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LAWYERS · PARTNERSCHAFT MBB /
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TIERRECHTSANWALT: Animal law firm

Equine law, animal purchases, keeper liability and animal welfare

Animal feed law: labelling, distribution and liability

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This page concerns German law and applicable EU rules. Foreign-law questions require separate assessment.

Horse feed, pet food, complementary feed and premixtures must be properly classified, safely manufactured and accurately marketed. We advise manufacturers, brand owners, importers, online retailers, farms and commercial animal keepers, and assist with disputes involving buyers, competitors and supervisory authorities.

Cattle in a pasture

On this page

How we can help · Product status: feed, additive or veterinary medicine? · Registration, approval and feed hygiene · Formulation, additives and particular nutritional purposes · Labels and mandatory information · Advertising, health claims and online offers · Contamination, traceability and recalls · When animals become ill after feeding · Supply contracts, own brands and distribution · Inspections, warning letters and litigation · Documents for the initial assessment · Frequently asked questions

How we can help

Typical matters include launching an animal feed brand or complementary feed, disputed health claims and suspected contamination. We also handle disputes following illness in horses, dogs or livestock and supply disputes between manufacturers, distributors and farms.

We start with the product, activity and territory: who develops the formula, manufactures, appears on the label and imports the goods? These roles create different responsibilities. Businesses without their own production facilities can also have legal obligations.

Product status: feed, additive or veterinary medicine?

Feed materials, complete feed, complementary feed, additives and premixtures are not interchangeable terms. Composition, purpose, presentation and advertising must align. “Supplement” does not create a separate category with lighter requirements.

The distinction from veterinary medicines needs particular care. Claims to cure or treat disease may change the assessment. Biocides, care products and medicated feed must also be distinguished where relevant. The formula should be assessed together with the label, website and distribution plan.

Registration, approval and feed hygiene

Under Regulation (EC) No 183/2005, the activity’s scope and any registration or approval requirement must first be established. Requirements vary by activity and business stage. Exceptions for certain pet-food retail activities cannot automatically be extended to manufacturing or wholesale.

For new businesses or product ranges, we assess the competent authority, required information and responses to queries. Hygiene, quality assurance, documented procedures, storage and transport may be relevant. General business registration does not replace feed-law registration or approval.

Formulation, additives and particular nutritional purposes

For additives, authorisation status and conditions of use must be checked. Approval for one species or use does not permit the same concentration in every feed. New ingredients and unusual compositions should be reviewed before production and packaging orders.

Feed for particular nutritional purposes is subject to additional requirements. A dietetic purpose cannot simply be chosen for marketing. Legal assessment is coordinated with technical and nutritional documentation; necessary specialist assessments are performed by appropriate experts.

Labels and mandatory information

Regulation (EC) No 767/2009 governs labelling, presentation and marketing. Required information depends, among other things, on feed type. It may include designation, responsible operator, species, composition, analytical constituents, additives, directions, quantity and batch details.

Review should use the actual print artwork. Abbreviations, illegibility and inconsistencies between front, back and accompanying information may create problems. Own-brand contracts should allocate labelling and approval responsibilities; agreements with contract manufacturers do not automatically remove public-law responsibility.

Advertising, health claims and online offers

Claims such as “against osteoarthritis”, “cures allergies” or “replaces medication” require particularly careful review. Feed advertising is subject to specific disease-claim restrictions and prohibitions on misleading statements. Images, testimonials and overall presentation can turn apparently restrained wording into an impermissible therapeutic claim.

Online sellers must make mandatory information available at the required time. An unreadable packaging photograph may not suffice. We review product pages, marketplaces, search ads, newsletters and social media together. Evidence for advertised properties should be documented before publication.

Contamination, traceability and recalls

Mould, foreign bodies, undesirable substances or unusual illness require rapid tracing of affected goods. Articles 18 and 20 of Regulation (EC) No 178/2002 are particularly relevant to traceability and responses to unsafe feed. Withdrawal, authority notification and possible recall are distinct from subsequent liability disputes.

We help assess the legal position, coordinate measures and communicate with suppliers and buyers. Batches, quantities, distribution routes, analyses and timing should be reliably documented. Suspect stock must be secured operationally, and samples and evidence preserved.

When animals become ill after feeding

Timing alone does not prove that feed caused illness. Assessment may require samples, laboratory reports, veterinary findings, ration composition, storage conditions and herd health. Other feed sources and alternative causes must also be considered.

