Regulation of Petfood Manufacturing in New Zealand

 There is a wide variety of regulatory requirements for petfood manufacturing in New Zealand and gaining a thorough understanding of them all can be difficult.

Like all manufacturing businesses, petfood manufacturers must comply with the Fair Trading Act 1986, the Health and Safety in Employment Act 1992, the Resource Management Act 1991, the Weights and Measures Act 1986, and others.

There are two pieces of legislation particularly important to New Zealand petfood manufacturers, both administered by the New Zealand Food Safety Authority. Both Acts and their associated Regulations, Specifications and Notices regulate petfood manufacture.

The Agricultural Compounds and Veterinary Medicines Act 1996 (ACVM Act)

Under the ACVM and associated Regulations, petfoods are Oral Nutritional Compounds (ONC). ONCs include all substances intended for oral administration to an animal to achieve a nutritional benefit. Petfoods are one subset of ONC.

Petfoods that are marketed purely to provide food for pets are exempt from registration but must comply with the ACVM Regulations which include;

The product must be fit for the purpose of feeding to the species, type and class of animal

The label must include:

a trade name

a list of ingredients
directions for use

contact details of the person responsible for the product (manufacturer or marketer)

batch and date codes to enable traceability

Under the ACVM Act petfoods will require registration as a veterinary medicine if they:

are marketed with a therapeutic or pharmacological claim

contain ingredients of known therapeutic action that exceed specified levels (eg glucosamine,      chondroitin sulphate, green-lipped mussel, carnitine, creatine)

contain additives that are not on the Generally Regarded as Safe (GRAS) list

contain substances that are therapeutic or pharmacological, including veterinary medicines

Further information about the ACVM Act, ACVM Regulations, ONCs, the GRAS list etc can be found at www.nzfsa.govt.nz/acvm .

The Animal Products Act 1999 (APA)

The APA applies to petfood manufacturers who:

are involved in slaughter and dressing of animals for petfood (primary processors)

produce products that require official assurances from NZFSA (eg export certificates)

process petfoods containing animal material that result from the death of an animal eg red meat, offals, poultry, fish), excluding rendered material.

For the first two activities a manufacturer must operate under a Risk Management Programme (RMP). An RMP is a comprehensive documented food safety system, which must be registered with NZFSA prior to commencing operations.

For the third activity an RMP is not required but manufacturers must:

be listed with the NZFSA (and supply details such as name, contact details and type of manufacture undertaken), and

have a documented system that demonstrated that animal material has been procured from regulated sources.

All three activities must be verified by the NZFSA Verification Agency. The frequency of these audits depends on the type of manufacturing being undertaken.

Further information about APA, AP Regulations, Specifications, RMPs, verification, etc can be found at www.nzfsa.govt.nz/animalproducts.

The NZ Petfood Manufacturers Association can help....

One of the key benefits of joining the Association is assistance with regulatory requirements.

The Association has produced Guidelines to assist, for example the petfood Labeling Guideline, which pulls together the requirements of the many Acts and regulations that impact on petfood labeling.

The Association is in the process of developing, jointly with NZFSA, a set of Codes of Practice for petfood processing, some of which have been published in draft form at http://www.nzfsa.govt.nz/animalproducts/publications/code-of-practice/petfood/index.htm .

For further assistance please email the Secretary of the Association.

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