To get access to the PAW platform or create an account or access please contact rc@petfoodcompliance.com.
When headlines broke last year about H5N1 avian flu being detected in raw cat food in San Francisco, the story spread as quickly as the virus itself. Shelves were cleared, worried pet parents flooded Facebook groups, and regulators stepped in. For many in the industry, it was a jarring reminder: one contaminated shipment can set off alarms not just in your own backyard, but across borders.
Here’s what’s interesting: if that same product had been headed for the UK or EU, the response would have looked completely different. In the U.S., recalls and FDA/FSVP enforcement are the main tools.
In Europe, the conversation would have started much earlier. In fact, it would have started at the border. Importers there must file pre-notifications in TRACES NT or IPAFFS, provide detailed Export Health Certificates, and prove that animal by-products meet strict rules before the food ever hits store shelves.
That contrast—reactive oversight in the U.S. versus preventative control in the UK/EU—says everything about how licensing and compliance differ depending on which side of the Atlantic you’re on.
In the States, licensing often feels like juggling. Every state has its own rules, which means a brand launching nationwide has to navigate dozens of applications, fees, and tonnage reports. On top of that, the FDA expects facilities to be registered, and importers must run a documented Foreign Supplier Verification Program (FSVP).
Think of it as a patchwork quilt: each square (state) has its own pattern, and the FDA stitches them together with broader food safety oversight. Most companies end up tracking multiple state licenses, managing product registrations for each SKU, submitting annual tonnage reports, and making sure their FDA facility registration is up to date. If they import, the FSVP program adds another layer, requiring documentation that proves suppliers are vetted and hazards have been analyzed.
And let’s not forget animal-based ingredients. Chews, treats, or raw formulas can trigger APHIS permits or special declarations. In short, the U.S. system gives you room to get products on shelves quickly but relies heavily on enforcement after the fact—recalls, warning letters, and inspections are the pressure points.
Across the pond, the focus isn’t on state-by-state approvals. Instead, the burden falls on the importer or distributor, and the whole system is designed to catch issues before products reach the consumer.
Before a shipment even leaves port, importers must:
The philosophy is simple: the U.S. says “get licensed and we’ll deal with problems later,” while the UK/EU says “prove safety and traceability before we even let you in.”
The UK/EU Pet Food Regulatory Guide lays out a week-by-week roadmap, and it shows just how front-loaded the process is. Instead of trickling in requirements, most of the heavy lifting happens before your product ever ships. Here’s what a typical first-time exporter timeline looks like:
Week | Action |
1–2 | Appoint a responsible importer or distributor in the UK/EU |
2–3 | Register with the competent authority (APHA in the UK or national feed authority in an EU Member State) |
3–5 | Prepare HACCP documentation, facility registration, and supplier agreements |
4–6 | Submit Export Health Certificate (UK) or CHED-P via TRACES NT (EU) |
5–7 | Develop compliant labeling (multilingual for EU) |
7–9 | Book customs broker and align logistics |
9–10 | First shipments cleared at Border Control Posts |
Costs aren’t negligible either. Facility registration runs around £1,000 in the UK or €1,200 in the EU, and every shipment requires an EHC or CHED-P certificate that costs about £150/€150. Add in translations, certificate preparation, and customs broker fees, and it’s easy to see why brands underestimate the financial and time investment of expanding overseas.
Plenty of U.S. brands have learned the hard way that what worked at home doesn’t always fly in Europe. The most common mistakes include:
Each of these errors has led to shipments being stopped at customs. They’re small details, but they carry big consequences. If you want help with this, we’d love to chat!
Back to that San Francisco story: the contamination triggered recalls and FDA oversight, but not before the product reached consumers. In the UK/EU, the shipment likely wouldn’t have cleared customs without the right paperwork on sourcing, processing, and disease status.
Neither system is perfect, but both highlight what matters most for brands: knowing where you’re selling, who carries the compliance burden, and how risk is managed.
In the U.S., it’s usually the manufacturer or brand owner who holds the responsibility.
In the UK/EU, it’s the importer, but your reputation is still at stake if things go wrong.
So what should a growing brand do? Start by mapping out where you plan to sell. If you’re U.S.-only, get familiar with each state’s licensing requirements, track your renewal dates, and make tonnage reporting part of your rhythm. If you’re importing, don’t just file an FSVP binder and call it good—build a real program that documents supplier audits, hazard analyses, and verification steps.
For the UK and EU, plan ahead for longer lead times. Appoint your importer early, build HACCP and traceability into your production process, and don’t underestimate the time it takes to apply for EHCs or access TRACES NT.
Most importantly, get your labels right before you print thousands of bags. A multilingual, Regulation 767/2009-compliant label is a lot cheaper to produce at the start than to redo after customs seizes your first shipment.
If you want your brand to grow globally, you’ll need to play by both sets of rules. The good news? You don’t have to do it alone. Whether it’s a state regulator in Montana asking for tonnage reports or a customs officer in Rotterdam asking for an EHC you didn’t know you needed, we can help you prepare before those headaches hit.