS
China's pet food labeling provisions allow ingredient, product characteristic and function claims subject to specific conditions and supporting evidence. This guide explains how the provisions address ingredient percentages and claims such as "gluten-free", "natural", "fresh", "low-fat" and "low-energy".
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General Principles for Pet Food Claims
Article 20 of the Pet Food Labeling Provisions addresses ingredient, characteristic and function claims. Claims that a pet food prevents or treats animal diseases are prohibited.
All claims must be supported by evidence, which may include publicly available publications, textbooks, formula composition, test data or study reports. Ingredient claims must appear adjacent to the product name and follow the relevant presentation requirements.
The English expressions below are explanatory translations. Check the applicable Chinese wording and the current requirements when preparing the final label. For the basic label elements, see Part 1: Essential Label Information.
1. Feed Ingredient Claims
Claims About Feed Materials
If a pet food claims to contain a specific feed material, its name and added amount must be stated in the feed material composition. If the material is identified using a category name, its specific name and amount must be shown in brackets after that category name.
Certain dehydrated feed materials may be claimed based on their calculated content after water recovery, using the methods in Appendix 7 of the provisions. If water recovery is used, all three categories of feed material covered by that appendix must be calculated simultaneously.
The required minimum percentage depends on the wording of the ingredient claim. Percentages below refer to the product's total weight:
| Claim Wording | Minimum Content | Combined Claims |
|---|---|---|
| "XX formula" | At least 26% of the named feed material. | At least one named material must reach 26%; each remaining named material must reach at least 3%. |
| "Formula containing XX" | At least 14% of the named feed material. | At least one named material must reach 14%; each remaining named material must reach at least 3%. |
| "Contains XX" | At least 4% of the named feed material. | At least one named material must reach 4%; each remaining named material must reach at least 3%. |
Combined ingredient claims must be presented in descending order of the feed materials' weight percentages.
Flavor and Characteristic Ingredient Claims
A flavor may be claimed if a feed material, compounded pet feed flavoring or flavor enhancer gives the product that flavor. The provisions specify the use of wording equivalent to "XX flavor".
If a feed material gives the product a particular characteristic, it may be claimed using wording equivalent to "added with XX" even when its content is below 4%. Claims about relevant nutrients or additives must be accompanied by the applicable guaranteed value or added amount in the corresponding label section.
"Free-from" and Comparative Claims
The provisions allow claims that a product is free from a feed material or feed additive using wording equivalent to "XX-free" or "without XX". For gluten, a "gluten-free" claim may be used when the gluten content is not more than 20 mg/kg.
Comparative claims such as "high", "increased", "low" or "reduced" must identify a reference product from the same company. The increase or reduction must be at least 15%; for macronutrients, the difference must be verifiable through the formula.
2. Product Characteristic Claims
Descriptions such as "natural", "fresh", "low-fat", "new product" and "upgraded formula" are subject to conditions concerning ingredients, processing, nutritional composition and supporting evidence.
"Natural"
A product may be described as "natural" or "natural food" when its feed materials and additives meet the specified origin and processing conditions. Permitted processes listed in the provisions include physical processing, heat treatment, extraction, purification, hydrolysis, enzymatic hydrolysis, fermentation and smoking.
Where added vitamins, amino acids or mineral trace elements are chemically synthesized, a natural food claim may still be made if the claim also identifies the relevant added substances as required. If two or more types are added, the applicable additive category names may be used.
| Ingredient Situation | Illustrative Claim |
|---|---|
| All feed materials and additives meet the relevant natural origin and processing conditions. | Natural food |
| Feed materials meet the conditions, with chemically synthesized vitamins or amino acids added. | Natural food with added vitamins; natural food with added vitamins and amino acids |
| A specific feed material or additive meets the conditions. | Natural colorant; natural preservative |
"Fresh"
A feed material may be described as "fresh" if, apart from refrigeration, it has not undergone cooking, drying, freezing, hydrolysis or similar processing and does not contain sodium chloride, preservatives or other feed additives.
"Low-fat" and "Low-energy"
The labeling provisions set species-specific fat and metabolizable energy (ME) limits according to moisture content. Fat and energy values shown below are maximum values.
| Product | Moisture | Low-fat: Fat Content | Low-energy: ME |
|---|---|---|---|
| Dog food | Below 20% | ≤ 9% | ≤ 1,296 kJ ME/100 g |
| Dog food | 20% to 65% | ≤ 7% | ≤ 1,045 kJ ME/100 g |
| Dog food | Above 65% for low-fat; at least 65% for low-energy | ≤ 4% | ≤ 376 kJ ME/100 g |
| Cat food | Below 20% | ≤ 10% | ≤ 1,359 kJ ME/100 g |
| Cat food | 20% to 65% | ≤ 8% | ≤ 1,108 kJ ME/100 g |
| Cat food | Above 65% for low-fat; at least 65% for low-energy | ≤ 5% | ≤ 397 kJ ME/100 g |
The official wording for the low-energy categories uses both "20% to 65%" and "not less than 65%". For a product at exactly 65% moisture, confirm the applicable interpretation before making the claim.
For a low-energy claim, the energy value must also be displayed on the same panel as the claim, expressed as ME in kJ/100 g. A calculated value may be used in accordance with Appendix 8, with the required indication that it is calculated.
"New Product", "Upgraded Formula" and Standards Claims
Claims such as "new product", "upgraded formula" and "upgraded product" require sufficient evidence and may appear on the label for no more than 18 months.
A product claiming conformity with an international or foreign standard must satisfy all requirements of that standard. The company should be able to provide supporting materials, such as test reports or formula information, when requested by the authority. The original article also notes that claims concerning certification by an overseas government or organization should be supported by appropriate documentation.
3. Product Function Claims
A function claim may be made where a feed material, feed additive or nutrient in a feed material helps maintain or support an animal's growth, development, physiological functions or health, subject to the applicable conditions and evidence requirements.
Feed additives covered by the claim must be declared in the additive composition or guaranteed analytical values as required. Feed materials covered by the claim must be named in the ingredient composition with their added amounts.
For non-disease problems, such as hairball formation or tartar accumulation, a prevention claim may identify the specific problem where the product has the relevant preventive effect. Claims relating to prevention or treatment of pet diseases remain prohibited.
How REACH24H Can Help
REACH24H supports companies preparing pet food for the Chinese market. Our services include:
Pet food product classification and import compliance consultation;
Chinese label translation and compliance review;
Support with applicable imported pet food registration procedures.
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Discuss your product claims, supporting information and Chinese label with our team.
