Using animal by-products to make pet food

Animal by-products (ABPs) you can use to make pet food, how to provide samples, and how to package your products.

Applies to England, Scotland and Wales

You need approval from the Animal and Plant Health Agency (APHA) to process animal by-products (ABPs) into pet food.

Complete form ABPR4 to get approval to operate.

In addition to APHA approval, you may also need to be approved or registered by your Local Authority (usually the trading standards service) as a feed business.

You can’t start production until you have received approval or registration by both APHA and local authority.

Getting ABPs to your site and storing them

You must only use suppliers and transporters that are approved or registered by APHA.

Find out how to register to transport ABPs and how you must store ABPs.

ABPs you can’t use

There are 3 different categories of ABPs.

Find out about different ABP categories.

You must not make pet food using:

  • category 1 or 2 ABPs
  • catering waste
  • fat from animals that passed inspection for diseases before death but failed inspection after death

ABPs you can use

You can use different ABPs depending on what type of pet food you are making.

To make raw pet food

You can only use:

  • slaughterhouse material that was passed fit for humans to eat but is unwanted for commercial reasons
  • fish by-products from factories and ships that prepare fish for human consumption
  • game that was passed fit for humans to eat but rejected for commercial reasons, not due to disease
  • material from animals that passed an ante-mortem test, that is unfit for humans to eat, for example liver with fluke

To make processed pet food

To make any processed pet food, in airtight containers or wrappers or otherwise, the ABPs you can use are:

  • category 3 ABPs from carcasses passed fit for human consumption
  • slaughterhouse by-products, like hides, skins, horns, feet, pig bristle, feather or blood
  • heads of poultry
  • milk production by-products
  • materials from on-farm slaughter of rabbits or poultry
  • hatchery waste, eggs, egg by-products and day-old chicks
  • fish and by-products from fish processing factories
  • food production by-products including degreased bones
  • products of animal origin (POA) or processed animal protein (PAP) no longer intended for human consumption
  • imported pet food
  • ABPs from aquatic animals from factories that make food for humans
  • factory-rejected pet foods of animal origin, containing ABPs or derived products
  • shells from shellfish with soft tissue or flesh
  • sea or land invertebrates (spineless animals, eg insects) once they don’t carry diseases that can be passed on to humans or animals
  • rodents and lagomorphs (rabbits) unless they are from zoos, experimental animals, or diseased wild animals
  • blood, placenta, wool, feathers, hair, horns, hoof cuts and raw milk from live animals
  • aquatic animals, and parts of such animals, except sea mammals

Heat treating processed pet food for non-airtight containers

If you are making processed pet food, other than dog chews, which won’t be sealed in an airtight container, you must treat ingredients derived from animal by-products, or the final product, at 90°C.

If you meet this heat treatment condition, you can use the following ABPs:

  • milk and milk-based products
  • gelatine
  • hydrolysed protein
  • egg products
  • collagen
  • blood products from disease-free animals that were passed fit for humans to eat before slaughter
  • PAP, including fishmeal
  • rendered fat, fish oils
  • dicalcium phosphate
  • tricalcium phosphate
  • flavouring innards / digests

You can also make processed pet food by drying or fermentation provided your method poses no risk to public or animal health.

Talk to your local APHA office if you want to check that your own method is legal.

Processed animal protein (PAP)

PAP is made from Category 3 material, which has been treated to make it safe to use as animal feed.

PAP use is controlled by TSE (transmissible spongiform encephalopathy) regulations.

If you’re using PAP or blood products from ruminants (animals that chew cud) to make pet food:

  • you must not make livestock feed on the same site
  • the pet foods must be kept separate from livestock feed during storage, transport, and packaging

Making dog chews

If you’re making dog chews, you must:

  • prove in sampling tests that your treatment destroys diseases like salmonella
  • prevent contamination after treatment by separating the final product from raw material

Testing samples for bacteria

You must send samples of your pet food product to an accredited laboratory, where they’ll be tested for bacteria.

Find out how to take samples from ABPs and find a laboratory.

You must take samples from:

  • raw pet food
  • dog chews
  • digests
  • any processed pet food that isn’t canned

You must send samples to be tested for:

  • enterobacteriaceae
  • salmonella

How many samples to take

Take a separate sample for salmonella and enterobacteriaceae from each of your product lines. You must have a different product line for:

  • each species of meat or offal that you process
  • each species of tripe that you process

Each sample should be made up of 10 sub-samples of 30 grams taken randomly from the product line.

The frequency of sampling will depend on several factors specific to each pet food facility. The APHA will discuss this with you individually.

Packaging pet food

You must package pet food in different ways depending on what type it is.

Raw pet food

Raw pet food must be packaged in clean leak-proof packaging.

Canned pet food

You must sterilise pet food at a minimum Fc value of 3 before you can it.

Find out more about Fc value by contacting the APHA.

Dog chews

Dog chews must be packed in unused packaging.

Digests and flavoured innards

Digests and flavoured innards must be packed in new or sterile packaging, or containers that have been cleaned and disinfected.

Dealing with raw pet food

Raw meat can be contaminated with harmful bacteria such as salmonella, campylobacter, listeria and Escherichia coli.

Producing raw pet food does not include a process for killing bacteria. These bacteria can cause serious illness in people and pets.

To prevent this, you must take the following precautions.

Use high quality raw material

You should always use high quality material in raw pet food.

Using materials for human consumption does not guarantee high quality. To choose high quality material, you can practise ‘safe sourcing’. This means you should:

  • choose material that does not present unacceptable risks to people or animals
  • transport ABPs safely to minimise risk to people or animals
  • develop a good relationship with your supplier to build a shared understanding of product requirements
  • audit your supplier regularly to make sure they continue to supply high quality raw material

Test samples for bacteria

You must test samples for salmonella and enterobacteriaceae. Follow guidance on testing samples for bacteria.

You can also carry out tests for other bacteria, such as listeria. Listeria can continue to grow at refrigeration temperatures and has a low infective dose for pregnant animals and women, and elderly people.

Transport and store raw pet food safely

Make sure your approved, registered ABP transporters meet the vehicle hygiene and storage requirements and label containers and vehicles clearly

You should check material has been stored appropriately. Follow the ABP hygiene on your site guidance.

Tell suppliers and distributors the correct storage temperature for your finished pet food product.

Prevent infection when handling raw pet food

Give guidance on safe handling, storage and use of raw pet food to everyone who handles raw pet food, including your customers. You can do this by publishing guidance on your website or on your packaging.

See the raw pet foods: handling and preventing infection guidance.

Published 5 September 2014
Last updated 11 September 2019 + show all updates
  1. Added new section on raw pet food.

  2. Content updated to confirm that in addition to APHA approval, you may also need to be approved or registered by your Local Authority.

  3. AHVLA documents have been re-assigned to the new Animal and Plant Health Agency (APHA).

  4. AHVLA documents have been re-assigned to the new Animal and Plant Health Agency (APHA).

  5. First published.