If you are importing pet food for the first time, the registration maze is usually the least understood part of the project — and the one that causes the most surprises at customs. This article explains the two most common destination markets (United States and European Union), who is responsible for what, and the mistakes we see importers make repeatedly.
A good rule of thumb: the factory holds the export-side registrations; the importer owns destination-market compliance. Both sides failing to understand this boundary is how shipments get held.
United States: FDA facility registration
What must be registered
Under the FDA's food facility registration requirements (rooted in FSMA, with preventive-control rules at 21 CFR Part 507), any facility that manufactures, processes, packs or holds pet food for sale in the US must be registered with the FDA. This applies to the foreign manufacturing facility — not just the US importer. Registration is not a one-time event: it must be renewed every two years, and the renewal period is an official window each even-numbered year.
What the factory needs
- A valid FDA Food Facility Registration number (FFR number), current and renewed on time.
- A DUNS number for the facility (used in FDA's registration and import systems).
- A US agent on record — a person or company in the US who can receive FDA communications.
- Preventive controls in place consistent with 21 CFR Part 507 (a written food safety plan, hazard analysis, etc.).
What the importer must also handle
The registration belongs to the factory, but the import entry is yours. Practical items that stop shipments: accurate product labels consistent with AAFCO model regulations, an FDA Prior Notice filed before arrival, and — increasingly — documentation readiness if your product is selected for examination. Most importers work with a customs broker for entry and a regulatory specialist for label review.
European Union: establishment approval and import checks
Two different EU regimes
Pet food in the EU is regulated partly as feed and partly under animal-by-product rules, so "EU registration" is not a single certificate. The key pieces for imported pet food:
- Establishment approval — the producing factory must be an approved/registered establishment able to supply the correct documentation for feed. Not all third-country factories are; the approval is tied to the specific activity and product category.
- Import documentation — shipments require the documents prescribed for feed imports, including health certificate requirements for products containing animal by-products, and entry through a border control post with the required notifications.
- Operator obligations — the EU importer is the feed business operator and must be registered in their member state, maintain traceability, and notify via the EU's trade control systems where required.
The common trap
EU requirements differ by product type — a freeze-dried treat containing animal protein is not treated identically to a fully plant-based supplement. Importers often discover this only after ordering, when the factory says "we export to the EU" but cannot show which product categories their approval covers. Ask the factory for the exact product scope of their approval, in writing, before you commit.
Who does what — a simple division
| Responsibility | Factory (exporter) | You (importer) |
|---|---|---|
| Facility registration / establishment approval | Holds and maintains it | Verifies it, checks renewal dates |
| Label compliance for destination market | Often assists / reviews | Final responsibility |
| Import entry & customs filing | Provides documents (invoice, COA, health certs) | Files via broker / handles prior notice |
| Batch testing & COA | Provides per-batch | Requests destination-market tests if needed |
| Traceability & recall | Maintains production records | Maintains distribution records |
Five mistakes that stop shipments
- "They have ISO, so the US is fine." ISO 22000 is a management system; FDA registration is a legal requirement. They are different documents.
- Expired registration numbers. The renewal window comes around every two years; an expired FFR number is caught at import.
- Label vs. registration mismatch. The product name and ingredients on the label must match what the facility is registered and approved to produce.
- Assuming the factory handles destination-market compliance. Most factories handle export side; importers must own the destination side. Confirm the split before the PO.
- Only asking "do you export to the US/EU?" Ask: to which markets in the last 12 months, with which product categories, and can you show the documents?
What a compliant supplier looks like
A serious pet food exporter answers registration questions in the first call, sends the registration numbers and renewal dates as a follow-up email the same day, and states plainly which product categories their approvals cover. They also tell you what you still need to do — because they have done this many times and know the boundary between their paperwork and yours. That clarity is worth more than a slightly lower price.