Feed Ingredient Catalog Compliance: Pet Food OEM Formula Review Checklist

# Feed Ingredient Catalog Compliance: Pet Food OEM Formula Review Checklist

MOARA (Ministry of Agriculture and Rural Affairs) issued Announcement No. 1028, completing a new revision of the Feed Ingredient Catalog: 260+ feed ingredients were added, adjusted, or removed, bringing the catalog above 600 entries. This revision updates upstream ingredient entry standards and clarifies compliance boundaries for pet food formulas, with more detailed requirements for end-product labeling. For brands and factories running domestic pet food contract manufacturing, formula review starts with the catalog check.

What the Feed Ingredient Catalog Governs

The catalog is the baseline ingredient list for feed and pet food in China:

• Only cataloged ingredients may be used as feed/pet food ingredients;
• Each entry defines the ingredient name, description, and permitted scope;
• Substances not listed cannot be added as regular ingredients in pet food formulas.

Note: pet food is also governed by labeling regulations, the additive catalog, and pet feed hygiene rules; the ingredient catalog is one link in the compliance chain.

What Changed in This Revision

1. New Ingredients

The catalog adds novel ingredients, expanding formula options. New ingredients passed safety assessment, but brands must still verify whether the permitted animal scope includes dogs and cats.

2. Adjusted Ingredients

Some entries' definitions, processing requirements, or limit descriptions were adjusted. Products still using old descriptions must be rechecked against new entries.

3. Removed Ingredients

Some ingredients were removed from the catalog. Existing formulas still using removed ingredients need replacement before formula changes are filed.

4. Refined Labeling Requirements

Ingredient lists on end packaging must match catalog standard names; generic or self-created ingredient names carry labeling compliance risk.

OEM Formula Compliance Checklist

1. Check Every Ingredient Against the Catalog

Go through each formula item against the current catalog:

• Is it listed?
• Does the entry cover the processed form (meal, oil, hydrolyzed, etc.)?
• Does the permitted scope include dog and cat food?

2. Verify Additives Separately

Nutritional and non-nutritional additives follow the Feed Additive Catalog and use regulations, not the ingredient catalog. Vitamins, minerals, preservatives, and antioxidants need separate confirmation of permitted varieties and limits.

3. Label Ingredient List Consistency

• Ingredients listed in descending inclusion order;
• Names use catalog standard names, not marketing self-created names;
• Claims such as "fresh meat," "freeze-dried," "grain-free" need formula and test evidence;
• Guaranteed analysis (crude protein, fat, fiber, ash, moisture) matches test reports.

4. Risk Ingredient Screening

• Meat source and species match the catalog entry;
• By-product descriptions are accurate;
• GMO and allergens (grains, eggs, dairy, etc.) declared per labeling rules.

5. Record Keeping

• Formula, supplier qualifications, and test reports archived;
• Catalog entry evidence retained for any novel ingredient;
• Active formulas reviewed periodically after catalog updates.

Three Common Compliance Misconceptions

1: If a human food ingredient works in human food, it works in pet food

Human food and pet food ingredient catalogs are not the same. Substances common in human food but absent from the feed ingredient catalog cannot be written into pet food formulas.

2: As long as the ingredient list sounds good, labeling passes

The list must use standard catalog names; marketing names cannot replace catalog names. Self-created ingredient naming is a label audit risk.

3: Catalog updates don't affect products already on sale

After removal or adjustment entries, active formulas need periodic rechecking. Continuing to use a removed ingredient is a formula compliance risk.

Compliance Division in Contract Manufacturing

| Stage | Brand | Co-packer |

|---|---|---|

| Formula concept and positioning | Lead | Feasibility input |

| Ingredient catalog compliance check | Oversee and confirm | Item-by-item check and opinion |

| Supplier qualifications | Provide | Review and archive |

| Label ingredient list | Provide brand copy | Compliance review and layout |

| Testing and retention samples | Participate in acceptance | Execute testing and archiving |

Brands should not hand all compliance review to the factory; factories know catalog rules best, but the brand must confirm label claims match the actual formula.

Bottom Line

After the Feed Ingredient Catalog revision, the first gate in pet food formula compliance is item-by-item ingredient verification. New brands that set up the catalog review process early pay far less than fixing problems after launch. Formula positioning, ingredient selection, and labeling must all leave records to support long-term domestic sales.

For brands needing formula compliance review or novel ingredient replacement, **Mixiaoqi pet food OEM/ODM** in Guangzhou's R&D team can review formulas item by item against the current catalog and adjust ingredient list labeling, building a compliant foundation from the sampling stage.

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FAQ

**Q: Can ingredients not in the Feed Ingredient Catalog never be used?**

A: Regular pet food formulas must use cataloged ingredients; novel ingredients follow MOARA announcements and approval requirements and cannot be self-added.

**Q: Are additives checked in the ingredient catalog?**

A: No. Additives are checked against the feed additive catalog and use regulations for permitted varieties and limits.

**Q: Do active products need re-review after catalog updates?**

A: Periodic rechecking is required, especially removed or adjusted entries; formulas still using removed ingredients should be replaced promptly.