Feed labelling — what must appear on the label

A label travels with a feed product from the moment it leaves the production plant right through to its actual use by the customer — on a farm, in a holding, or at another processing plant. Many companies treat it as a formality completed at the end of the production process, just before shipment, yet in practice it is one of the most frequently checked elements, both in official supervision and during a GMP+ certification audit. The guide below describes general principles and the categories of information typical of feed labelling in the European Union, without citing specific article numbers or the exact wording of regulations — these should always be verified against the current text of the relevant rules or with a legal adviser specialising in feed law.

Why proper labelling matters

A label performs several functions at once. First, it tells the customer what they are actually buying — what type of product it is, what it is intended for, which animal species it is meant for, and what it contains. Second, it enables safe use of the product — particularly for feed additives or premixes, where incorrect dosing can have a real impact on animal health. Third — and this aspect is especially relevant from the perspective of quality systems such as GMP+ — the label is part of a wider traceability system, because it is on the label itself (or on the accompanying delivery document) that the batch number appears, physically linking the product held by the customer to the production record at the manufacturer's plant.

From the perspective of a professional customer — a livestock farmer, a farm, or another company further along the feed chain — the label is also the primary source of information needed to make a purchasing decision and to use the product correctly in animal feeding. A lack of clear information about the target species, recommended dosage or storage conditions increases the risk of misuse, even if the product itself meets all quality requirements. Labelling should therefore not be treated purely as a formal obligation towards supervisory authorities, but also as a practical tool for communicating with the customer. GMP+ traceability requirements — described in more detail on the GMP+ standard requirements page — assume that a company can quickly establish where the raw materials used to produce a given batch came from and which customers that batch was delivered to. The label, together with production records and sales documents, is one link in that chain — which is why its quality and consistency with the rest of the documentation has a direct bearing on whether the traceability system in a company actually works in practice, and not only on paper.

General principles of feed labelling in the EU

Placing feed on the market and using it within the European Union is subject to EU feed legislation, including rules that apply directly to the labelling of feed materials, compound feed and feed additives (the key piece of legislation in this area is the regulation on the placing on the market and use of feed). Without going into the detailed wording of individual provisions, a few principles common to this whole area of regulation can be highlighted.

The basic principle is that the information given on the label must be consistent with the actual nature, composition and intended use of the product. A label must not mislead the customer — not as to the type of product, nor as to its origin, properties, composition or the way it was manufactured. This applies both to information stated directly and to anything that, through its wording or graphic presentation, might suggest false characteristics of the product. A second important principle is that the operator placing the product on the market is responsible for the content of the label — it is that operator who must ensure the information on it is true, current and compliant with applicable requirements, regardless of whether it manufactured the product itself or merely distributes it under its own brand.

A third principle, often overlooked in practice at smaller plants, concerns consistency between the label and the documentation accompanying a sale — the invoice, the delivery document or the technical specification handed to the customer. Discrepancies between these documents (for example a different product name on the invoice than on the label, or a different batch number) make it harder for the customer to identify the product unambiguously, and in the event of an inspection or a complaint they create an extra source of confusion that is easily avoided by consistently using the same identifiers across all documents relating to a given batch.

Basic mandatory elements on the label

Although the exact scope of information depends on the type of product, there are categories of data that in practice appear on the label of the vast majority of feed placed on the market in the European Union. The first is the name or designation of the product together with an indication of its type — whether it is a feed material, compound feed (complete or complementary), a feed additive or a premix. The second category is the species and, in many cases, the category of the target animals the product is intended to feed — this information can be critical, especially for products containing substances with species-specific restrictions.

The third category is the composition of the product — its form depends on the type of feed: for feed materials and compound feed, a list of ingredients used (the feed materials making up the compound feed) and an analytical declaration are usually required, i.e. an indication of the basic nutritional parameters of the product (such as protein, fat, fibre or ash content, depending on the type of compound feed). For feed additives and premixes, what matters most is unambiguous identification of the active substance, its declared content and the recommended dosage. The fourth category is identification data — the net content of the product in the package, the details of the manufacturer or of the operator responsible for placing the product on the market (name, address), the production batch number and, where relevant, storage conditions and — in some cases — a best-before or minimum durability date.

It is worth stressing that the set of categories above is a general, indicative description of the information typically found on feed labels — it is not an exhaustive, legally binding list of requirements for a specific product. The actual, detailed scope of mandatory label elements must always be established on the basis of the currently applicable regulations relevant to the type of product in question, since it differs depending on whether the product is a feed material, compound feed or a feed additive, and — in some cases — on whether the product is intended for farm animals or for pets.

Differences in labelling requirements for different product types

The scope of mandatory label information grows along with the complexity and the potential risk associated with the product. A feed material — a raw material used directly in animal feeding or as an ingredient in compound feed production — is usually subject to comparatively simpler labelling requirements, focused on clearly identifying the type of raw material, its origin and its basic parameters. Compound feed, whether complete or complementary, already requires a more extensive declaration — typically including a list of the feed materials used and an analytical declaration reflecting the nutritional value of the finished product, tailored to the species and category of animals the compound feed is intended for.

