FEDIAF EuropeanPetFood aisbl
FEDIAF
FEDIAF is the trade body representing the European pet food industry.
ID: 053117613298-41
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
FEDIAF is the voice of the European pet food industry. We represent 15 national pet food industry associations and five pet food manufacturers operating in Europe, accounting for around 95% of the market. We work closely with EU institutions, national authorities, scientific bodies and NGOs to ensure the availability of safe, nutritious and high-quality pet food across Europe, while promoting best practices and supporting a resilient, sustainable and competitive sector. FEDIAF welcomes the Commissions ambition to accelerate Europes circular transition. The European pet food sector already operates one of the EUs most established bio-based circular systems by safely converting Category 3 Animal By-Products (ABPs)materials originally intended for the human food chain but not consumed for various reasonsinto nutritious, high-quality pet food. This practice keeps valuable biological resources in productive use, reduces waste, and contributes to European food and feed security. However, the success of such systems depends on ensuring coherence across EU circularity, bioeconomy and renewable energy policies. Current incentives under the Renewable Energy Directive (RED) encourage the diversion of certain ABPs into biofuel production. This creates competition with the feed chain and risks shifting essential nutrient resources away from food and feed uses toward energy, contrary to the cascading use principle. To ensure sustainable resource management, nutrition and feed applications must be prioritised before energy recovery. The Circular Economy Act (CEA) should clearly distinguish ABPs from waste and secondary raw materials. ABPs are safe, regulated biological inputs that support a mature, high-value circular supply chain. Misclassification could generate legal uncertainty and undermine investment and supply stability. The CEA should recognise the ABP framework as a model of effective risk management and traceability that can inform wider circularity governance. Protecting the availability of Category 3 ABPs is essential for maintaining feed and food security, industry competitiveness, and SME resilience across the pet food value chain. At the same time, the sector continues to actively explore and invest in alternative proteinsincluding insect, plant, microbial and fermentation-derived ingredients. Such innovation should be supported through clear, science-based regulatory pathways that ensure safety, nutritional adequacy and consumer acceptance, while complementing, rather than replacing, existing circular systems. Overall, the CEA should act as a coherent framework that integrates circularity and bioeconomy objectives, ensures consistent material classification, safeguards biological feedstock availability, and promotes responsible innovation. By doing so, it can strengthen Europes resilience and sustainability while maintaining high standards for animal nutrition and welfare. Key Recommendations: - Recognise existing bio-based circular systems: Acknowledge the longstanding use of Category 3 ABPs in pet food as a model of efficient circularity. - Embed the cascading use principle: Ensure food and feed applications are prioritised before energy recovery. - Ensure policy coherence: Align the CEA with renewable energy, bioeconomy and waste legislation to avoid conflicting incentives or regulatory overlap. - Safeguard feedstock availability: Prevent policy-driven diversion of ABPs into competing uses that risk food/feed security. - Support responsible innovation: Enable alternative protein development under science-based, proportionate regulatory pathways.
Read full responseResponse to Food and Feed Safety Simplification Omnibus
13 Oct 2025
FEDIAF, representing the European pet food industry, welcomes the European Commission's Call for Evidence on the Food and Feed Safety Simplification Omnibus initiative. As an association committed to promoting high standards in pet nutrition, animal welfare, and sustainability, we appreciate the Commission's efforts to streamline regulations while upholding robust protections for human health, animal health, and the environment. FEDIAF highlights the need for proportionate and risk-based regulatory approaches. We support a more flexible system for the authorisation and renewal of feed additives, replacing the fixed 10-year renewal period with reassessment only when new evidence arises, in line with the food additive model. The use of in-vitro and in-silico methods should be encouraged to reduce reliance on live animal testing, consistent with the 3R principles. FEDIAF also endorses the digitalisation of labelling for feed additives and suggests that a similar approach should be considered for compound feed in the future. Regarding BSE-related rules, proportionate updates are supported to reflect todays low risk levels, provided they remain science-based and maintain consumer confidence. Finally, FEDIAF welcomes clarification on the legal status of fermentation products obtained using genetically modified micro-organisms, supporting their classification as feed produced with GMOs and therefore outside the scope of GMO legislation. Please find a more detailed position in the attached document. We stand ready to engage further, providing detailed insights from our members to support the Commission's work.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
Please find attached the contribution of FEDIAF. FEDIAF is the united voice of the European Pet Food Industry. Our membership includes 15 European national pet food associations, together with five pet food manufacturers operating in Europe. This equates to around 95% of the industry.
