Six things on a South African pet food label that carry a legal meaning, and one that does not mean what most owners think it does.
Almost every guide to reading a pet food label is written for an American or a European reader, and we wanted to change that. South African pet food is regulated differently from both US and European feeds; it is considered a farm feed under an Act passed in 1947, and the labelling rules sit in a single regulation made under it. Several of those rules are far more specific than we expected and one of them is weaker than the imported advice assumes. Here is what actually has legal force on a bag bought in this country.
1. The picture on the front is a claim
Since 2010, images on a pet food label have carried percentage requirements. If the label shows vegetables, fish, milk or eggs, that ingredient must make up at least 4% of the finished product. Cereals or grains pictured, at least 14%. Meat pictured, at least 26% (regulation 22(2)(a)). A graphic or pictorial representation may also not misrepresent the contents of the package.
Most of us read packaging imagery as decoration, but in South Africa it is a claim with a number attached, and it is the easiest thing on the whole bag to check.
DID YOU KNOW?
A picture of meat on the front of the bag legally means at least 26% of that meat is in the food.
2. The wording tells you the percentage
The regulation sets a ladder of meanings for ingredient claims, based on the finished product (regulation 22(2)(i)). Using chicken as the example:
• ‘With chicken flavour’: traces of the flavour substance, or up to and including 4% chicken.
• ‘With chicken’: at least 4%.
• ‘High in chicken’, ‘rich in chicken’ or ‘with extra chicken’: at least 14%.
• ‘Chicken dinner’, ‘chicken recipe’ or ‘chicken menu’: at least 26%.
• ‘All chicken’: at least 65%.
Word order matters too. Where the form of the material follows its name, as in ‘beef cubes’, the inclusion must be at least 26%, but where the form precedes the name, as in ‘cubed beef’, it must be at least 65%.
It is also worth knowing what ‘meat’ may cover. For a meat claim, the material may include all parts of that species except a listed set: added blood, bone and bone meal, bone fractions and contents, meals or greaves from knackers, claws, hair, horns, hide other than pork rind, feathers, teeth, hooves, the content proportion of intestines, and added fat (regulation 22(2)(j)). Organ meat and connective tissue are not on that list.
3. The analysis is an average, not a guarantee
This is the one that catches people out, including people who work in the industry.
Until 2010, South African labels carried a ‘Guaranteed Analysis’, with crude protein and crude fat declared as minimums and fibre, moisture and ash as maximums. An amendment in June 2010 replaced that requirement. Labels must now carry an ‘Average analysis’ or ‘analysis’, listing crude protein, moisture, crude fat or oil, crude fibre and crude ash, with the minimum and maximum designations removed. Calcium and phosphorus are optional (regulation 22(1)(g), substituted by GNR 552 of 2010).
This is a real difference from the American labelling most online advice is based on, where protein is a guaranteed floor; a protein figure on a South African bag is a central value, not a minimum.
However, it does not follow that the number is meaningless, and it would be unfair to suggest so. Registration is granted on condition that a product’s composition does not deviate by more than the allowable deviation under which it was registered (regulation 5(1)), and permitted tolerances are set out separately. The regulation is also internally inconsistent: it retains a definition of ‘guaranteed analysis’ and still uses the word ‘guarantees’ in the subregulation immediately after the one that removed them, but the effect is that the figure printed on the bag is an average, and it should be read as one.
Figures are declared on an as-fed basis, so a wet food and a dry food cannot be compared straight off the tin and the bag. Converting to a dry matter basis first is the only fair way to make a comparison between wet and dry food.
4. ‘Premium’ is a comparison with itself
Claims such as premium, super-premium and high-digestibility must be scientifically substantiated by the manufacturer, but the regulation requires that substantiation to be made against standard or baseline products within the manufacturer’s own product range (regulation 22(2)(s)).
There is no industry benchmark and no external standard. Premium means better than the same company’s cheaper food. Two premium foods from two different manufacturers are not making comparable claims, and comparing them on that word alone tells you nothing.
The same structure applies to calorie terms such as light, less and reduced, and to fat terms such as lean and reduced fat. Both are substantiated against a standard maintenance diet in the applicant’s own range (regulation 22(2)(f) and (g)).
Two terms do have fixed external meanings. ‘Enriched’ requires 25% more, and ‘fortified’ 15% more, than the nutrient requirements laid down in the regulation’s own tables (regulation 22(2)(e)).
