EU 767/2009

This glossary term is part of the SG Systems Global regulatory & operations guide library.

Updated January 2026 • Regulation (EC) No 767/2009 (Placing Feed on the Market & Use), feed labeling particulars, claims governance, composition declarations, presentation/legibility, prohibited misleading info, batch identification, traceability & rapid withdrawal, complaint handling evidence • EU & UK Feed / Animal Nutrition / Animal Health-adjacent manufacturing (premix, minerals, micro-ingredients, co-packers, private label, distribution)

EU 767/2009 is the European Union’s core framework for placing feed on the market and its use. Operationally, it’s the rule set that turns “we make or sell feed” into “we can prove our feed is labelled correctly, described honestly, and supported by traceable, audit-ready evidence from formulation to shipment.” If you sell compound feed, complementary feed, pet food-style products, premixes, or claims-driven nutrition products, 767/2009 is the regulation that governs how you present the product to the market—what you must declare, what you must not imply, and how fast you must be able to defend or withdraw a batch when something is challenged.

This regulation matters because feed is sold on trust: composition, purpose, and claims drive purchasing decisions. 767/2009 is designed to protect that trust by forcing transparency and preventing misleading information. It ties labeling and marketing directly to manufacturing reality. It is where the “commercial layer” becomes regulated: the label isn’t just packaging artwork; it’s a compliance artifact that must match the controlled formulation, actual ingredient use, and authorized additive conditions. In practice, 767/2009 is why label changes require governance, why claims need evidence, and why complaints can’t be handled casually.

Tell it like it is: most 767/2009 problems aren’t found in legal text—they’re found on the shop floor and in the customer file. Labels drift from recipe versions, “equivalent” ingredients get substituted without updating declarations, additive claims outrun what’s authorized, online listings become a parallel truth, and batch identification isn’t strong enough to support rapid withdrawal. Then a customer questions performance, a regulator samples, or a competitor challenges a claim—and the company can’t produce a clean evidence chain. 767/2009 is where that informal model breaks, because the regulation assumes you can prove the truth of what you sold.

“If your feed labels are ‘mostly right’ and your evidence lives in spreadsheets, EU 767/2009 is where that approach becomes a liability.”

1) What people mean when they cite EU 767/2009

When teams say “we need to comply with 767,” they usually mean one of three operational realities:

• Label and claims risk: the commercial presentation is moving faster than controlled data and batch evidence.
• Private label pressure: customers demand proof that the label matches what was manufactured and shipped.
• Challenge readiness: when a claim or composition is questioned, the business must respond fast and defensibly.

Tell it like it is: 767/2009 is where “marketing language” becomes regulated. If you can’t prove it, you shouldn’t sell it as truth.

2) Scope map: what 767/2009 actually controls

EU 767/2009 is a control map for market-facing truth: what you declare, what you imply, and what you must be able to prove from the factory record.

The practical takeaway: 767/2009 compliance is a systems property. The label is just the visible surface of your data integrity and execution integrity.

3) Placing on the market: responsibility starts at the label

767/2009 is explicit about the responsibility of operators placing feed on the market. In operational terms, this means you own the truth of what you sell and how it is described—whether you manufacture it, co-pack it, import it, or private label it. Responsibility becomes a governance problem across parties: who controls master data, who approves claims, who validates labels, and who proves what shipped.

Tell it like it is: the fastest way to lose trust is to say “the co-packer handled it” when a label is challenged. If your name is on the product, you need evidence that stands on its own.

4) Mandatory label particulars: where “small omissions” become findings

Mandatory particulars are where compliance becomes binary. Missing, inconsistent, or outdated information isn’t “almost compliant.” It’s wrong. The operational challenge is that labels often change for commercial reasons—new market, new customer, new claims, new language—faster than manufacturing systems update.