Read full responseResponse to Evaluation of the European Food Safety Authority (EFSA) 2017-2024
8 Apr 2024
FEDIAF is the trade body representing the European pet food industry. Our association brings together 15 national trade associations from 18 countries and five companies that are members in their own capacity. We welcome the opportunity to contribute to the call for evidence and evaluation of EFSA performance in the years 2017- 2024 and thank the European Commission for consideration of our initial feedback as attached. We look forward to providing further information in the future consultations.
Read full responseResponse to Welfare of dogs and cats and their traceability
11 Mar 2024
FEDIAF, the European Pet Food Association, is the collective voice of its members, comprising 15 national associations and 5 direct companies. The Association advocates for the interests of approximately 150 pet food companies across Europe, representing 95% of the industry. FEDIAF welcomes the opportunity to provide feedback to the EC proposal for new rules on the welfare of dogs and cats and their traceability. FEDIAFs primary expertise in pet food manufacturing and the nutritional requirements of cats and dogs leads us to focus our input on the aspects of watering and feeding. The specific nutritional requirements of pets according to their life stage, health and activity levels are detailed in FEDIAFs Nutritional Guidelines. The Nutritional Guidelines are written and peer-reviewed by a Scientific Advisory Board (SAB) of independent board-certified veterinary nutritionists (veterinarians with an expertise in nutrition). The SAB interprets and evaluates the latest scientific research to ensure the pet food guidance is kept up to date. Based on this, please find attached our feedback along with justifications for the amendments. Many thanks for considering our input.
Read full responseResponse to Setting and reviewing maximum levels for certain undesirable substances in feed
2 Feb 2024
FEDIAF, the European Pet Food Association has noted with interest the proposed amendments to the Directive 2002/32 and associated annexes. We support the ongoing updates to this Directive as need and additional science develops to drive such changes. However, we urge those responsible for such updates to be led by a balance of informed risk assessment and emerging, peer reviewed science to direct updates. As such, we are concerned that some of the proposed changes are not grounded in new emerging research that certain undesirables substances represent a greater risk than first thought. It is also not clear what process has been followed to assess the resilience of the feed industry to the proposed changes. For example, it is clear the changes to the climate can drive variability in crop-based contamination from the action of microbiological entities. It is not clear therefore, that the feed materials supply can guarantee to comply with the proposed lower levels of rye ergot. We note that Nickel has been added to the annex under heavy metals, restricted to the group including mono, di and tri glycerides. While not opposing such an addition, we are not aware of the publication of research that suggests this risk is significant enough to warrant inclusion. As new materials are added to this list, the burden of testing and validation is often carried by producers of animal feed, passed on the consumer over time. We recognise the inclusion of phenetidine as a metabolite of ethoxyquin. It is not clear to our association why this particular metabolite has been added to the list of materials. The industry well understands the restrictions on the use of ethoxyquin under very controlled circumstances. In addition, we are unaware of incidents in which the inclusion of ethoxyquin outside the boundaries specified has been detected and therefore it is not clear how this move increases consumer safety in any way.
Read full responseResponse to Environmental claims based on environmental footprint methods
21 Jul 2023
FEDIAF Position Paper on Green Claims Directive, July 2023 FEDIAF, the European Pet Food Association, welcomes the European Commissions proposal for the Green Claims Directive. Throughout the Commissions consultation process, FEDIAF has sought to be a constructive partner. As such, FEDIAF acknowledges the need for clear legislation regarding Business to Consumer marketing claims of an environmental nature as part of fair commercial practices in the Single Market. We support the development of an EU-harmonised legislative framework which should set minimum requirements for the voluntary provision of product environmental information. FEDIAF and its members have proudly participated during the pilot phase, in partnership with the European Commission, in the development of a methodology (Product Environment Footprint) to substantiate environmental footprint claims in a verifiable and comparable way across the EU. We believe this has the potential to increase the level of consumer confidence to support the Green Transition. It will facilitate a level playing field among companies in the Single Market and encourage more sustainable production and consumption. In light of this, FEDIAF is calling for EU decision-makers to consider the following: - To support harmonisation, FEDIAF had expressed the view, prior to the publication of this proposal that legislation would best be framed as a Regulation, rather than a Directive. A Regulation would ensure environmental claims are substantiated in a harmonised way across the EU thereby leading to greater consumer reliability, clarity and trust. - Article 2: Avoid divergence in definitions between the Green Claims and the Empowering Consumers for the Green Transition directive proposals. These two legislative proposals should be fully aligned to avoid confusion and different