Selling Homemade Dog Treats — Registration, Labelling, and What Most People Don't Know

Why dog treats are animal feed

This is the bit that catches everyone off guard. Homemade dog biscuits, training treats, and chews are all legally classified as animal feed under UK law. The primary legislation is Regulation (EC) No 183/2005 (feed hygiene), Regulation (EC) No 767/2009 (placing feed on the market), and Regulation (EC) No 1069/2009 (animal by-products). All three are retained in UK law.

This matters because the rules for manufacturing and selling animal feed are different from — and in many ways stricter than — the rules for selling human food at a craft fair. You cannot simply apply what you know about food hygiene ratings or Natasha's Law to dog treats. Different laws, different registrations, different labelling.

Step 1 — Register with Trading Standards

Every person who manufactures pet food or treats for sale must be registered with their local authority Trading Standards office before they start selling. This is mandatory under Regulation (EC) No 183/2005 and applies regardless of scale. There is no exemption for small-batch or hobbyist producers.

To register:

• Contact the Trading Standards service at the local council where your premises (usually your home) is based.
• You can find your local Trading Standards office through the GOV.UK 'Register an animal feed business' service.
• Registration is free in most areas.
• You must register before you sell any pet food or treats — not after.

This registration is separate from food business registration with environmental health. If you also sell human food, you need both registrations. They are different departments covering different legislation.

Step 2 — APHA approval (if using animal-origin ingredients)

This is the step that trips up most people. If your dog treats contain any ingredients of animal origin, you must also obtain approval from the Animal and Plant Health Agency (APHA). This is separate from and additional to your Trading Standards registration.

Ingredients of animal origin include:

• Eggs
• Butter, milk, cheese, yoghurt, or any dairy product
• Meat, fish, or bone broth
• Honey
• Animal fats (including lard and dripping)
• Fish oil

The moment you use any of these ingredients in pet food, they become legally classified as animal by-products, and APHA approval is required to handle them — even if you bought them from a supermarket.

APHA approval requires your premises to meet specific conditions, including strict separation of pet food ingredients from any food intended for human consumption. In a domestic kitchen, this usually means either a dedicated separate space for pet food production, or strict time-based separation — making pet food at completely different times from human food, with full cleaning in between.

There is a statutory fee for APHA approval, and the process can take several weeks. Apply well before you plan to start selling.

For treats that contain no animal-origin ingredients at all — for example, peanut butter and oat biscuits where the peanut butter contains no dairy — APHA approval may not be required. But Trading Standards registration still is. If you are unsure, check with your local Trading Standards office before you start.

Step 3 — Feed safety management (HACCP)

All pet food manufacturers, including home-based producers, must have a feed safety management system based on HACCP (Hazard Analysis and Critical Control Points) principles.

In practice, this means documenting:

• Your production process — what you make, how you make it, and in what order.
• Potential hazards — contamination, incorrect storage temperatures, allergen cross-contact, pest control.
• Controls in place to manage those risks — cleaning schedules, temperature checks, ingredient storage procedures.
• Batch records — what went into each batch, when it was made, and where the ingredients came from.

This applies whether you make ten bags a week or ten thousand. The scale of documentation should be proportionate to your operation, but the requirement itself has no lower threshold.

If you already have a food safety management system for human food production, you will recognise the HACCP framework — but you will need a separate system specifically for your pet food production.

Labelling — completely different from human food

Pet food labelling falls under Regulation (EC) No 767/2009 and is fundamentally different from human food labelling. You cannot simply apply what you know about Natasha's Law or food information regulations to dog treats.

Every package of dog treats must include a statutory statement containing:

• Type of feed — most treats are "complementary feed" (they supplement the dog's main diet, not replace it).
• Species — e.g. "Complementary feed for dogs."
• Instructions for proper use — feeding guidelines such as "Feed 2–3 treats per day as a supplement to a balanced diet. Always ensure fresh water is available."
• Composition — a full ingredients list in descending order by weight.
• Analytical constituents — the percentage of crude protein, crude oils and fats, crude fibre, and crude ash. If moisture exceeds 14%, that must also be declared.
• Net weight.
• Batch number or date of manufacture.
• Best before date or minimum storage life.
• Your name and address as the feed business operator responsible for the labelling.
• Your registration or approval number (from your Trading Standards registration or APHA approval).

