The level of substantiation required for functional claims depends on whether the claim can be considered “generic” or “innovative”. For “content claims”, substantiation will depend on whether the claim is made for major or minor components of the recipe. (FEDIAF, 2018). It is necessary to substantiate that the product contributes to a beneficial effect to make a functional claim. The substance that contributes to the beneficial effect must also be present in the pet food in sufficient quantities to produce the claimed effect.

• The type of feed, e.g. Complete or Complementary
• The Species or Categories of animals for which the feed is intended
• Name or Business Name and Address of Feed Business Operator responsible for the labelling
• A free telephone number or other appropriate means of communication, e.g. email address/ website
• The Batch or Lot reference number
• The Approval number of the producer (Manufacturer’s Registration number)
• The indication of the minimum storage life, e.g. ‘Best Before …’ followed by the date indicating a particular month
• Storage Conditions, e.g. Store in a cool, dry place
• ‘Always ensure fresh water is available’ statement for dry products
• The Net Quantity expressed in units of mass
• A list of Feed Materials the product is composed of, listed in descending order by weight-bearing the heading ‘Composition’.
• Instructions for proper use indicating the purpose for which the feed is intended, including appropriate feeding quantity per day
• Additives (as set out in Regulation 767/2009, Annex VI Chapter 1)
• Analytical Constituents ( as set out in Regulation 767/2009, Annex VI, Chapter 2)
• If Claims are present, substantiation should be available

Regulation (EC) No 767/2009 states ‘Scientific substantiation should be the main factor to be taken into account for the purpose of making claims.’ FBOs should substantiate claims, considering all evidence and scientific data available. Information provided (inclusive of claims) should be clear, coherent, consistent and comprehensible and must not mislead or deceive purchasers. Purchasers do hold the right to bring any claim related doubts and queries to the attention of the competent authorities. If it is concluded that a claim is not sufficiently substantiated, the product’s labelling is deemed misleading.

Substantiating Claims

All claims must be substantiated and verifiable to protect the purchaser against false claims. The degree of substantiation will depend on the type of claim made. Well substantiated claims will allow an FBO to offer better benefits to pets and owners, encouraging continued investment. For ‘innovative’ or not well established/widely recognised claims, substantiation should be available in a dossier, consisting of scientific evidence that may be existing scientific publications, published or unpublished new research. Substantiation dossiers should be well-structured, self-explanatory and sufficiently detailed. Key scientific data must be included, and the claim’s validity should be easily verified. Manufacturers should review the substantiation of claims to establish if new science has evolved or if there have been any changes that may impact validity.

Substantiation helps justify the use of claims and manage what claims are being used. If an FBO cannot substantiate a claim, it should not be used. This should help reduce the risk of misleading claims and misleading and misinforming purchasers. Substantiation also allows some fair and common ground across the pet food industry. Scientific data is widely available, providing FBOs with the opportunity to develop substantiation to make similar claims to their competitors. Using claims that are well substantiated and proven can benefit the FBO. If purchasers identify a link between claims on a pack and a visible, beneficial effect on their pet, they know the product is effective. This may encourage a positive relationship between purchasers and FBOs, as the FBO becomes reputable and trustworthy. This could further generate brand loyalty. Schleicher and colleagues reported that pet owners are more ‘brand loyal’ to pet food than brands used for their food (Schleicher, 2019).