interpretations between member states. - Article 10: FEDIAF calls on the EU to consider the wider implications of implementing a pre-approval verification process of environmental claims through a conformity assessment. The enforcement of this proposal may require a significant burden and heavy lifting of enforcement to be carried out by EU member states. It can ultimately also lead to different requirements across EU. - Article 3: FEDIAF has previously advocated for a uniform and robust methodology in the European Union, such as the Product Environmental Footprint (PEF) for Pet Food. We believe that with PEFCRs we have achieved: a robust, credible and comparable methodology allowing operators to assess and communicate the environmental impact of their products; a methodology that can be verified homogenously across EU members states in order to ensure environmental footprint claims are properly substantiated; a methodology that provides a wide view of different environmental impacts; a methodology that can increase the level of confidence in green claims among consumers, supporting in this way the Green Transition. FEDIAF is in favour of the continuous improvement of PEFCRs, its practical implementation and the communication to consumers. FEDIAF's full position paper on the Green Claims proposals, including our recommendations to legislators, is contained in the attached file.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
20 Dec 2022
FEDIAF, the European Pet Food Association, representing 15 National Associations and 5 direct companies, acknowledges the positive development that Category 3 animal fats were not added to the approved list of sustainable biofuel feedstocks ( Annex IX). FEDIAF has been campaigning for the protection of these vital pet food ingredients and is pleased that the Commission has taken this step. However, not being listed in Annex IX is not enough to safeguard category 3 animal fats as they can still be counted towards the overall transport targets. This happens because there are not sufficient safeguards at the legislation allowing individual member states to accept the use of materials for the production of biofuels, which are not mentioned in Annex IX. Despite not being listed in Annex IX, the demand for animal fats category 3 for biofuel production has grown by 88% between 2018 and 2020. Therefore, not including Cat 3 animal fats in Annex IX is not enough to sufficiently safeguard Category 3 animal fats. RED III should contain provisions, which only allows materials listed in Annex IX for the production of biofuels or at least to promote the use in the food/ feed chain before the energetic valorization. We recommend to better define the cascading principle to ensure that animal fats are not deviated away from material use. We also recommend coherence across all files RED, aviation and maritime. We strongly support limiting the production of biofuel to feedstocks listed in RED II Annex IX A and B to ensure these sectors attain their decarbonisation targets utilizing waste-based biofuel feedstocks. Animal fats category 3 are not waste but are by-products that have an important existing use in the pet food sector for which the decreased availability and loss are detrimental.
Read full responseResponse to Amendment of the list of products and substances authorised in organic production
16 Nov 2022
The European Pet Food Industry Association FEDIAF, which represents pet food manufacturers across Europe (15 National Associations and 5 direct companies from a total of 18 countries), welcomes the opportunity to provide comments on the authorised products & substances (updated list) and contribute to the EU decision-making process. Our comments are related to the proposal of authorization of ammonium chloride restricted to be used for particular nutritional purposes for cats in accordance with Commission Regulation (EU) 2020/354. We would like to bring the following points to consideration: - Ammonium chloride is already approved at Regulation 1831/2003 with no restrictions for cats & dogs. - Ammonium chloride in organic pet food would be necessary to produce complete organic pet food to prevent negative consequences on healthy cats, which have a tendency to form urinary stones. This tendency is not related to a disease, but to its carnivorous physiology. Please find attached a paper prepared by Dr. Villaverde, PhD and a Board Certified Veterinary Nutritionist, who summarizes the latest scientific evidence on this regard. This paper also addresses concerns around the long-term use of acidifiers (one of the concerns from the EGTOP report). these findings do not support a negative effect of long term moderate urinary acidification in healthy cats. Based on the above we respectfully ask, the European Commission, to extend the scope of the Ammonium Chloride authorization for cats (and remove for particular nutritional purposes for cats in accordance with Commission Regulation (EU) 2020/354).
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
17 Nov 2021
FEDIAF, the European Pet Food Association, acknowledges and supports the role of renewable energy in achieving the climate ambitions of the EU. Our members have made several commitments in this area already. We believe the revision of the Renewable Energy Directive and its Annex IX provides a good opportunity to address these challenges.
However, the current situation is driving unsustainable patterns, leading to an increase in competition between biofuels, feed and human food or large-scale importation of raw materials outside of the EU. In many cases by-products are no longer available to produce food and feed because they are burned as biofuels. We believe that these are not in line with the Circular Economy ambitions of the EU. Based on this concern, FEDIAF would like to share with you the attached position.