The label must be on the packaging before the customer picks it up. You cannot rely on a sign on your table.

Analytical constituents — the bit that confuses everyone

The requirement to declare crude protein, crude oils and fats, crude fibre, and crude ash catches most new pet treat makers off guard. "Crude ash" in particular sounds alarming — it has nothing to do with actual ash in the product. It is a standardised laboratory term for the mineral content remaining after the organic matter is burned away during testing. It is a standard part of animal feed nutritional analysis.

You have two options for determining your analytical constituents:

• Laboratory analysis — send a sample of your finished product to a laboratory for nutritional testing. This typically costs £50–£150 per product and gives you precise, defensible figures.
• Calculation from ingredient data — calculate the values from the known nutritional profiles of your ingredients and the recipe proportions. This is acceptable but requires care, documentation, and reliable source data. Some ingredient suppliers provide nutritional data sheets that can help.

For your first product, laboratory testing is the safest approach. Once you understand the process, calculation becomes more practical for recipe variations.

Claims you cannot make

You cannot make medicinal or health claims on pet food labels unless you have evidence to support them and they comply with the regulations. Statements like "helps with joint pain," "cures anxiety," or "improves digestion" could make your product a veterinary medicine, which requires a completely different — and far more expensive — authorisation.

Claims you can make, if they are truthful and verifiable:

• "Grain-free" — if the product genuinely contains no grain.
• "Natural" — if all ingredients are genuinely natural and minimally processed.
• "Single protein" — if there is only one source of animal protein.

Claims you should avoid unless you have specific evidence:

• Anything suggesting the treat prevents, treats, or cures a health condition.
• "Hypoallergenic" — this is a complex claim that requires evidence.
• "Organic" — unless you are certified organic.

When in doubt, describe what is in the product, not what it does. "Made with peanut butter and oats" is a description. "Calms anxious dogs" is a medicinal claim.

Vegan and plant-based treats — slightly simpler

If your treats contain no ingredients of animal origin whatsoever, APHA approval is not required. This removes one significant step from the process.

You still need:

• Trading Standards registration (mandatory for all pet food).
• A HACCP-based feed safety management system.
• Full compliant labelling including analytical constituents.

However, be cautious about hidden animal-origin ingredients. Butter is dairy. Many peanut butters contain dairy derivatives. Some flours are enriched with animal-derived vitamins. Check every single ingredient — including the ingredients of your ingredients — before assuming your product is free from animal-origin material.

If you are confident your recipe is entirely plant-based, confirm this with your local Trading Standards office. They can advise whether APHA approval applies to your specific products.

Insurance

Your insurance needs to cover pet food production specifically. Standard craft insurance or food vendor insurance may not cover animal feed manufacturing — it is a different category of risk.

When arranging your insurance, make sure you:

• Tell your insurer exactly what you are making and that it is classified as animal feed.
• Check that your product liability cover extends to pet food products.
• Confirm that your public liability cover applies to selling pet treats at events.

If your existing craft insurance does not cover pet food production, you may need to arrange specialist cover or an endorsement to your existing policy.

Practical checklist before your first sale

Before you sell a single dog treat at a craft fair, make sure you have:

• Registered with your local Trading Standards office as an animal feed business.
• Applied for and received APHA approval if your treats contain any animal-origin ingredients.
• Written a HACCP-based feed safety management plan for your production process.
• Had your products' analytical constituents determined (by laboratory testing or documented calculation).
• Designed compliant labels containing all the required statutory information.
• Confirmed your insurance covers pet food production.
• Set up a batch recording system so you can trace every ingredient in every batch.

Contact your local Trading Standards office before you start. This is genuinely one of those areas where getting advice early prevents expensive mistakes later. Trading Standards officers are generally helpful and would rather guide you through the process than find you selling non-compliant products at a fair.