Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the labelling of organic pet food
Date: 2022-11-28
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: consumer information, domestic animal, eco-label, labelling, organic certification, organic farming, organic product, pet food

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   EUROPEAN COMMISSION  Brussels, 28.11.2022  COM(2022) 659 final 2022/0390 (COD)  Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the labelling of organic pet food  
 
EXPLANATORY MEMORANDUM 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

On 1 January 2022, Regulation (EU) 2018/848 of the European Parliament and of the Council 
of  30  May  2018  on  organic  production  and  labelling  of  organic  products  and  repealing 
Council  Regulation  (EC)  No  834/20071  became  applicable.  This  brought  about  a  change  as 
concerns pet food. Before 1 January 2022, pet food, in particular for cats and dogs, could be 
labelled as organic where not all agricultural ingredients were organic because Member States 
could lay down national rules or, in the absence thereof, accept or recognise private standards. 
However,  since  1  January  2022,  pet  food  can  no  longer  be  labelled  as  organic  because 
Regulation (EU) 2018/848, while covering the labelling of feed for farm animals like hay and 
silage, does not establish specific rules for the labelling of pet food. 

Regulation  (EU)  2018/848  applies  both  to  feed  for  food-producing  animals  and  to  feed  for 
pets, i.e. pet food. Under that Regulation, while non-organic ingredients of agricultural origin 
are authorised in the production of organic feed, a term referring to organic production cannot 
be used in the sales description where not all agricultural ingredients are organic. Moreover, 
such feed cannot bear the organic production logo of the European Union. Consequently, final 
consumers  are  not  directly  informed  about  the  compliance  of  the  product  with  organic 
production rules. 

On  the  one  hand,  professional  operators  are  informed  about  the  composition  and  the 
proportion of organic, in-conversion and non-organic compounds in feed in accordance with 
point 2.1.2 of Annex III to Regulation (EU) 2018/848. On the other hand, when feed is sold 
directly at retail level to final consumers, there are currently no rules concerning the provision 
of information on the organic compounds in the feed where not all agricultural ingredients are 
organic. Moreover, the labels of food and pet food are intended for the same customers: pet 
food and food (including prepacked food) are both sold at retail level to final consumers.   

Against this background, the purpose of this proposal is to establish specific labelling rules for 
pet food. These rules will allow pet food, in particular for cats and dogs, to bear the organic 
production  logo  of  the  European  Union.  Moreover,  the  organic  production  logo  of  the 
European Union will be mandatory for prepacked pet food labelled as organic. 

The  proposal  will  support  the  small  but  growing  organic  pet  food  sector  by  allowing 
producers  to  use  the  organic  production  logo  of  the  European  Union  when  promoting  their 
products.  In addition,  the proposal will contribute to  the development  of organic agriculture 
via  the  possibility  of  creating  added  value  for  organic  by-products  that  may  be  used  in  the 
production  of  pet  food.  This  is  in  accordance  with  the  Green  Deal,  the  Farm  to  Fork  and 
Biodiversity strategies, the Action Plan for the Development of Organic Production, and the 
target of achieving 25% of EU agricultural land under organic farming by 2030. 

• 

Consistency with existing policy provisions in the policy area 

The proposal is consistent with Regulation  (EU) 2018/848. The proposed labelling rules for 
organic  pet  food  mirror  the  labelling  rules  applicable  to  food,  including  the  mandatory 
requirement  of  the  use  of  the  organic  production  logo  of  the  European  Union  on  the 

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OJ L 150, 14.6.2018, p. 1. 

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packaging of prepacked food. Indeed, the labels of those products are intended for the same 
customers: pet food and food (including prepacked food) are both sold at retail level to final 
consumers. 

• 

Consistency with other Union policies 

The proposal is consistent with Regulation (EC) No 767/2009 of the European Parliament and 
of the Council on feed, which contains specific provisions for the labelling of feed for non-
food-producing animals like pets. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

Article 43(2) of the Treaty on the Functioning of the European Union. 

• 

Subsidiarity (for non-exclusive competence)  

Pursuant  to  Regulation  (EU) No  2018/848,  the Union has established  a Union-wide organic 
scheme and harmonised organic production rules, including rules concerning the labelling of 
organic products. The adoption of specific uniform rules for the labelling of organic pet food 
cannot therefore be sufficiently achieved by the Member States. 

• 

Proportionality 

The  proposal  proposes  limited  and  targeted  additional  rules  to  the  current  legislative 
framework  for  the  labelling  of  organic  products.  Those  rules  do  not  go  beyond  what  is 
necessary to achieve the objective of establishing rules for the labelling of organic pet food. 

