Pet food companies that market their products to China have until March 1, 2020 to fully comply with the new pet food labeling regulations issued by the Ministry of Agriculture and Rural Affairs of the People’s Republic of China (MARA) in April 2018.

Pursuant to the MARA Public Notice [2018] No. 20, labels of domestic and imported pet food must comply with the “Provisions of Pet Food Labels” from September 1, 2019. However, the Ministry offered to extend the deadline after market players raised the possibility of huge business losses if they had to discard their large inventories of old labels for the new ones before the set deadline.

New provisions in place for a smoother transition

To alleviate the industry's concerns, MARA has now put in place Public Notice [2019] No. 210, designed to allow for a smoother transition to China's new labeling provisions with the following provisions:

  1. An additional six months’ transition period for pet food labels has been granted. Domestically produced pet food products and imported pet food products after March 1, 2020, must use labels that comply with the “Provisions of Pet Food Labels.”
  2. Before March 1, 2020, if pet food producers continue using the old labels, they should stick or attach a supplementary label. The supplementary label should mark the following content: common names of the product that comply with the “Provisions of Pet Food Labels,” the guaranteed values of product ingredient analyses that are not provided in the old labels, and the statement that “This product complies with provisions of pet food sanitary requirements.” The supplementary label should be stuck or placed at an obvious spot on the old label. The font size of the product’s common name should not be smaller than that of the common name and product name in the old labels.
  3. Starting on March 1, 2020, the feed regulatory authorities at all levels will, following requirements in the “Provisions of Pet Food Labels,” conduct oversight and law enforcement work on pet food labels to promote the healthy development of the industry.

Aside from Provisions for Labeling of Pet Food, MARA's original notice covered five other regulatory documents concerning pet foods, including the Administrative Measures for Pet Food.