We assess contractual defect remedies, damages and other potential liability. Treatment costs, animal losses and business losses must be proven and legally attributed. Commercial transactions may also involve inspection and notification obligations. We represent affected businesses and defend unfounded claims.

Supply contracts, own brands and distribution

Contracts should cover specifications, approvals, testing, storage, transport and complaints. Contract manufacture and own-brand products also require rules on formula rights, confidentiality, change approval and packaging responsibility.

Recall costs, insurance and recourse should be addressed before an incident. International deliveries also require assessment of governing law, jurisdiction, import rules and potentially the CISG. Lawful marketing in the country of origin does not automatically establish marketability in Germany.

Inspections, warning letters and litigation

For regulatory complaints we examine the investigation report, legal basis, measures and deadlines. Responses may include submissions, legal challenges and urgent administrative court relief. Fine or criminal allegations require a separate defence strategy.

For unfair competition warning letters, we assess the alleged infringement, advertisement, claimant’s standing and requested undertaking. A premature undertaking may restrict distribution for years. Supply and liability disputes are pursued through negotiation and, where necessary, civil proceedings.

Documents for the initial assessment

Product launches require the formula or specifications, target species, draft labels, advertising, channels and countries. Inspections require the full authority letter, analyses and deadlines. Damage claims also need delivery records, batch numbers, samples, veterinary findings and insurance documents.

We first agree the scope and goal: launch, campaign approval, response to a complaint or enforcement of a claim. Technical questions, legal assessment and commercial decisions are coordinated transparently.

Frequently asked questions

Can complementary feed be sold without any assessment? No. This category is also regulated. Business and product obligations depend on the specific offer.

May customer testimonials be used? They must be assessed in their advertising context. A customer’s authorship does not make a therapeutic claim automatically permissible.

Who pays recall costs? This depends on cause, contracts and responsibility. Public-law measures may be required before internal allocation of costs has been resolved.

Legal sources and further information

Regulation (EC) No 767/2009: labelling and marketing · Regulation (EC) No 183/2005: feed hygiene · Regulation (EC) No 178/2002: safety and traceability · Section 20 LFGB: disease-related advertising

Animal feed law · Veterinary medicine and medicinal products · Veterinary technical products

Discuss your matter with us

We advise throughout Germany and assist with cross-border matters. Please identify the product, parties, target markets and deadlines. Before accepting instructions we clarify conflicts of interest, scope and fees.

Request advice · 0511 35 73 56-0

As at 7 November 2026. This overview describes typical assessment questions; classification depends on the specific product and procedure.

In depth: product status, supply chains and marketing

Legal assessment starts with composition, intended use, mode of action and advertising claims. The supplier’s chosen name does not alone determine product status. Only then can manufacturing, marketability, labelling and distribution requirements be identified. For different species or markets, a single approach may not suffice. A certificate does not automatically answer every marketing question or release all supply-chain participants from responsibility.

Identifying and addressing disputes early

Manufacturers, importers, distributors and users may have different obligations. Supply contracts should clearly allocate specifications, changes, testing records, complaints and recall costs. When a complaint arises, affected batches or devices are identified and evidence preserved. Regulatory notification, a sales suspension or recall depends on the risk and applicable product rules. Contractual arrangements do not replace public-law duties.

Four practical examples

The following scenarios are illustrative, not accounts of actual instructions or promised outcomes. Legal assessment depends on the facts that can be established.

1. Contaminated feed batch

Several farms report illness after the same delivery. Retained samples, batch numbers and feeding logs are secured. Risk assessment, supply-chain communication and possible regulatory duties run in parallel; timing alone does not prove causation.

2. Complementary feed with therapeutic claims

An online shop advertises treatment of a disease. Product status and individual claims are examined separately. Even lawfully manufactured feed can be advertised in breach of unfair competition law.

3. Own-brand retail products

A distributor commissions pet food under its own brand. The contract should allocate specifications, labelling, change approval and recall costs. The distributor may nevertheless retain regulatory duties that cannot all be transferred to the manufacturer.

4. Incorrect feed storage

A supplier attributes a complaint to damp storage. Transport condition, packaging, handover and storage must be evidenced. Establishing when damage arose is necessary to assess defect claims and counterclaims.

Documents, evidence and next steps

Labels, instructions, advertisements, specifications, test reports and supply-chain records are particularly useful. Where health damage occurs, samples, treatment histories and alternative causes should be documented. Regulatory measures, unfair competition claims and civil damages are assessed separately, with coordinated communication. A commercially sensible response may combine replacement, revised advertising, technical improvements and clear customer information.

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