The most extensive requirements usually apply to feed additives and premixes. Because these are products with a relatively small mass in relation to their potency, the label must clearly state the active substance and its declared content, the recommended dosage in the finished feed, the target species and, where relevant, warnings and precautions associated with using the product, including any withdrawal periods or restrictions on combining it with other substances. Plants that produce several product categories at once — feed materials, compound feed and additives — should be clearly aware within the company that each of these categories requires a separate approach to preparing the label template, rather than one universal template used across the whole product range. We describe the specifics of production for individual product categories in more detail on the GMP+ for feed production page.

In practice, a company producing both compound feed and premixes sometimes uses two separate label graphic templates — not only because of the different scope of required information, but also to visually distinguish products with a different risk profile and a different way of being used. This approach also makes it easier for sales and warehouse staff to quickly recognise which type of product they are handling, further reducing the risk of error when assembling a shipment.

Batch number as the link between the label and traceability

Of all the elements on a label, the batch number deserves particular attention, because it acts as a bridge between formal labelling and the practical traceability required by GMP+. The mere fact that a batch number appears on the label is not enough — it must be legible, unambiguous and actually consistent with the record in the production documentation for that specific batch. In practice this means that the system for assigning batch numbers should be simple and consistent, and the print or label carrying the batch number should remain durable and legible throughout the product's shelf life, not only immediately after it leaves the plant.

The importance of the batch number becomes fully apparent during a traceability test, also known as a mock recall — an exercise in which a company checks how quickly and how precisely it can reconstruct the path of a specific batch backwards (to the raw materials and suppliers) and forwards (to the customers the product was delivered to). If the batch number on the label is illegible, ambiguous, or differs from the number used in internal documentation, the whole traceability process fails in practice — no matter how well the procedures are described on paper. GMP+ auditors pay particular attention to this consistency, because it determines whether, in a real situation — for example, when a product needs to be withdrawn from the market — a company can actually handle the task within a reasonable time.

It is also good practice to keep a simple register linking internally assigned batch numbers to the numbers visible on the label, if for some reason the two designations differ (for example, when an IT system generates an internal batch number in a different format from the one printed on the packaging). Ideally the two numbers are identical, which greatly simplifies both day-to-day warehouse work and the course of a traceability test — but if, for technical reasons, the numbers must differ, a clear mapping between them should be documented and readily accessible to whoever is responsible for handling a potential incident.

Declared composition vs. actual formulation

One of the foundations of trust in a label is that what it states matches what the product actually contains. This seems obvious, yet in the day-to-day practice of production plants, discrepancies between declared and actual composition are among the more common sources of non-conformity — both in official inspections and during certification audits. The most frequent cause is not deliberate misrepresentation, but a lack of formal connection between the process of changing a formulation and the process of updating the label.

When a plant changes a formulation — for example replacing one raw material with another of similar parameters, changing the supplier of a component that affects the analytical declaration, or adjusting the share of a feed additive — that change should automatically trigger a review of the label template linked to the product concerned. If these two processes — formulation management and label management — operate independently of each other within the company, with no formal point of contact, there is a real risk that the product will start being manufactured to the new formulation while labels reflecting the old composition are still in the warehouse (and still being used).

Formulation management — its formal approval and versioning — is a topic covered in more detail in the context of production on the GMP+ for feed production page. From a labelling perspective, what matters is that every version of a formulation has a clearly assigned, current version of the label — so that whoever is responsible for printing or ordering the next batch of packaging can easily verify they are using the correct, current template rather than an archived version kept, for instance, in an old graphic file on an employee's local drive.

Labelling for export

Selling feed outside the domestic market — whether to another EU country or beyond the Union's borders — adds an extra layer of labelling challenges. Within the European Union, basic labelling principles are harmonised, but in practice a customer in another member state expects a label in a language they understand, which usually means preparing a language version suited to the target market — either through a separate print run or through a multilingual label covering the markets a company regularly exports to.

Selling outside the European Union tends to be more complex, since individual non-EU countries may have their own, separate requirements regarding the scope and form of feed labelling, different from those applicable within the EU market. Without going into the details of specific third-country regulations (which are always worth verifying individually, ideally with a local trading partner or an adviser familiar with the realities of the given market), the general rule is that an exporter should check in advance whether the standard label template used on the domestic market meets the requirements of the target country, or whether it needs modification — for example adding information not present on the EU label, changing units of measurement, or adjusting the date format.

When planning regular exports, good practice is to prepare a separate, documented label template for each target market with different requirements, rather than making ad-hoc, manual modifications to the domestic label for every individual shipment. This approach reduces the risk of error and also makes it easier to update all language versions in parallel whenever the formulation or the manufacturer's details change.

Common mistakes in feed labelling

Experience from advisory and audit work shows a handful of recurring mistakes. The first, and probably the most common, is inconsistency between the label and the current formulation — the situation described above, where a change in composition is not reflected on the label in time. The second is simply an outdated label still in use alongside a new version — for example when the packaging store has not been restocked with the new print in time and staff, wanting to avoid a production stoppage, reach for the remaining stock of old labels "temporarily", which in practice often lasts longer than originally intended.