Controls that reduce label-particular failures include:

• artwork version control with approvals and effective dates,
• print authorization so only approved versions can be produced,
• line clearance + reconciliation to prevent wrong-label carryover,
• version linkage between label, recipe, and batch record.

Tell it like it is: if old labels are physically accessible, they will eventually get used—usually on the most stressful day.

5) Composition declarations: recipe truth vs commercial truth

Composition declarations are where most “silent” compliance drift happens. Substitutions, supplier changes, and rework use can change what the product actually is, without anyone updating the commercial declaration. That creates a gap between recipe truth, execution truth, and market truth.

Tell it like it is: if substitutions are approved informally and never propagate into controlled master data, you are manufacturing label risk at scale.

6) Claims governance: stop selling what you can’t defend

767/2009 is allergic to misleading information. That makes claims governance an operational discipline, not a marketing preference. Claims must be defensible, consistent with composition, and aligned with any additive conditions-of-use where relevant. That means claim approval needs evidence, not enthusiasm.

Tell it like it is: a claim is a promise. If you can’t back it up with controlled formulation and batch evidence, you’re building future disputes into today’s revenue.

7) Additives interface: conditions-of-use must match market claims

Many feed products rely on additives that sit under separate authorization frameworks. Operationally, this means the label and claims can’t imply a use that the additive conditions don’t support. Your formulation controls, label controls, and additive controls must be aligned—otherwise you end up selling a story you’re not allowed to tell.

Tell it like it is: if the sales narrative outruns additive conditions, compliance is already broken even if the batch is perfectly manufactured.

8) Presentation & legibility: compliance isn’t “technically present”

Presentation rules exist for a reason: information must be usable. Designing labels that bury mandatory particulars in tiny text might reduce packaging clutter, but it increases compliance risk and complaint risk. In audits, legibility problems read like intent to obscure, even if that wasn’t the goal.

Tell it like it is: “we included it somewhere” is not the standard. “A customer can read it and understand it” is closer to the intent.

9) Online listings: the parallel-label problem

Modern feed businesses sell through distributors and online catalogs. The failure mode is predictable: the printed label is controlled, but online listings drift and become a second truth. If the online truth diverges from controlled master data, disputes become inevitable.

Tell it like it is: you can’t claim control if the sales channel is unmanaged. Treat online content as controlled output from the same versioned label data.

10) Batch ID discipline: the backbone of withdrawal speed

767/2009 becomes very real when something is challenged. Batch identification must be strong enough to support rapid withdrawal and precise communication. That requires consistent lot coding, scanable identifiers where appropriate, and end-to-end genealogy linking ingredients, processes, packaging, and shipments.

Tell it like it is: “we can probably figure it out” is not a withdrawal plan. A plan is being able to identify impacted customers and stock in minutes.

11) Complaints and challenges: build an evidence-first response

Complaints in feed are often composition and performance disputes. A serious 767/2009 posture means complaints trigger controlled investigations: identify the lot, pull the genealogy, review formulation and execution evidence, and take controlled actions. If you can’t retrieve the evidence quickly, you end up arguing with opinions.

Tell it like it is: in disputes, the business that can produce evidence wins. The business that can’t produces apologies and discounts.

12) Rapid withdrawal readiness: traceability as a safety control

When the market truth is questioned—composition, labeling, contamination, or claims—you need rapid withdrawal capability. That requires “one up / one down” visibility at a minimum and ideally lot genealogy that can be queried instantly. Withdrawal speed is not only regulatory hygiene; it’s commercial survival.

Tell it like it is: recall readiness is the cost of being trusted. If you can’t act fast, customers assume you don’t control your product.

13) Copy/paste EU 767/2009 readiness scorecard

Use this as a practical self-assessment. If you can’t answer these cleanly, your 767/2009 posture is fragile.

The goal isn’t “good labels.” The goal is a system where market truth is a controlled output of execution truth.

