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, legislation requires the Animal and Plant Health Agency (APHA), as the competent authority, to approve 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 referred to as a 'statutory statement'.
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, and raw feed (frozen or fresh).
Feed legislation applies principally to feed for 'food-producing animals', which means farmed livestock, including rabbits and horses. However, it also covers feed for what are called 'non-food producing animals'. This typically means creatures living freely in the wild, fur-bearing animals, pets, and animals kept in zoos, circuses and laboratories. A pet is defined as any 'non-food producing animal' belonging to a species fed, bred or kept but not normally used for human consumption.
Manufacturing pet food
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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 or small unit.
The overarching principle of the legislation 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.
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 and Critical Control Point (HACCP - feed-safety management system)
Storage and transport
Record-keeping, including traceability
Complaints and product recall
All pet food manufacturers must also comply with 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 covers 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.

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