A third frequent mistake is the absence of a legible, unambiguous batch number — either because the print quality is poor and fades during transport and storage, or because the batch number is generated manually and prone to error (for example the same number being repeated for two different batches). A fourth is incomplete or outdated contact details for the manufacturer or the responsible operator — for example after a change of registered address or after two entities merge, when old labels with out-of-date details are still circulating in warehouses.

A fifth, less often mentioned but regularly encountered, mistake is inconsistency in units and data format between products within the same portfolio — for example when one compound feed has its analytical declaration expressed in a different layout from the rest of the products in the same line, which makes it harder for the customer to compare offers and creates an impression of a lack of internal documentation consistency within the company. It is also worth mentioning purely editorial errors — typos in the name of an active substance, or a value copied incorrectly from a previous version of the label — which, though seemingly minor, can have serious consequences if they concern, for example, the recommended dosage of a feed additive.

Labelling and the GMP+ audit

During a GMP+ certification audit, product labelling is one of the elements checked in a practical way, not just through a review of documentation. The auditor typically asks to see a sample label (or a photograph of the packaging) for selected products from the range, then compares its content with the current, formally approved formulation and with the production record for the specific batch whose number appears on the label. In doing so, the auditor checks whether the list of ingredients or the analytical declaration on the label actually matches what was produced, rather than, for instance, an earlier version of the formulation.

Very often this element is directly linked to the traceability test described earlier — the auditor asks the company to locate the documentation for the specific batch whose number appears on the selected label, and to trace the production record for that batch. If the company is unable to reconstruct this path efficiently, or if it turns out that the label refers to a different version of the product than the one actually manufactured, this is usually treated as a major non-conformity requiring documented corrective action within a specified deadline. We describe the general course of the certification audit — including how documentation preparation and the auditor's visit to the plant look — on the GMP+ certification process page.

It is worth stressing that auditors do not expect only the existence of a correct label as such, but above all evidence that the process of approving and updating it is organised in the company in a repeatable way — meaning that every change to the product is reflected on the label within a reasonable time, and that the label's consistency with the formulation is not a matter of chance or the result of a one-off, ad-hoc correction made just before the auditor's visit.

How to organise the label approval process in your company

Effective label management rests on a few simple but consistently applied principles. First, every change to a formulation — no matter how minor it may seem from a technological point of view — should formally trigger a review of the label template linked to the product concerned, before the new version of the product reaches sale. This link is best written explicitly into the company's change-management procedure, rather than left to the default vigilance of whoever is responsible for labels.

Second, good practice is to keep a version history of labels — even in the simple form of an archive of graphic files with dates and version numbers — so that, if needed (for example in response to a complaint about a batch sold several months earlier), it is possible to reconstruct unambiguously which label template was in force during a given period and whether it matched the formulation used at that time. Third, before every new print run or order of packaging, it is worth carrying out a short check that the current template matches the current formulation — a simple, few-minute step that in practice prevents many costly mistakes, such as printing a large batch of labels reflecting an outdated product composition.

Fourth, it is worth clearly assigning responsibility for approving the final version of a label to a specific person or role within the company — so that it is always clear who formally confirms that the label's content matches the formulation and applicable requirements before the template goes to print. Diffuse responsibility, where a label is decided on by "whoever happens to be dealing with it" at a given moment, is one of the most common sources of the mistakes described in this article. In practice, a simple label-approval checklist works well — a short list of points to confirm (consistency of name, composition, manufacturer details, batch number, storage conditions) worked through by the responsible person for every new or amended version, before the template is sent for printing or used to mark the next batch.

Finally, for companies working with external printers or packaging suppliers, it is worth establishing a clear channel for passing on updated graphic files — so that it never happens that a printer works from a file sent several versions earlier, simply because no one formally informed them of the update. A simple register, in which every new file sent for printing is logged with a date and version number, makes it much easier to clarify any discrepancies later and quickly establish at which stage of the chain an error occurred.

Glossary

Feed label

The set of information placed on the packaging of a feed product, or in an accompanying document, identifying the product, its composition, intended use and origin, and enabling its safe and correct use.

Composition declaration

A list of ingredients used, or an analytical declaration indicating the basic nutritional parameters of the product, the form and scope of which depend on the type of feed (feed material, compound feed, feed additive).

Batch number

A unique identifier for a given production batch, placed on the label or the delivery document, forming the primary link between the product held by the customer and the production record in the manufacturer's documentation.

Responsible operator

The company responsible for placing the product on the market and for the label's content complying with applicable requirements, regardless of whether it manufactured the product itself or merely distributes it under its own brand.

Feed material vs. compound feed

A fundamental distinction that affects the scope of labelling: a feed material is a single raw material with usually simpler labelling requirements, while compound feed is a product made up of several ingredients, requiring a more extensive declaration of composition and nutritional value.

Label versioning

The practice of formally marking and archiving successive versions of a label template, linked to the corresponding version of the formulation, allowing unambiguous reconstruction of which template was in force during a given period.