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Appendix LPetfood advertising

1. Preamble

This section is supplementary to the general provisions of the Code. Special care should be taken by advertisers to ensure that the spirit and the letter of those provisions are scrupulously observed.
2. Registration and substantiation

All pet-food products must be registered in terms of the Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act 36 of 1947 ("the Act”).
All pet-food advertisements must be approved by the Registrar empowered to do so in terms of the Act.
The Registrar must consider an application for the registration of a pet food after investigating and enquiring whether the product so applied for is suitable and sufficiently effective for the purpose for which it is intended and that the claims made are not false and misleading.
The Registrar engages the services of technical advisors being persons or entities who are independent, credible and experts in the field of pet nutrition.
The technical advisors will advise the Registrar whether the claims are accurate, and if the Registrar, on the strength thereof, registers the product, the claims are substantiated within the meaning of Section II, Clause 4.1 of the Code.
3. Definitions and terms

"all life stages”: gestation, lactation, weaning, growth, adult and senior life stages of an animal;
"complementary pet food”: a pet food which is either a treat or is a fresh, frozen or canned meat or fish product that does not meet all the daily feeding requirements of a pet animal;
"complete pet food”: a pet food which contains all the necessary nutrients in the correct amounts and proportions for a given physi-ological need of the pet as established by a recognized authority in pet nutrition and which meets the total daily requirements of a pet animal as specified by these guidelines;
"feed ingredient”: a product of vegetable or animal origin, in its natural state, fresh or preserved, and a product derived from the in-dustrial processing thereof, and an organic or inorganic substance, whether or not containing additives, which is intended for use in oral animal feeding, either directly as such or after processing, in the pre-paration of animal feeds or as a carrier of premixtures. Feed ingredient has the same meaning as ingredient, raw material, feed material, feed-stuff or any words of similar connotation;
"family”: means a group of products which are nutritionally adequate for any or all life stages based on their nutritional similarity to a lead product the nutritional adequacy of which has been substantiated;
"fresh”: meat: not preserved by salting, canning or dehydrating;
"fresh”: other: newly made, produced or gathered/harvested; not stale; not preserved through the use of preservatives;
"immediate container”: means, in relation to a pet food, a container which is in direct contact with the pet food. Hereinafter, in these guidelines, the word "container” shall have a corresponding meaning to immediate container;
"ingredient statement”: means a collective and contiguous listing on the label of the ingredients of which the pet food is composed

"label”: when used as a noun, means any written, printed or graphic representation attached to an immediate container of a pet food or produced on an immediate container in any possible manner and which states the details required in terms of these guidelines for the particular pet food contained therein;
"labelling”: means all labels and other written, printed or graphic mat-ter on pet food or any of its containers or wrappers or accompanying such pet food;
"natural”: a feed or ingredient derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis, or fermentation, but not having been produced by or subject to a chemical synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as might occur unavoidably in good manufacturing practices;
"nutrient”: a substance which conveys nourishment to an animal;
"particular nutritional purpose”: the purpose of satisfying the spe-cific nutritional needs of certain pets whose process of assimilation, ab-sorption or metabolism could be temporarily impaired or is temporarily or irreversibly impaired and are, therefore, able to derive benefit from ingestion of pet foods appropriate to their condition;
"pet animal”: an animal belonging to a species normally nourished and kept, but not consumed, by humans, except an animal bred for fur

"pet food”: animal feed for pet animals;
"registration holder”: the juristic person to whom the Registrar has issued a certificate of registration;
"registration number”: the number given by the Registrar once a product has been registered and under which a product may be sold;
"sell” and "sold”: shall have the same meaning as "sell” as defined in the Act;
"the Act”: the Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (Act 36 of 1947);
"the Department”: the National Department of Agriculture in the Republic of South Africa;
"treat”: when used as a noun, means a complementary pet food prod-uct that is intended by the manufacturer to be fed to cover less than 15% of the daily energy intake of the animal for which it is intended.
4. Existing and new registration numbers
In cases where significant changes have been made to a product's guaranteed analysis or where a product's specification has been changed relating to new claims and resulting from guarantees and/or ingredient changes which have not previously been claimed, a new application for registration shall be submitted in order to allow the granting of a new registration number.
Where the registration holder changes, and the products, which are already registered in the name of such holder, have not undergone a change in specification within the meaning of (1), a new registration number may not be required.
5. Registration of products that deviate from the guidelines

