2026 practice series · Editorial allocation: 1/2026. Added retrospectively on 13 November 2026; legal review date: 13 November 2026. The archive month does not represent an original publication on that date.
A product is presented by more than its formulation. Its name, images, instructions and online claims create a combined impression. Manufacturers and private-label businesses therefore benefit from a coordinated approval process: review each new pack and material advertising change against the specification and supporting evidence.
Questions to resolve in practice
Provide actual artwork, all language versions and the live shop copy. Identify who implements changes on marketplaces and distributors’ sites. Record the scope of approval so a later new claim is not mistakenly treated as already reviewed.
Legal assessment and practical approach
Assess formulation, labelling and the operator’s role together. The intended use, target species and all packaging and online claims matter. Supply contracts should allocate testing, change approval and complaint handling in a way that matches the actual supply chain.
Four practical examples
These are hypothetical scenarios illustrating issues to assess. They do not describe actual client matters or promise a particular outcome.
Practical example 1
A supplement is advertised as “curing arthritis”. Classification and the claim need review before sale; a general disclaimer does not correct a specific treatment claim. Review packaging, the online shop and distributor copy together.
Practical example 2
After several animals become ill, a manufacturer holds a batch. Retained samples, delivery records and clinical findings help investigate the cause. Safety action and possible authority notification need attention separately from subsequent recovery claims.
Practical example 3
A private-label supplier changes an ingredient source. Check whether specifications and supporting evidence remain valid and who approves changes. The contract should prevent the brand learning about the change only through a customer complaint.
Practical example 4
An overseas seller markets pet food in Germany through a marketplace. The responsible operator, mandatory information and language must fit the destination market. A compliant label does not cure inconsistent online product information.
Prepare the relevant evidence
Provide complete documents and a concise chronology. Distinguish your observations from statements by others and unresolved questions. Include attachments, evidence of service and deadlines with official notices and correspondence. Preserve original files, images and message histories unchanged; an organised working copy assists review.
Legal sources: EU feed marketing