What The Pet Food Label Doesn't Tell You - Part 1

Healthy dog

In this article we look at the regulation surrounding labelling a pet food “natural” “hypoallergenic” or “Sensitive” and what is required of a pet food manufacturer before it can make these claims. We also offer our thoughts on what to consider before you buy a pet food labelled “natural”, “hypoallergenic” or “Sensitive”.

There has been much media attention in the last decade on the health implications of many processed foods available at the supermarket for humans. It should, therefore, come as little surprise that highly processed pet foods can also have serious health implications for our pets. 

With this in mind more and more pet owners look to provide their pets with pet food brands that are healthy, free from artificial preservatives and colourings and contain identifiable sources of protein. Others look for brands that are appropriate for pets with existing allergies and intolerances. In response to this the pet food industry has provided pet foods labelled with words such as “natural”,  “hypoallergenic”, and “sensitive”, as well as many other claims. The problem is some of these claims mean very little. Provided the pet food manufacturer is not making a claim that a pet food actually treats a condition (known as “medical claims” 1), then it can claim that a pet food has a whole range of health benefits (known as a “functional claim” 2), provided it can point to evidence which supports its claim, even if that evidence arises out of research commissioned by the manufacturer3.

The European Pet Food Industry Federation “FEDIAF” represents the national pet food industry associations in the EU, including the Pet Food Manufacturers Association in the UK (“PFMA”). FEDIAF has produced a Code of Good Labelling Practice For Pet Food (the “Code”).4 The Code considers the claims that pet food manufacturers can make and what is required before they can make these claims. The Code is published on the PFMA’s website and is largely based on the less than airtight legislative requirements imposed on the Pet Food Industry.

The Pet Food Label

Natural Pet Food-What Does it Mean?

One of the terms considered by the Code is the use of the term “natural” on a pet food label. To the uninitiated, a pet food claiming to contain “natural ingredients” may imply that the pet food is healthy for your pet and a sign of a quality pet food. When you look at the guidance contained in the Code on the use of the word “natural” you realise that calling a pet food natural is no guarantee of quality at all.  The Code states the following:

“The term “natural” should be used to describe pet food components (derived from plant, animal, micro-organism or minerals) to which nothing has been added and which have been subjected only to such physical processing as to make them suitable for pet food production and maintaining the natural composition.” 5

The Code goes onto state: 

“ Bleaching, oxidation by chemical, chemical treatment and similar processes exclude use of the term “natural”

Feed materials and additives containing or derived from GMOs also exclude the use of the term “natural”.6

So breaking this down the guidance tells us the following:

  • The use of the term “natural” should only be used to describe pet food components derived from “plant, animal, micro-organism or mineral”. So all cereals, meats and cellular organisms including bacteria and fungi would come within this part of the definition. So a food high in cereal content (a known cause of allergies in dogs and diabetes in cats) may still permit a manufacture to call the pet food “natural”. What is clear from this is that just because something claims to be “natural” does not mean it is a species appropriate food, nor, does it suggest that it will benefit your pet, it just means it is derived from a “plant, animal, micro-organism or mineral”.
  • Provided the process applied to the “natural” ingredient is necessary to make the food “suitable for pet food production” then, save for the limited number of exceptions set out above, concerning the chemical treatments of pet food and additives containing or derived from GMOs, the word “natural” can still be used on the pet food label. FEDIAF do not provide a definitive list of acceptable and unacceptable processes, it simply gives examples.

FEDIAF also confirms that the terms “made with natural…” 7 may be used provided the natural components are clearly identified. So it could be claimed that a pet food is made “with natural ingredients” but could still contain other highly processed ingredients that may not be beneficial to your pet’s health.

So does a pet food label containing the word “natural” help you identify a high quality and healthy pet food? No not really. Some pet foods that use the word natural are excellent pet foods, and this article does not seek to in any way suggest otherwise. Indeed it is preferable that your pet food contains natural ingredients. It is, however, necessary to read the ingredients breakdown on the back of the pet food label before you decide whether it is the right food for your pet.

“Hypoallergenic” and “Sensitive” Pet Foods-What Does it Mean?

Another claim frequently made on pet food labels is that the food is “hypoallergenic”, or, “Sensitive”. The problem is that the words “hypoallergenic”, and “sensitive” can be placed on a pet food label and still contain many components capable of causing, or, inflaming an allergy and other health issues in your pet.

In January 2010, the PFMA circulated a frequently asked questions document for its members. The document concerned EU Regulation 767/2009, which among other matters sets out certain legal requirements concerning the labelling of pet foods. The PFMA confirms in this document that: 

“There is no definition of the term “hypoallergenic” as such. Companies need to carry out an internal risk assessment if the use of the term is justified. (Need to substantiate if challenged by Authorities).”

So in essence, it is a matter for the manufacturer and its own internal risk assessment whether it decides to claim a pet food is “hypoallergenic”. The PFMA does remind its members that the FEDIAF Code “includes a checklist and tables that can help members to collect information to substantiate their claims” and that manufactures can be required to substantiate their claims. Provided, however, the manufacturer can point to evidence to support its claims (which may be in the form of its own funded research), and provided it takes other research which may not support its views into account, it can conclude that its own research is right and its claim that a food is “hypoallergenic” is valid.