Pet foods that deviate from the nutritional adequacy requirements spe-cified in the guidelines shall be registered only if, in the opinion of the Registrar, their nutritional adequacy has been substantiated by scientific trials and/or scientific data and they are fit to be placed on the market.
6. Requirements for the registration of pet food products
Labels and labelling
All pet food products shall comply with the label under which they are sold and with the mandatory labelling requirements as set out in the Regulations and the Guidelines to Act 36 of 1947
2. "Best before” date
  1. Dry pet food containers must carry a "best before” date which is up to 12 months from the date of manufacture and information in support of the shelf life must be supplied to the Registrar with the application for regis-tration.
  2. Wet pet food containers must carry a "best before” date which is up to 24 months from the date of manufacture and information in support of the shelf life must be supplied to the Registrar with the application for regis-tration.
  3. "Best before” dates exceeding these respective limits are allowed if substantiated
7. Labelling and marking of pet food containers

Pet food labels shall also conform to the following requirements:
A vignette, graphic, or pictorial representation of a prod-uct on a pet food shall not misinterpret the contents of the package.
Personal or commercial endorsements are permitted on labels where said endorsements are factual and not other-wise misleading.
The label of a pet food shall not contain an unqualified representation or claim, directly or indirectly, that the pet food therein contained or a recommended feeding there¬of is or meets the requisites of a complete, scientific or balanced ration for dogs or cats unless such product or feeding complies with the requirements of item 5 above.
The use of claims on pet food labels stating improvement or newness shall be substantiated and limited to the first twelve months' production.
The use of claims stating a preference or comparative attribute shall be substantiated and limited to one year of production after which the claim must be removed or re-substantiated.
Enriched or fortified terms used on a pet food label require that the food must contain 25% and 15% more than the nutrient requirements for enriched and fortified respectively.
Calorie terms such as "light”, "less”, "reduced” or terms and words of similar connotation must be substantiated against a standard maintenance diet in the advertiser's own product range.
Fat-content-related terms such as "lean”, "less”, "reduced fat” or terms and words of similar connotation must be substantiated against a standard maintenance diet in the advertiser's own range.
Claims as to the content of particular ingredients shall be subject to the following rules, which are based on fin-ished products, and for which credible rehydration or de-hydration factors respectively shall be used when ap-plying them to products containing a combination of dry and wet ingredients:
  1. "with X flavour” shall mean either that there are traces of the flavour substance, essence or extract present in the product, or that there is up to or including 4% of X itself in the product;
  2. "with X” shall mean that there is at least 4% of X present;
  3. "high in X”, "rich in X”, or "with extra X” shall mean that there is at least 14% of X present;
  4. "X dinner”, "X recipe” or "X menu” shall mean that there is at least 26% of X present;
  5. "all X” shall mean that at least 65% of X is present;
  6. When the ingredient or material is described as a form following the name of the material, the inclusion level must be at least 26%, eg Beef Cubes, then the beef inclusion must be at least 26%.
  7. When the form of the ingredient or material precedes the name of the material, the inclusion level must be at least 65%, eg Cubes Beef, then the beef inclusion must be at least 65%.
Where "X” in subparagraph (h) above refers to the meat of an animal, the meat used for the purposes of making such a meat claim may include all parts of that species except:
  • added blood;
  • bone and bone meal;
  • bone fraction of fresh materials which consist of fleshy or other moist material with associated bone;
  • bone contents of meat and bone meals;
  • bone content of poultry carcasses;
  • bone component of poultry meals;
  • meals/greaves from knackers;
  • claws;
  • hair;
  • horns;
  • hide (except pork rind);
  • feathers;
  • teeth;
  • hooves;
  • the content proportion of intestines;
  • added fat.


