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EU Compliance & Market Access
Sector Applications
Compliance obligations applied to specific sourcing contexts — mapping general regulatory requirements to sector-specific risk.
Pet Products & Responsible Sourcing
Applies to companies sourcing pet food, treats, and accessories from non-EU origins for the EU market.
Regulation (EC) 767/2009 · Regulation (EC) 1831/2003
Pet Food Safety & Composition Rules
EU pet food is regulated as animal feed. Products placed on the EU market must comply with feed safety, labelling, and additive authorisation rules — regardless of where they are manufactured.
- Feed law framework
- Regulation (EC) 178/2002 (general food law) and Regulation (EC) 767/2009 (placing on market and use of feed) provide the primary framework. Both apply to pet food.
- Labelling requirements
- Pet food must declare: species it is intended for, net quantity, best-before date, responsible operator name and address, country of origin where required to avoid misleading the consumer.
- Feed additives
- Regulation (EC) 1831/2003 governs feed additives — preservatives, antioxidants, vitamins. Only authorised additives may be used; each has a maximum permitted level. Authorisation is EU-wide.
- Contaminant limits
- Regulation (EC) 574/2011 (and successor acts) set maximum levels for undesirable substances in feed — including heavy metals, mycotoxins, and dioxins — applicable to pet food ingredients.
- Official controls
- Member states are responsible for enforcement. Products from third countries are subject to import checks at Border Inspection Posts or designated entry points under Regulation (EU) 2017/625.
- Operator responsibility
- The EU-established operator placing the product on the market is responsible for compliance. A non-EU manufacturer exporting to the EU must appoint an EU responsible person or import via an EU importer who assumes that role.
CSDDD · Regulation (EC) 1005/2008 · SMETA · BSCI
Responsible Sourcing & Due Diligence
Pet food supply chains — particularly those involving seafood ingredients — carry distinct due diligence obligations under EU law. Three frameworks apply simultaneously.
- CSDDD obligations
- Directive (EU) 2024/1760 requires large companies to identify, prevent, and remediate adverse human rights and environmental impacts in their value chains. Ingredient-level suppliers — including fish meal and fish oil processors — fall within scope. Phase-in begins 2027.
- IUU Fishing Regulation
- Regulation (EC) 1005/2008 prohibits import of fish products caught through illegal, unreported, or unregulated fishing. All seafood imports require a catch certificate validated by the flag state. Applies to fish meal and fish oil used as pet food ingredients.
- Audit framework expectations
- SMETA (2-pillar or 4-pillar) and amfori BSCI are the primary audit standards used for food manufacturing suppliers. SMETA 4-pillar covers Labour, Health & Safety, Environment, and Business Ethics — the relevant standard for CSDDD-aligned supplier assessments.
- Documentation requirements
- Minimum evidence set: signed supplier declarations, audit reports (SMETA/BSCI) not older than 24 months, corrective action plans with closure evidence, catch certificates for seafood ingredients, and recruitment fee reimbursement policies where applicable.
- Practical mitigations
- MSC-certified seafood ingredients, supplier engagement programmes, documented corrective action closure, and a maintained compliance evidence register reduce both regulatory and reputational exposure.
EUDR · PPWR · Green Claims Directive
Environmental Obligations for Pet Products
Pet food and accessories face three overlapping environmental compliance layers — deforestation, packaging, and claims substantiation.
- EUDR — palm oil & rubber
- Thailand is a significant palm oil and rubber producer. Palm oil is used in some wet pet foods and treats. Rubber appears in toys and accessories. Both are EUDR-regulated commodities requiring geolocation data and due diligence statements from 30 December 2025.
- PPWR — pouches & trays
- Wet cat and dog food pouches, trays, and treat bags are all in scope for the Packaging and Packaging Waste Regulation. Multi-layer flexible pouches present recyclability challenges under harmonised EU criteria from 2030.
- Recycled content — plastics
- Mandatory recycled content targets apply by packaging type from 2030. Flexible consumer packaging: 10% by 2030, 25% by 2040. Suppliers packaging locally should plan accordingly.
- Green claims — pet sector
- Claims such as "sustainably sourced fish", "ocean-friendly", "eco packaging", or "responsible sourcing" on pet product packaging and marketing must be substantiated under Directive 2024/825 (in force March 2024, transposition by March 2026).
- Substantiation standard
- Claims must be based on recognised scientific evidence, cover the relevant lifecycle stages, and be verified by an accredited third party. Generic environmental labels not approved by EU or national authorities are banned.
GHG Protocol Scope 3 — Category 1
Scope 3 Emissions — Pet Food Supply Chain
Purchased goods and services (Category 1) is typically the dominant Scope 3 category for companies sourcing manufactured pet food. The data collection challenge is significant.
- What counts in Category 1
- All cradle-to-gate emissions associated with purchased raw materials, ingredients, packaging, and finished goods — including agriculture, processing, and upstream transport to the supplier.
- Fish meal & fish oil
- High-carbon-intensity ingredients. Emissions vary substantially by species and fishing method. Supplier-specific data is preferable to emission factors; IFFO and GHG Protocol guidance is available.
- Sea freight — Thailand to EU
- Approximately 0.8–1.2 kg CO₂e per kg cargo (GLEC Framework deep-sea container estimate, Gulf of Thailand → Northwest Europe via Suez, 25–30 day transit).
- ESRS E1 obligation
- Under CSRD, Category 1 Scope 3 is material for most physical goods companies. Disclosure is required where material — large buyers of Thailand-origin pet food will typically meet this threshold.
- Data gap — pet food sector
- Primary activity data from seafood processors is rarely available. Spend-based methods dominate in current practice; engagement programmes to collect supplier-specific emission factors are the improvement path.
- Packaging emissions
- Aluminium-laminate pouches carry significant embodied carbon. Switching to mono-material alternatives or increasing recycled content reduces both packaging Scope 3 and regulatory PPWR risk simultaneously.
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