EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 28.11.2022  
COM(2022) 659 final  
2022/0390 (COD)  
 
Proposal for a  
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  
on the labelling of organic pet food   EN 1  EN EXPLANATORY MEMORANDUM  
1. CONTEXT  OF THE  PROPOSAL  
• Reasons for and objectives of the proposal  
On 1 January 2022, Regulation (EU) 2018/848  of the European Parliament and of the Council 
of 30 May 2018 on organic production and labelling of organic products and repealing 
Council Regulation (EC) No 834/20071 became applicable . This brought about a  change as 
concerns pet food. Before 1 January 2022, pet food, in particular for cats and dogs , could be 
labelled as organic where not all agricultural ingredients were organic  because Member States 
could lay down national rules or, in the absence thereof, accept or recognise private standards . 
However, s ince 1  January 2022, pet food can no longer be  labelled  as organic  because 
Regulation (EU) 2018/848 , while covering the labelling of feed for farm animals like hay and 
silage, does not establish specific rules for the labelling of pet food . 
Regulation (EU) 2018/848 applies both to feed for food -producing animals and to feed  for 
pets, i.e. pet food . Under that Regulation, while non -organic ingredients of agricultural origin  
are authorised in the production of  organic  feed, a term referring to organic production cannot 
be used in the sales description  where not all agricultural ingredients are organic . Moreover, 
such feed cannot  bear the organic production logo of the European Union.  Consequently , final 
consumers are not directly informed about the compliance of the product with organic 
production rules.  
On the one hand, professional operators are informed about the composition and the 
proportion of organic, in -conversion and non -organic compounds in feed in accordance with 
point 2.1.2 of Annex III to Regulation (EU) 2018/848. On the other hand, when feed is sold 
directly at retail level to final consumers , there are currently no rules concerning the  provi sion 
of information on the organic compounds in the feed where not  all agricultural ingredients are 
organic . Moreover , the labels of food and pet food are intended for the same customers: pet 
food and food (including prepacked food) are both sold at retail level to final consumers.   
Against this background, the purpose of this proposal is to establish  specific labelling rules for 
pet food. These rules will allow pet food , in particular for cats and dogs,  to bear the organic 
production logo of the European Union . Moreover, the organic production logo of the 
European Union  will be mandatory for prepacked pet food labelled as organic . 
The proposal will support  the small but growing organic pet food sector  by allowing 
producers  to use the organic production logo of the European Union  when  promot ing their 
products . In addition, the proposal  will contribute to the development of organic agriculture 
via the possibility of creat ing added value for organic by -products  that may be used in the 
production of pet food . This is in accordance with the Green Deal, the Farm to  Fork and 
Biodiversity strategies, the Action Plan for the Development of Organic Production, and the 
target of achieving 25% of EU agricultural land under organic farming by 2030.  
• Consistency with existing policy provisions in the policy area  
The propos al is consistent with Regulation (EU) 2018/848 . The proposed labelling rules for 
organic pet food mirror the labelling rules appl icable  to food , including the mandatory 
requirement of the use of the organic production logo of the European Union on the 
                                                 
1 OJ L 150, 14.6.2018, p. 1.  EN 2  EN packaging of prepacked food. Indeed, the labels of those products are intended for the same 
customers: p et food and food  (including prepacked food)  are both sold at retail level to final 
consumers . 
• Consistency with other Union policies  
The propos al is consistent with Regulation (EC) No 767/2009 of the European Parliament and 
of the Council on feed, which contains specific provisions for the labelling of feed for non -
food-producing animals like pets.  
2. LEGAL  BASIS,  SUBSIDIARITY  AND  PROPORTIONALITY  
• Legal  basis  
Article 43(2) of the Treaty on the Functioning of the European Union.  
• Subsidiarity  (for non-exclusive  competence)   
Pursuant to Regulation (EU) No 2018/848, the Union has established a Union -wide organic 
scheme  and harmonised  organic production rules, including rules concerning the labelling  of 
organic products.  The adoption of specific uniform rules for the labelling of organic pet food 
cannot therefore be sufficiently achieved by the Member States . 
• Proportionality  
The proposal proposes  limited and targeted additional rules to the current legislative 
framework for the labelling of organic products. Th ose rules do not go beyond what is 
necessary to achieve the objective of establishing  rules for  the labelling of organic pet food.  
• Choice  of the instrument  
The proposed rules concerning the labelling of organic pet food require their direct 
applicability in the Member States. A Regulation of the European Parliament and of the 
Council is the a ppropriat e instrument for the adoption of specific rules for th e labelling of 
organic pet food , taking into account that the legislation currently in force consists of  
Regulation (EU) 2018/848 . 