An affidavit pertaining to the use and inclusion level of this ingredient must be submitted.
Where "X” in subparagraph (h) above refers to a species of an animal, the material used for the purpose of making such a species claim may include all parts of that species except :
  • bone and bone meal;
  • meals/greaves from knackers;
  • claws;
  • hair;
  • horns;
  • hide (except pork rind);
  • feathers;
  • teeth;
  • hooves;
  • the content proportion of intestines.
In addition, the material shall contain at least 25% tissue material.
The "best before” or "use by” date and the batch number may be marked on a part of the packaging other than the label. In such cases, the relevant expression shall be ac-companied by an indication of where the information ap-pears on the container.
Declarations of feed ingredients shall conform to the fol-lowing requirements:
  1. The listing of feed ingredients on pet foods shall either indicate the amount contained or name the feed ingredients by mass in descending order;
  2. The feed ingredients shall be described by inter-nationally recognized specific names. However, categories grouping several feed ingredients may be used. In such cases, the indication of the spe-cific name of the feed ingredient may be replaced by the name of the category to which the feed ingredient belongs. Use of one of these two forms of declaration shall exclude the use of the other, save where one of the feed ingredients be¬longs to none of the categories that have been defined. In such a case, the feed ingredient, desig¬nated by its specific name, shall be mentioned in order of importance by mass in relation to the categories.
  3. Vitamins and minerals may be grouped or split into individual elements independent of sub-item (ii) above.
The labelling of pet foods may also draw particular atten¬tion outside the area designated on the label for the items listed to the presence or content of one or more feed ingredients and/or nutrients which are essential aspects of the characteristics of the pet food. In such a case, the in¬gredient must form part of the ingredient statement. In the case of nutrients, the minimum or maximum content must clearly be indicated as part of the guaranteed analysis and must follow the mandatory guarantees. In the case of ingredients, the percentage inclusion must be stated as a minimum in the ingredient statement.
Guarantees are not required for label claims that refer to a nutrient which is contained in a specific ingredient (eg, "corn is a rich source of linoleic acid”), or for claims that refer to a group of ingredients or nutrients (eg, "fortified with vitamins and minerals”).
The person responsible for the labelling particulars of a pet food may provide information in addition to that required under these guidelines. However, such infor-mation –
  1. may not be designed to indicate the presence or content of analytical constituents other than those present;
  2. must not mislead the user, in particular by attributing to the pet food effects or properties it does not possess or by suggesting that it possesses special characteristics when, in fact, all similar pet foods possess such characteristics;
  3. must not claim that the pet food will treat or cure a disease;
  4. must relate to objective or quantifiable factors which can be substantiated;
  5. must not misrepresent the contents of the con-tainer.
In the case of a complementary pet food, the directions for use shall be sufficient to make it clear to the person administering the pet food that the complementary pet food is not a complete food and is, therefore, only suit-able for short-term or intermittent use or, in the case of pure meat and fish products, that the complementary pet food has to be mixed with a complete dry pet food so that together they will provide all the energy and nutri-tional needs of the particular animal and physiological state for which they are intended.
Statements of energy content shall not be permitted on labels.
Statements of digestibility of nutrients or dry-matter con¬tent shall not be permitted on labels.
Claims such as premium, super premium, high digestibi-lity or claims with a similar connotation must be scienti-fically substantiated by the manufacturer against standard or base-line products within the manufacturer's own product range.
No reference to quality or grade of an ingredient shall appear in the ingredient statement of a pet food.
A reference to the quality, nature, form, or other attri-butes of an ingredient shall not be made unless such ref-erence is accurate and unless the ingredient imparts a dis-tinctive characteristic to the pet food because it possesses that attribute.
Label claims to prevent or reduce the risk of FLUTD, cystitis, urinary problems or similar verbiage are limited to the claims.
Labels claims with respect to raw hides, biscuits and other pet-food products claiming to cleanse, freshen or whiten teeth by virtue of their abrasive or mechanical action are allowed, as is food bearing claims for plaque or tartar re¬duction or prevention, or control of breath odour. All such claims are subject to substantiation.
The following additional indications shall appear on the label or labelling of pet foods for a particular nutritional purpose:
  1. the precise use, ie the particular nutritional purpose for which the product is intended;
  2. the indication of the essential nutritional characteristics of the pet food;
  3. the recommended length of time for use of the pet food.
The labelling of pet foods for particular nutritional purposes may make reference to a specific pathological condition as long as no drug claims are made and proper product registration has been completed.
The label of pet foods for particular nutritional purposes must bear an indication of such fact, eg "It is recommended that a specialist's or veterinarian's opinion be sought before use”.
The labelling of a pet food for a particular nutritional purpose may also highlight the presence of the low level of one or more nutrients and/or ingredients essential for the description of the pet food. In such cases, the minimum and/or maximum level of the nutrients expressed in g/kg of the pet food must be expressed in the guaranteed analysis. The ingredients must be clearly indicated in the ingredient list.
8. Claims, content, and analyses