5. Calories are optional, unless the bag mentions weight
Energy content statements are permitted on a label only if they are substantiated. But where a label makes any claim referring to weight control or obesity, it must be accompanied by a declaration of the product’s energy content (regulation 22(2)(q)).
Therefore, a food marketed on weight management that gives you no energy figure is not meeting the requirement. For every other food, there is no obligation to declare energy content at all, which is a genuine gap for anyone managing a dog’s weight. The manufacturer has certainly calculated it, because feeding quantities in grams per day must be based on the metabolisable energy content of the diet (regulation 22(1)(c)). It just does not have to appear on the packaging.
Statements of digestibility of nutrients or dry matter content are not permitted on labels at all (regulation 22(2)(r)).
6. The V number, and what does not need one
Every registered pet food must carry its registration number, expressed as ‘Reg. No. V … Act No. 36/1947’, together with the name, company registration number and address of the person in whose favour it is registered. Those details must appear below one another in that sequence (regulation 22(1)).
Not everything in the pet aisle needs one, though. Pet chews, toys and exercisers made of rawhide, wood, man-made material, hooves, ears, bones or ligaments, whether flavour coated or not, are exempt from registration entirely, unless the label claims a nutritional value or benefit such as digestibility or tartar control (regulation 18(1)(a)). Treats and complementary pet foods require no nutritional adequacy validation at all (regulation 18(1)(b)), although those with a nutritional value must still show an analysis and an ingredient statement.
If a chew does carry a plaque, tartar or breath claim, that claim must be substantiated (regulation 22(2)(y)). Claims about cleaning or whitening teeth by abrasive or mechanical action are allowed, but also require substantiation (regulation 22(2)(x)).
The verdict
South African pet food labelling is more informative, and in places stricter, than most of us assume. The picture rules and the ingredient percentage ladder are genuinely useful and genuinely enforceable. The honest problem is not that the label lies, but that there is a gap between what the law requires and what we, as consumers, have been taught to read.
The two real weaknesses we found are the shift from a guaranteed to an average analysis, and the fact that premium and its relatives are defined only against the manufacturer’s own shelf.
Yet, these regulations are taken seriously by the government, and failure to comply with them is a criminal offence.
What to check in the aisle
• Is there a V number and an Act 36 reference? If not, and it is not an exempt chew, it should not be on sale.
• Does it say complete or complementary? Complementary is not a full diet.
• Read the front of the bag as a set of percentages. Flavour means up to 4%. Dinner means at least 26%.
• Check what the pictures commit to, not just the words.
• If it claims weight control, look for an energy figure. It is required.
• Ignore ‘premium’ when comparing across brands. It only ranks a manufacturer against itself.
• Convert to a dry matter basis before comparing a tin with a bag.
The bigger problem
All of the above sits in regulations made under the Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act of 1947. The pet food labelling provisions were last substantively amended in June 2010.
A replacement has been in the works for a long time. The legislative review began in 2008 with the publication of an animal feed policy for South Africa. The resulting Feeds and Pet Food Bill was published for public comment in February 2019, and still carried the short title ‘Feeds and Pet Foods Act, 2018’. Industry consultation was still underway in August 2024 and a further set of proposed amendments to the farm feeds regulations went out for public comment in January 2026.
But, here is the part that matters for anyone hoping the label is about to improve. The Bill as published does not fix anything on the bag. Its entire labelling provision is a single sentence requiring manufacturers to comply with labelling requirements ‘as may be prescribed’, leaving every detail to regulations that have not yet been written (section 23). The Bill would prohibit false or misleading packaging, labelling and advertising, much as the current regulation does but beyond that, it delegates to another section that we don’t have sight of yet.
So even if the Bill were signed tomorrow, nothing about what a South African owner can read on a bag of dog food would change until someone drafts the regulations underneath it. In the meantime, the rules that govern what you are told about your dog’s food are seventy nine years old, and the useful parts of them are sixteen.
References
• Regulations relating to Farm Feeds, Government Notice R.1087, Government Gazette 29332, 3 November 2006, as amended by GNR 552 in Government Gazette 33310, 25 June 2010, corrected by GNR 789 in Government Gazette 33519, 10 September 2010. • Feeds and Pet Food Bill, published for public comment under Notice 70 of 2019, Government Gazette 42230, 15 February 2019. • AFMA White Paper on Feeds and Pet Food Bill Issues, 30 August 2024. • Amended Regulations relating to Farm Feeds: invitation for public comment, Government Notice 6998, Government Gazette 53956, 16 January 2026.