• 

Choice of the instrument 

The  proposed  rules  concerning  the  labelling  of  organic  pet  food  require  their  direct 
applicability  in  the  Member  States.  A  Regulation  of  the  European  Parliament  and  of  the 
Council  is  the  appropriate  instrument  for  the  adoption  of  specific  rules  for  the  labelling  of 
organic  pet  food,  taking  into  account  that  the  legislation  currently  in  force  consists  of 
Regulation (EU) 2018/848. 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

Stakeholder consultations 

Collection and use of expertise 

Impact assessment 

3. 

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NA 

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NA 

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NA 

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NA 

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Regulatory fitness and simplification 

Fundamental rights 

BUDGETARY IMPLICATIONS 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

Explanatory documents (for directives) 

• 

NA 

• 

NA 

4. 

NA 

5. 

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NA 

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NA 

• 

Detailed explanation of the specific provisions of the proposal 

The proposal proposes to establish specific rules for the labelling of organic pet food. In order 
for pet  food to be labelled as organic and bear the organic production logo of the European 
Union, at least 95% in terms of weight of the agricultural ingredients will have to be organic. 
When less than 95% of the agricultural ingredients  will be organic, the reference to organic 
may only be used in the list of ingredients in relation to organic ingredients with an indication 
of the total percentage of organic ingredients in proportion to the total quantity of agricultural 
ingredients. 

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2022/0390 (COD) 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on the labelling of organic pet food 

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 43(2) thereof, 

Having regard to the proposal from the European Commission, 

After transmission of the draft legislative act to the national parliaments, 
Having regard to the opinion of the European Economic and Social Committee2, 
Having regard to the opinion of the Committee of the Regions3, 

Acting in accordance with the ordinary legislative procedure, 

Whereas: 

(1) 

(2) 

Regulation (EU) 2018/848 of the European Parliament and of the Council4 lays down 
rules on the labelling of feed and applies both to feed for food-producing animals and 
to feed for pets, i.e. pet food. Under that Regulation, while non-organic ingredients of 
agricultural origin are authorised in the production of organic feed, a term referring to 
organic  production  cannot  be  used  in  the  sales  description  where  not  all  agricultural 
ingredients are organic, even if to a low extent. Moreover, such feed cannot bear the 
organic  production  logo  of  the  European  Union.  Consequently,  final  consumers  are 
not  directly  informed  about  the  compliance  of  the  product  with  organic  production 
rules. 

Professional  operators  are  informed  about  the  composition  and  the  proportion  of 
organic,  in-conversion  and  non-organic  compounds  in  feed  in  accordance  with  point 
2.1.2  of  Annex  III  to  Regulation  (EU)  2018/848.  By  contrast,  when  feed  is  sold 
directly at  retail  level  to  final  consumers, there are currently no rules  concerning the 
provision  of  information  on  the  organic  compounds  in  the  feed  where  not  all  of 
agricultural ingredients are organic. This is particularly relevant for pet food. 

(3) 

Prior to the application of Regulation (EU) 2018/848, and in accordance with Article 
95(5)  of  Commission  Regulation  (EC)  No  889/20085,  certain  Member  States  had 
established  national  rules  or  recognised  private  standards  that  allowed  the  use  of  a 

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OJ C , , p. . 
OJ C , , p. . 
Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic 
production and labelling of organic products and repealing Council Regulation (EC) No 834/2007 (OJ 
L 150, 14.6.2018, p. 1).  
Commission  Regulation  (EC)  No  889/2008  of  5  September  2008  laying  down  detailed  rules  for  the 
implementation  of  Council  Regulation  (EC)  No  834/2007  on  organic  production  and  labelling  of 
organic products with regard to organic production, labelling and control (OJ L 250, 18.9.2008, p. 1). 

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(4) 

(5) 

(6) 

term referring to organic production in the sales description of pet food when at least 
95 % of the agricultural ingredients of the product by weight were organic, mirroring 
the rules for organic processed food.  

The labelling rules  for  organic pet  food at  Union level  should  therefore  mirror those 
for organic food, given that both categories of products are mainly sold at retail level 
to  final  consumers.  Information  on  compliance  with  organic  production  rules  should 
be provided through the terms referring to organic production in the sales description 
and through the use of the organic production logo of the European Union. In order to 
facilitate  awareness  about  compliance  with  organic  production  rules,  the  organic 
production logo of the European Union should be obligatory for all prepacked pet food 
complying  with  Regulation  (EU)  2018/848  and  this  Regulation  and  produced  within 
the Union, as is the case with prepacked food pursuant to Article 32(1), point (b), of 
Regulation (EU) 2018/848.  

In order to promote the further development of the pet food sector, it is appropriate to 
introduce specific provisions on the labelling of organic pet food, on the use of terms 
referring  to  organic  production  in  the  sales  description  and  in  the  list  of  ingredients, 
and on the use of the organic production logo of the European Union.  