All pet food offered for sale must comply with the standards as set out in the Act, its regulations and guidelines (or the specific standards of such product registrations as may be allowed and registered by the Registrar). The pet food must analyse correctly with regard to its registered stan¬dards and the guaranteed analysis, and as regards the ingredient state¬ment and label claims advertised on the container containing the prod¬uct. If a brand of pet food is, upon testing and analysis, found to be det¬rimentally outside the required registration standards, it will be deemed to be misleading and in contravention of this code.
9. Procedure: Sampling and testing of pet food

When bags of pet food are purchased for testing purposes, the following procedure shall be used:

Three identical sealed bags are to be purchased at the same retail outlet. Check for Batch ID and/or Manufacturing Date and attempt to buy three bags as close to each other as possible based on this information.
The bags must remain sealed, and be handed to a representative of the PFI, or transfer one bag direct to the designated laboratory for analysis, who will note the batch number or mark the bags to identify same. If transferred to the laboratory directly then note the batch number or mark the bag yourself.
The purchaser will complete and sign an affadavit before a commissioner of oaths as proof of purchase of the bags referred to above. The affadavit will be substantially similar to the specimen appended hereto as Annexure 1.
The representative of the PFI will personally deliver one of the bags to the laboratory who will test the pet food (if this has not already been done) and will retain the other two bags, one for further testing if needed, and the other to be supplied with the complaint to the ASA.
The PFI representative will complete and sign an affadavit before a commissioner of oaths as proof of receipt of the bags referred to above. The affadavit will be substantially similar to the specimen appended hereto as Annexure 2.
The representative of the PFI will also obtain an affadavit from the laboratory as proof of receipt of the bag of pet food and to verify the test results. The affadavit will be substantially similar to the specimen appended hereto as Annexure 3.
Should the registration holder/owner of the pet food so tested dispute any of the procedure or results, copies of the affidavits will be presented to him/her and he will be allowed to take a sample of the retained bag or stipulate at which laboratory he would like it analysed.
Annexure 1
Affadavit by Purchaser
I, the undersigned, do hereby make an oath and say:
1. I am an (job description) and reside at (address). The content of this affadavit falls within my personal knowledge, and is both true and correct.
2. I purchased three bags of (registered name) pet food from (name and place of purchase) on (date of purchase) on behalf of the Pet Food Industry Association. The bags were marked with the following batch number/I marked the bags as follows: (give batch number or marking).
I handed the three bags to (person that took possession).
I handed one of the bags to (name of laboratory and person that took possession) for testing, and handed the two bags to (person that took possession).
Thus done and sworn to before me at this day of ,
the deponent having acknowledged that he knows and understands the content of this Affadavit, that he has no objection to taking the pre-scribed oath, and considers the oath to be binding on his conscience.


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