Manufacturing pet food, animal feed, and supplements
The requirements for manufacturers depend on the type of processor and the raw materials used.
Meet ONC requirements
All manufacturers of pet food, animal feed, and dietary supplements must meet the requirements for oral nutritional compounds (ONCs).
Your products are exempt from registration, but you must comply with ONC requirements. These are set out in the Agricultural Compounds and Veterinary Medicines (ACVM) (Exemptions and Prohibited Substances) Regulations 2011.
You must make sure:
- your product is fit for purpose (Regulation 7)
- you have a documented system for manufacturing, follow the system, and keep adequate records (Regulations 9 and 14)
- specified information is on the product label (Regulation 12)
- you don't make misleading statements about it, particularly therapeutic claims (Regulation 13)
- you meet the specific requirements for ONCs (Schedule 2, Part B, entry 22).
If your animal feed or dietary supplement contains animal material, you might already have a risk management programme (RMP) under the Animal Products (APA) Act 1999. You may use your RMP for your documented system for manufacturing – if it covers the other ONC requirements.
When pet food is not pet food
A pet food could be classified as a veterinary medicine if you:
- make claims about your product that aren't just nutritional claims (for example, "this product can help manage arthritis")
- include levels of nutrients above those necessary for the maintenance of health
- include substances that aren't nutrients or feed additives (such as flavours and preservatives).
At a minimum, you'll have to prove any claims. Your product might require registration.
Primary pet food processors
Pet food manufacturers who slaughter and dress animals (primary pet food processors) also need to comply with the APA. As part of this, you'll need to operate under an RMP.
You'll need to meet requirements in the Animal Products Regulations and the Animal Consumption Specifications.
Check the requirements for manufacturing pet food:
- Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2017 [PDF, 1 MB]
- Animal Products Regulations 2000
- Animal Products Act 1999
Operating under a registered RMP
Read the pet food operational code for guidance on meeting requirements. Slaughtered animals must have a post-mortem examination to make sure they're suitable for pet food. Post-mortem tables set out how this must be done.
Operational Code Pet Food Processing [PDF, 1.6 MB]
Secondary pet food processors
If you don't slaughter or dress animals, you're known as a secondary pet food processor.
Your legal requirements depend on whether you are a:
- manufacturer producing pet food requiring official assurances, such as for products for export
- manufacturer producing pet food containing animal material such as red meat, offal, poultry, or fish resulting from the death of an animal (a "further pet food processor")
- secondary pet food processor who doesn't use animal products (except meat and bone meal) in your pet food.
ACVM export certification
There are no ACVM legal requirements for export-only ONCs, but you must keep them separate from products to be sold in New Zealand.
If you want to export ONCs, you may need to meet certification requirements for the importing country. Find out about these requirements:
- Certification under the ACVM legislation [PDF, 547 KB]
Producers requiring official assurances
If you require official New Zealand assurances, you need to meet requirements under the ACVM and APA Acts, and operate under a registered RMP.
Learn more about official assurances:
There may be additional overseas market access requirements (OMARs) depending on which country you are exporting to.
Further (pet food) processors
As well as the ACVM Act, you are required under the APA to:
- comply with relevant parts of the Animal Consumption Specifications (unless exempt)
- only get animal material from regulated sources
- have a documented tracking system to show you meet requirements.
A template and guidance are available to help you develop a documented tracking system:
- Tracking system template for further pet food processors [PDF, 352 KB]
- Tracking system template for further pet food processors [DOC, 318 KB]
- Guidance document: Tracking system template for further pet food processors [PDF, 234 KB]
- Coversheet for guidance document: Approval memorandum for tracking system template [PDF, 324 KB]
You're also required to provide MPI with details of your processing operations by completing this form:
- Further pet food processor listing form AP61 [PDF, 653 KB]
Other secondary pet food processors
If you don't use any animal products (aside from the options listed below) to manufacture pet food, you will not have to operate under the APA. You will still need to meet ACVM Act requirements.
Animal products not considered to require operation under the APA when used in the secondary processing of pet food are:
- raw meat, poultry, or fish bought in a ready-for-sale form from a regulated source (for example, meat bought from a retail butcher or supermarket)
- rendered or manufactured animal product.