Read full responseResponse to Sustainable food system – setting up an EU framework
26 Oct 2021
FEDIAF, the European Pet Food Industry Federation (EU Transparency Register number 053117613298-41), is the trade body representing the European pet food industry. We have members from 15 National Associations and 5 companies from a total of 18 countries. FEDIAF welcomes the opportunity to provide feedback on the Inception Impact Assessment (IIA) on the Sustainable Food Systems Framework. Please find attached our contribution.
Read full responseResponse to Animal welfare labelling for food
19 Aug 2021
FEDIAF, the European Pet Food Industry Federation, is the trade body representing the European pet food industry.
Pets provide companionship, affection and protection and unique bonds are formed with owners. In addition to being a source of love and friendship, there have been numerous scientific studies analysing the many ways in which pets are good for our mental and physical health. As part of its mission, FEDIAF and its members are fully committed to the wellbeing of pet animals, and to promoting responsible pet ownership. As such, FEDIAF welcomes the opportunity to provide feedback to the Inception Impact Assessment (IIA) on the revision of the EU legislation in animal welfare. Please find our input in the attached file.
Read full responseResponse to Detailed implementing rules for the voluntary schemes recognised by the European Commission
27 Jul 2021
FEDIAF, the European Pet Food Industry Association represents pet food manufacturers across Europe who provide pets with nutritious and balanced pet food every day. FEDIAF welcomes the opportunity to provide comments on the proposal rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria.
Raw materials including animal fat derived from Category 3 by-products have many functions in pet food. They provide a source of protein, energy, palatability. Animal fats are particularly valuable for the diet of pets and even life stock feed as they provide essential fatty acids, energy and contribute to the palatability of the compound feed. They are quite unique and difficult to replace by other commodity. We recognize that the Renewable Energy Directive explicitly only covers by-products from Cat 1 and 2 as a feedstock for the production of biofuels and biogas for transport, but this is not sufficient to safeguard that suitable Cat 3 by-products is reserved for feeding animals. Therefore:
• Annex IV - MINIMUM REQUIREMENTS ON THE METHOD FOR CERTIFYING WASTE AND RESIDUES:
The ABP regulation does allow for the re-categorisation of Cat 3 by-products to Cat 1 or 2 and so potentially removing valuable raw materials from the animal feed production. This cannot be in the spirit of a sustainable economy. We would welcome the cascading principle that is in the RED III proposal to become a binding sustainability criterion for by-products and residues (as opposed to just forest biomass as it is defined now). Hence we recommend to make the decision tree clearer, more effective and transparent. This would avoid competition between biofuels, feed and human food and clear instructions excluding the use of down categorized Cat3 by-products as acceptable feedstock for the production of biofuels could help prevent loss of valuable raw materials.
The use of Category 3 by-products in pet food represents a major valorization route (prevention by reuse) and our industry has ensured this happens in accordance with highest safety and environmental standards. Therefore, it should be considered superior to fuel production, which is the least preferred option and equivalent to energy recovery in the waste hierarchy.
At the moment the evaluation of the sustainability of biofuels based on only GHG emissions results to be not complete. LCA analysis can improve the accuracy of such analysis. Attributional LCA should be joined with consequential LCA to broaden the scope of analysis and have a more clear idea of sustainability of the biofuels sector and interconnections with other industrial sectors as well. In this way the analysis can take into account in a more effective way the waste hierarchy, which should be considered for all the raw materials used in the production phase.
Read full responseResponse to Agriculture - List of products and substances authorised in organic production
23 Apr 2021
FEDIAF, the European Pet food Association, we would like to thank the European Commission for the opportunity to provide additional information during this public consultation on organic farming that focuses on the list of products and substances authorized in organic production. Please find attached our contribution.
Read full responseResponse to Feed additives - revision of EU rules
25 Jan 2021
FEDIAF, the European Pet Food Industry Federation, thanks to the European Commission for the opportunity to express our views on the EC Inception Impact Assessment - Ares(2020)7546840 – on the Revision of the Feed Additives Regulation (EC) No 1831/2003. FEDIAF full feedback as shared via position paper in the attachment.
Read full responseResponse to Amending the Annexes for the labelling of compound feed and pet food
23 Jun 2017
FEDIAF, the European Pet Food Industry Federation, representing the pet food industry in Europe (EU transparency register ID : 053117613298-41) welcomes the modernization of certain parts of the annexes of Regulation 767/2009.
FEDIAF has three proposal for amendments which are in the uploaded document
Read full response