From pet food to veterinary medicines: we want the best for our companion animals
Posted: April 28, 2026 Filed under: Food Comments Off on From pet food to veterinary medicines: we want the best for our companion animals
Something has changed in the way we think about our pets. The dog that once slept in the garden now sleeps at the foot of the bed. We want the very best for our companion animals: not just in terms of food, but also when it comes to the medicines they may need. This shift in attitude is evident in the market. The range of premium pet food is growing year on year. Manufacturers promise ‘natural ingredients’, ‘grain-free’ recipes and ‘human-grade’ meat. The packaging looks like products from a delicatessen. But what does the law actually say about pet food? How is it classified, what must be on the label, and where are the legal boundaries?
Pet food is legally qualified as feed
Under EU law, pet food is not treated as food, but as feed. Commercially, pet food sits between the two: it is sold in supermarkets, marketed with language borrowed from the food world, but legally it follows the feed rules. That means the labelling requirements, the rules on claims and the enforcement framework all come from feed legislation, not food law.
The main piece of EU legislation for pet food is the Feed Regulation). Specific ingredients are subject to their own rules: feed additives need pre-market approval under Feed Additives Regulation and animal by-products, such as slaughterhouse offal, blood and blood products, bone meal and fish meal, are classified by risk level under the Animal by-products Regulation.
The spectrum of products for companion animals
When it comes to products intended for companion animals, it helps to think of a spectrum rather than a single category. At one end sits regular pet food and at the other end sit veterinary medicinal products. In between are products that share characteristics of both. Each point on the spectrum has its own legal regime, and moving from one to another has significant legal consequences.
The following table sets out the main categories of products for companion animals, from standard pet food to veterinary medicinal products, along with the applicable legal framework for each.
| Product category | Applicable legislation | Key characteristics |
| Standard pet food | Feed Regulation | Complete meals, complementary feeds and treats; least regulated category |
| PARNUTS (feed for particular nutritional purposes) | Commission Regulation (EU) No 2020/354 | Specially formulated for a specific nutritional need (e.g. kidney support, weight management); must carry a recommendation to consult a vet; permitted purposes listed in a positive list |
| Medicated feed | Regulation (EU) No 2019/4 | Contains one or more veterinary medicines mixed into feed; veterinary prescription required |
| Veterinary medicinal products | Regulation (EU) No 2019/6 | No longer pet food or feed; pre-market approval required; strictest regulatory regime |
Mandatory information on the label of pet food
There are mandatory labelling requirements for pet food. For example, the pet food labels must state whether the product is a complete or complementary feed and it must list the ingredients in descending order by weight. It is good to keep in mind that the term ‘labelling’ in the Feed Regulation covers not only the physical packaging but also the website. What you put on your product page is legally considered part of the label and must meet the same requirements. The same applies to social media if it is directly linked to a product.
Voluntary information on the label of pet food: claims
As discussed above, manufacturers are increasingly pushing the boundaries of what they claim about their products for pets. Claims must be supported by evidence and they must not mislead buyers. The most critical choice often is a single word, namely the word that determines which side of the line between feed and medicine you are on. Words such as ‘treats’ and ‘cures’ in combination with a disease constitute medicinal claims. A pet food product making such claims risks being reclassified as a veterinary medicinal product without marketing authorisation.
A case before the Dutch Advertising Code Committee illustrates that claims on pet food are subject to scrutiny. A radio commercial stated that Royal Canin was ‘so healthy for cat and dog’ that a pet insurer offered premium discounts to customers who fed it to their pets. The Committee found this claim too absolute: Royal Canin had not sufficiently substantiated that its pet food was, in general terms, ‘healthy’. The claim was held to be misleading. On appeal, however, the Board of Appeal overturned the decision after Royal Canin submitted scientific research and expert endorsements supporting the quality of its products. The case underlines a key point: especially a broad health claim on pet food must be substantiated. If challenged, the burden falls on the manufacturer to demonstrate that the claim holds up.
The boundary with veterinary medicines
On 1 March 2026, a revised version of the CAVP Code came into force. CAVP stands for Commissie Aanprijzing van Veterinaire Producten (Committee on Promotion of Veterinary Medicines), the Dutch self-regulatory body that oversees the promotion of veterinary products. The Code was revised in connection with new European legislation and is primarily aimed at manufacturers of veterinary medicines, not at pet food producers. But it is relevant to anyone operating near the boundary between feed and medicine, which is a boundary that pet food producers can approach more easily than they might expect.
The Code’s scope extends beyond vet
erinary medicines: it also covers biocidal products (such as disinfectants and pest control products) and other animal care products. This broader scope reflects the fact that many products used in and around animal care raise similar concerns about responsible promotion. For example, fear-based marketing (e.g. ‘protect your dog against serious diseases’) that encourages excessive or unnecessary use of a product is not permitted under the Code. And for biocidal products specifically, certain words such as ‘harmless’ and ‘animal-friendly’ are simply prohibited, even if they are factually correct. This signals clearly where regulatory thinking is heading on ethical and environmental language more broadly.
The CAVP Code also contains rules on hospitality, gifts and other advantages offered to veterinary professionals (Chapter 7). These rules will be familiar to anyone who knows the CGR Code of Conduct, the self-regulatory framework for the promotion of human medicines in the Netherlands: the underlying principles are strikingly similar. Just as the CGR system does on the human side, the CAVP operates a complaints procedure in cooperation with the Inspection Board (Keuringsraad) and has working arrangements with the NVWA for enforcement purposes.
A recent decision illustrates how this works in practice. On 3 November 2025, the CAVP ruled on a complaint by a vaccine manufacturer alleging that a competitor’s promotional communications about its bluetongue vaccine constituted misleading comparative advertising. The competitor had advised veterinarians and livestock farmers to switch to its vaccine for revaccination, implying, without sufficient scientific substantiation, that it offered better protection than the complainant’s competing product. The CAVP found the complaint partially well-founded: the letter to farmers and a newsletter unconditionally advised readers to switch to its own vaccine, without adding the important caveat “if you choose [our vaccine]” that did appear in the letter to veterinarians, and that omission made those communications misleading under the Code. The letter to veterinarians and a press release were found not to breach the Code. The lesson is straightforward: an unconditional recommendation to switch to one’s own product, without adequate scientific substantiation, is misleading comparative advertising under the Code.
That case concerned vaccines, but the CAVP Code is not limited to veterinary medicines. The definition of ‘veterinary products’ under the Code is broad: it covers not only veterinary medicines and biocidal products, but also animal feed with a particular nutritional purpose and complementary feed. This means that pet food producers whose products fall within these categories are directly subject to the Code’s requirements on promotion.
Conclusion
The pet food market may look like a premium food sector, but legally it is not. Anyone who produces or sells pet food operates within an animal feed framework with its own rules for labelling, claims and categorisation. The greatest risks lie not in major violations, but in subtle word choices: the difference between ‘supports the joints’ and ‘treats joint pain’ can be the difference between standard pet food and an unauthorised veterinary medicinal product.
Our pets don’t read the label. The NVWA does.
When drafting this blogpost, inspiration was found in a presentation by Francesco Planchensteiner at the EFFL conference in Berlin on 27 and 28 November 2025 on the evolution of pet food and its legal implications.
Images by freepik.