Many pet owners purchase these products unaware that words such as “hypoallergenic” and “sensitive” are not legally defined and that the use of these words are not subject to stringent regulation. The simple fact is there is no definitive list of what is and what isn’t “hypoallergenic” or “sensitive”, it is simply a matter for the manufacturer of the food. 

EU Directive 2008/38 Annex 1 Part B provides a list of requirements which are mandatory for a manufacturer making a claim that the food is for a “particular nutritional purpose” 8 such as a claim that “this pet food supports renal function in the case of chronic renal insufficiency”. Most pet foods, however, that claim to be “hypoallergenic”, or, “sensitive” ensure that the language stops short of claiming that the food is for a particular nutritional purpose. Instead they use words such as “Sensitive Digestion”. This is entirely legal and many manufacturers make these claims, the pet foods may, however, also contain ingredients which may irritate a pet with a sensitive digestion, depending on what exactly is the cause of the pets digestive issues. 

If your not sure whether a pet food manufacturer is making a functional claim, or, a claim that a food is for a particular nutritional purpose, look at the pet food label. By law a pet food label claiming that the pet food is for a particular nutritional purpose must contain on the label the qualifying expression “dietetic” 9. Further, it must also state that the opinion of a nutrition expert or veterinarian should be sought before using the feed or before extending its period of use.10

Accordingly, there is no guarantee that because something states it is “hypoallergenic”, or, “Sensitive” that it is a good quality pet food, or, that it will be beneficial for your pet. Whether a particular food will be beneficial for a pet with allergies or intolerances will ultimately depend upon the ingredients contained in the pet food and type of allergy or intolerance an individual pet is suffering from (assuming it can be identified). A classic example is a hypoallergenic pet food that contains grains or cereals. Whilst some grains such as brown rice may be very beneficial for some pets with allergies or intolerances, if your pet scratches and has itchy skin because it has an allergy to storage mites, then feeding your pet any food which contains grain or cereal, which attracts storage mites, is unlikely to assist your pets allergy. A pet with a storage mite allergy is likely to benefit from a grain and cereal free diet, which should help alleviate the symptoms of its allergy (see our article on storage mites). 

Again the point should be stressed that some pet foods which contain the term “hypoallergenic” or “sensitive” are excellent pet foods, and they may be beneficial for your pet, but don’t take the manufacturers word for it, read the ingredients list on the pet food and make your own mind up as to whether it is a food which is likely to benefit your pet.

Our Thoughts

If you do have a pet with allergies or intolerances, then here are our thoughts on what to consider when looking for a suitable food for your pet:

  1. If your pet suffers from allergies or intolerances, which are being treated by your vet, then always speak with your vet before changing your pet’s diet. 
  2. Try a grain and cereal free pet food, this will assist with storage mite allergies, or, allergies to cereals. If you can feed a wet food, which is grain and cereal free, even better.
  3. Try feeding single source identifiable proteins; avoid having more than one meat type in your pet’s food, at least whilst you’re trying to works out what meats your pet can tolerate. Pets with digestive issues can find a pet food with a mix of proteins more difficult to digest. This will also help you identify if your pet is allergic, or, intolerant to certain types of meat.
  4. You may want to try feeding your pet a form of protein it has not eaten before (provided it is species appropriate). Pets with food allergies and intolerances usually build up intolerances to the common forms of protein we feed to pets such as chicken and beef. So try something different, such as turkey, rabbit, or venison. Make sure you read the ingredient list for any pet food you purchase, as many pet foods contain more than one type of meat but they don’t necessarily tell you that on the front of the label. If you are buying a pet food off the Internet then most online store will display the ingredients list, this can usually be accessed by clicking on the “more” button, or, the photograph of the product you are considering purchasing. 
  5. Ensure that your pet food does not contain meat and animal derivatives, meat meal, or, animal by-product. You simply cant be sure what you are feeding your pet if these ingredients are present in your pet’s food. It could be a meat source your pet is intolerant or allergic to, or, it could be the parts of an animal that are not particularly digestible and will inflame an existing intolerance, or, allergy.
  6. Ensure you are as strict with your pet’s treats as you are with your pet’s food. Even small quantities of a food type which your pet is allergic, or, intolerant to can cause a reaction. If you have a pet with allergies you may be better feeding a dried meat or fish treat that has nothing else added to it.
  7. Always introduce a new food slowly over 3-4 days. Changing your pet food overnight is likely to cause an upset tummy. Give your pet time to adjust to a new food. 

Fact File


  • 1. F.E.D.I.A.F Code of Good Labelling Practice for Pet Food 20 October 2011 paragraph p34; Regulation (EU) 767/2009 Art 13.3
  • 2. F.E.D.I.A.F Code of Good Labelling Practice for Pet Food 20 October 2011 paragraph 5.2.3 p34
  • 3. Regulation (EU) 767/2009 Art 13.1 & 13.2
  • 4. F.E.D.I.A.F Code of Good Labelling Practice for Pet Food 20 October 2011
  • 5. F.E.D.I.A.F Code of Good Labelling Practice for Pet Food 20 October 2011 paragraph
  • 6. F.E.D.I.A.F Code of Good Labelling Practice for Pet Food 20 October 2011 paragraph
  • 7. F.E.D.I.A.F Code of Good Labelling Practice for Pet Food 20 October 2011 paragraph
  • 8. EU Regulation 767/2009 Art 9, 10 & 18
  • 9. EU Regulation 767/2009 Art 18 (a)
  • 10. EU Regulation 767/2009 Art 18 (c)

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