Since the objectives of this Regulation can be better achieved at Union level through 
the  adoption  of  uniform  rules  for  the  labelling  of  organic  pet  food,  the  Union  may 
adopt measures, in accordance with the principle of subsidiarity as set out in Article 5 
of the Treaty on European Union. In accordance with the principle of proportionality 
as set out in that Article, this Regulation does not go beyond what is necessary in order 
to achieve those objectives, 

HAVE ADOPTED THIS REGULATION: 

Article 1 

Subject matter  

This  Regulation  lays  down  specific  labelling  requirements  for  pet  food  produced  in 
accordance  with  the  rules  concerning  organic  production  provided  in  Regulation  (EU) 
2018/848. 

Article 2 

Definitions 

For the purpose of this Regulation, the following definitions apply: 

1. 

2. 

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‘pet  food’  means  feed  intended  for  pets  as  defined  in  Article  3(2),  point  (f),  of 
Regulation (EC) No 767/2009 of the European Parliament and of the Council6; 

‘prepacked pet  food’  means any single item  of pet  food  for presentation  as  such to 
the  final  consumer,  including  the  packaging  into  which  it  was  put  before  being 

Regulation (EC) No  767/2009 of the European Parliament and of the  Council of  13 July 2009 on the 
placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 
1831/2003 and repealing Council Directive  79/373/EEC, Commission Directive 80/511/EEC, Council 
Directives 82/471/EEC, 83/228/EEC, 93/74/EEC, 93/113/EC and 96/25/EC and Commission Decision 
2004/217/EC (Feed marketing Regulation) (OJ L 229, 1.9.2009, p. 1). 

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offered  for  sale,  whether  such  packaging  encloses  the  food  completely  or  only 
partially, but in any event in such a way that the contents cannot be altered without 
opening  or  changing  the  packaging;  prepacked  pet  food  does  not  cover  pet  food 
packed on the sales premises at the final consumer’s request or prepacked for direct 
sale. 

Article 3 

Use of terms referring to organic production on the labelling of pet food 

1. 

For pet food, the terms referred to in Article 30(1) of Regulation (EU) 2018/848 may 
be used: 

(a) 

in the sales description and in the list of ingredients, provided that: 

(i) 

the pet food complies with the detailed production rules set out in Part V 
of  Annex  II  to  Regulation  (EU)  2018/848  and  with  the  processing 
techniques laid down in accordance with Article 17(3) of that Regulation; 
and 

(ii) 

at least 95 % of the agricultural ingredients of the product by weight are 
organic; 

(b)  only in the list of ingredients, provided that: 

(i) 

less than 95 % of the agricultural ingredients of the product by weight are 
organic, and provided that those ingredients comply with the production 
rules set out in Regulation (EU) 2018/848; 

(ii)  only feed additives and processing aids authorised pursuant to Article 24 
of Regulation (EU) 2018/848 are used in the processing of the pet food; 
and 

(iii) 

the pet food complies with the detailed production rules set out in points 
1.5, 2.1, 2.2 and 2.4 in Part V of Annex II to Regulation (EU) 2018/848 
and with the processing techniques laid down in accordance with Article 
17(3) of that Regulation. 

2. 

3. 

4. 

The list of ingredients referred to in paragraph 1 shall indicate which ingredients are 
organic.  The  references  to  organic  production  may  only  appear  in  relation  to  the 
organic ingredients. 

The  list  of  ingredients  referred  to  in  paragraph  1,  point  (b),  shall  include  an 
indication  of  the  total  percentage  of  organic  ingredients  in  proportion  to  the  total 
quantity of agricultural ingredients. 

The  terms  referred  to  in  Article  30(1)  of  Regulation  (EU)  2018/848  and  the 
indication of the percentage referred to in paragraph 3 of this Article shall appear in 
the same colour, identical size and style of lettering as the other indications in the list 
of ingredients referred to in paragraph 1 of this Article. 

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Article 4 

Use of the organic production logo of the European Union on the labelling of pet food 

1. 

2. 

The  organic  production  logo  of  the  European  Union  referred  to  in  Article  33  of 
Regulation  (EU)  2018/848  may  only  be  used  in  the  labelling,  presentation  and 
advertising of pet food complying with the conditions referred to in Article 3(1)(a).  

In  the  case  of  prepacked  pet  food  bearing  a  term  referred  to  in  Article  30(1)  of 
Regulation (EU) 2018/848, the organic production logo of the European Union shall 
appear on the packaging. 

Article 5 

Entry into force 

This Regulation shall enter into force on the third day following that of its publication in the 
Official Journal of the European Union. 

This Regulation shall be binding in its entirety and directly applicable in all Member States. 

Done at Brussels, 

For the European Parliament 
The President 

For the Council 
The President 

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