14) Selection pitfalls: how 767/2009 compliance gets faked

• Artwork controlled, usage not. Versions exist but old labels still reach the line.
• Claims by enthusiasm. Sales language outruns evidence and conditions-of-use reality.
• Substitution by convenience. Ingredients change without updating declarations.
• Online drift. Catalogs and listings become an unmanaged second truth.
• Lot coding inconsistency. Traceability exists, but only after manual reconstruction.
• Complaint theatre. Complaints are “handled,” but root causes are not evidenced.
• Slow retrieval. Evidence exists but can’t be produced quickly under pressure.

Tell it like it is: these failure modes don’t just trigger findings. They drive customer loss because trust collapses when the story can’t be proven.

15) How this maps to V5 by SG Systems Global

V5 supports EU 767/2009 outcomes by making market-truth controls executable: controlled label versions, controlled formulations, scan-based genealogy, complaint-linked investigations, and rapid retrieval. The advantage isn’t that software “knows the regulation.” The advantage is that software makes it hard to ship unproven truth.

• Platform overview: V5 Solution Overview
• Execution control: Manufacturing Execution System (MES) for recipe execution, substitutions governance, and batch evidence
• Inventory + movements: Warehouse Management System (WMS) for lot/location discipline, picking controls, and shipment traceability
• Quality governance: Quality Management System (QMS) for complaints, deviations, CAPA, and audit-ready closure
• Integration layer: V5 Connect (API) to synchronize ERP, labeling systems, scanners, and external catalogs into one controlled truth

Tell it like it is: 767/2009 compliance collapses when label truth, recipe truth, and shipment truth are separate systems. V5 aligns them so challenges are answered with evidence, not opinions.

16) Where this matters by industry

EU 767/2009 is most visible in feed and nutrition-adjacent operations where the product is sold on declared composition and claims. In Ingredients & Dry Mixes, the risk is version drift: the line runs substitutions and rework under pressure, while label declarations and catalogs lag behind. In broader Food Processing sites that also touch animal nutrition or co-products, the challenge is keeping market truth aligned across multiple streams, multiple labels, and multiple customers.

Where high-volume logistics and private label are involved, withdrawal readiness becomes the real test. In Produce Packing and Sausage & Meat Processing, the operational lesson is the same: if you can’t identify lots fast and prove where they went, you lose control during disputes. That same evidence discipline is what regulated and claims-sensitive markets expect in Dietary Supplements and Pharmaceutical Manufacturing, even when the underlying regulation differs.

If you want the full market map, start here: Industry Solutions. The same “market truth must match execution truth” principle also strengthens labeling and claims governance in Consumer Products and Cosmetics, where customer challenges are common and evidence wins arguments.

17) Extended FAQ

Q1. Is EU 767/2009 mainly a labeling regulation?
It governs placing feed on the market and its use, and labeling is the most visible control surface. Operationally, it forces composition truth, claims governance, batch identification, and rapid withdrawal capability.

Q2. What’s the most common failure pattern?
Version drift: recipe substitutions and changes are not synchronized with label declarations and sales catalogs, so the market truth diverges from the manufacturing truth.

Q3. Why does withdrawal readiness matter even without “recalls”?
Because challenges and complaints still demand fast action. The ability to identify impacted lots and customers quickly is what separates “controlled” from “uncertain.”

Q4. How do we stress-test our 767 system?
Pick a shipped batch and produce the chain: label version, recipe version, actual material lots used, any substitutions, release decision, shipments and customers, and complaint history. If truth requires spreadsheets and guesswork, controls need tightening.

Q5. What’s the fastest way to reduce risk?
Tight version linkage between labels, recipes, and batch records—plus scan-based lot genealogy and controlled print authorization. These controls eliminate most busy-shift and private label failures.

Related Reading
Build market-truth compliance as an execution system: govern labels with Labeling Control and Label Reconciliation, keep disputes survivable with Complaint Handling and End-to-End Lot Genealogy, and support it across V5, MES, WMS, QMS, and V5 Connect.