3. RESULTS  OF EX-POST  EVALUATIONS,  STAKEHOLDER  
CONSULTATIONS  AND  IMPACT  ASSESSMENTS  
• Ex-post evaluations/fitness  checks  of existing  legislation  
NA 
• Stakeholder  consultations  
NA 
• Collection  and use of expertise  
NA 
• Impact  assessment  
NA EN 3  EN • Regulatory  fitness  and simplification  
NA 
• Fundamental  rights  
NA 
4. BUDGETARY  IMPLICATIONS  
NA 
5. OTHER  ELEMENTS  
• Implementation  plans  and monitoring,  evaluation  and reporting  arrangements  
NA 
• Explanatory  documents  (for directives)  
NA 
• Detailed  explanation  of the specific  provisions  of the proposal  
The propos al proposes to establish specific rules for the labelling of organic pet food. In order 
for pet food to be labelled as organic and bear the organic production logo of the European 
Union, at least 95% in terms of weight of the agricultural ingredients will have to be orga nic. 
When less than 95% of the agricultural ingredients will be  organic, the reference to organic 
may only be used in the list of ingredients in relation to organic ingredients with an indication 
of the total percentage of organic ingredients in proportion  to the total quantity of agricultural 
ingredients.  EN 4  EN 2022/0390 (COD)  
Proposal for a  
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  
on the labelling of organic pet food  
THE EUROPEAN PARLIA MENT AND THE COUNCIL OF THE EUROPEAN UNION,  
Having regard to the Treaty on the Functioning of the European Union, and in particular 
Article 43(2)  thereof,  
Having regard to the proposal from the European Commission,  
After transmission of the draft legislati ve act to the national parliaments,  
Having regard to the opinion of the European Economic and Social Committee2, 
Having regard to the opinion of  the Committee of the Regions3, 
Acting in accordance with the ordinary legislative procedure,  
Whereas:  
(1) Regulation (EU) 2018/848 of the European Parliament and of the Council4 lays down 
rules on the labelling of feed  and applies both to feed for food -producing animals and 
to feed for pets , i.e. pet food . Under that Regulation , while non-organic ingredie nts o f 
agricultural origin are authorised  in the production of organic feed, a term referring to 
organic production cannot be used in the sales description  where not all  agricultural 
ingredient s are organic , even if to a low extent . Moreover, such feed cannot bear the 
organic production logo  of the European  Union . Consequently , final consumers  are 
not directly informed about the compliance  of the product  with organic production 
rules.  
(2) Professional operators are informed about the composition and the proport ion of 
organic, in -conversion and non -organic compounds in feed in accordance with point 
2.1.2 of Annex III to Regulation (EU) 2018/848. By contrast, when feed is sold 
directly at retail level to final consumers, there are currently no rules concerning the  
provision of  information on the organic compounds in the feed where not all of 
agricultural ingredients are organic . This is particularly relevant for pet food . 
(3) Prior to  the application of Regulation (EU) 2018/848, and i n accordance with Article 
95(5)  of Commission Regulation (EC) No 889/20085, certain Member States had 
established national rules or recognised private standards that allowed the use of a 
                                                 
2 OJ C , , p. .  
3 OJ C , , p. . 
4 Regulation (EU) 2018/848 of  the European Parliament and of the Council of 30 May 2018 on organic 
production and labelling of organic products and repealing Council Regulation (EC) No 834/2007  (OJ 
L 150, 14.6.2018 , p. 1 ).  
5 Commission Regulation (EC) No 889/2008 of 5 September 2008 laying down detailed rules for the 
implementation of Council Regulation (EC) No 834/2007 on organic production and labelling of 
organic products with regard to organic pr oduction, labelling and control ( OJ L 250, 18.9.2008, p. 1 ). EN 5  EN term referring to organic production in the sales description of pet food when at least 
95 % of the agricultural ingredients of the product by weight were  organic, mirroring 
the rules for organic processed food.   
(4) The labelling rules for organic pet food at Union level should therefore mirror those 
for organic food, given  that both categories of produ cts are mainly sold at retail level 
to final consumers.  Information on compliance with organic production rules should 
be provided through the terms referring to organic production in the sales description 
and through the use of the organic production logo of the European Union. In order to 
facilitate awareness about compliance with organic production rules , the organic 
production logo of the European Union should be obligatory for all prepacked pet food  
complying with Regulation (EU) 2018/848  and this Regulation and produced within 
the Union , as is the case with prepacked food pursuant to  Article 32(1), point (b), of 
Regulat ion (EU) 2018/848 .  
(5) In order to promote the further development of th e pet food sector, it is appropriate to 
introduce specific provisions on the labelling of organic pet food , on the use of terms 
referring to organic production in the sales description and in the list of ingredients , 
and on the use of the  organic production logo of the European Union .  
(6) Since the objectives of this Regulation  can be better achieved at Union level through  
the adoption of uniform rules for the labelling of organic pet food , the Union may 
adopt measures, in accordance with the principle of subsidiarity as set out in Article 5 
of the Treaty on European Union. In accordance with the principle of proportionality 
as set out in that Article, this Regulation does no t go beyond what is necessary in order 
to achieve those objectives , 
HAVE ADOPTED THIS REGULATION:  
Article 1  
Subject matter  
This Regulation lays down specific labelling requirements for pet food produced in 
accordance with the rules concerning organic prod uction provided in Regulation (EU) 
2018/848.  
Article 2  
Definition s 
For the purpose of this Regulation,  the following definitions apply:  
1. ‘pet food’ means feed intended for pet s as defined in Article 3(2), point (f), of 
Regulation (EC) No 767/2009 of the European Parliament and of the Council6; 
2. ‘prepacked pet food ’ means any single item of pet food for presentation as such to 
the final consumer, including the packaging into wh ich it was put before being 
                                                 
6 Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the 
placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 
1831/2003 and repealing Council Directive 79/373/EEC, Commission Directive 80/511/E EC, Council 
Directives 82/471/EEC, 83/228/EEC, 93/74/EEC, 93/113/EC and 96/25/EC and Commission Decision 
2004/217/EC  (Feed marketing  Regulation)  (OJ L 229, 1.9.2009, p. 1).  EN 6  EN offered for sale, whether such packaging encloses the food completely or only 
partially, but in any event in such a way that the contents cannot be altered without 
opening or changing the packaging; prepacked pet food does not c over pet food 
packed on the sales premises at the final consumer’s request or prepacked for direct 
sale. 
Article 3  
Use of terms referring to organic production  on the labelling  of pet food  
1. For pet food, the terms referred to in Article 30 (1) of Regulation (EU) 2018/848 may 
be used:  
(a) in the sales description and in the list of ingredients, provided that:  
(i) the pet food complies with the detailed production rules set out in Part V 
of Annex II to Regulation (EU) 2018/848 and with the proces sing 
techniques laid down in accordance with Article 17(3) of that Regulation; 
and 
(ii) at least 95 % of the agricultural ingredient s of the product by weight are 
organic;  
(b) only in the list of ingredients, provided that:  
(i) less than 95 % of the agricu ltural ingredients of the product by weight are 
organic, and provided that those ingredients comply with the production 
rules set out in Regulation  (EU) 2018/848 ; 
(ii) only feed additives and processing aids authorised pursuant to Article 24 
of Regulation (EU) 2018/848 are used in the processing of the pet food ; 
and 
(iii) the pet food complies with the detailed production rules set out in points 
1.5, 2.1, 2.2 and 2.4 in Part V  of Annex II to Regulation (EU) 2018/848 
and with the processing techniques laid d own in accordance with Article 
17(3) of that Regulation.  
2. The list of ingredients referred to in  paragraph 1  shall indicate which ingredients are 
organic. The references to organic production may only appear in relation to the 
organic ingredients.  
3. The list of ingredients referred to in paragraph 1 , point (b) , shall include an 
indication of the total percentage of organic ingredients in proportion to the total 
quantity of agricultural ingredients.  
4. The terms referred to in Article 30 (1) of Regulation (EU) 2018/848 and the 
indication of the percentage referred to in paragraph 3 of this Article shall appear in 
the same colour, identical size and style of lettering as the other indications in the list 
of ingredients  referred to in paragraph 1  of this Article . EN 7  EN Article 4  
Use of the organic production logo  of the European Union  on the labelling of pet food  
1. The organic production logo of the European Union referred to in Article 33 of 
Regulation (EU) 2018/848 may only be used in the labelling, presentation and 
advertising of pet  food complying with the conditions referred to in Article 3 (1)(a).  
2. In the case of prepacked pet food bearing a term referred to in Article 30 (1) of 
Regulation (EU) 2018/848 , the organic pro duction logo of the European Union shall 
appear on the packaging.  
Article 5  
Entry into force  
This Regulation shall enter into force on the  third  day following that of its publication in the 
Official Journal of the European Union . 
This Regulation shall be binding in its entirety and directly applicable in all Member States.  
Done at Brussels,  
For the European Parliament  For the Council  
The President  The President  