This article has not yet been professionally approved. The information is based on the sources listed below.
Feed or medicine?
The line between complementary feed and veterinary medicine is sharply drawn in law. Why healing claims are not permitted – illustrated by a court ruling.
Products for oral administration to horses are subject to strict rules in the EU. The basis is Regulation (EC) No 767/2009, supplemented by Regulation (EC) No 1831/2003 on additives 12.
When a product becomes a medicine
As soon as a product has a demonstrable pharmacological, immunological or metabolic effect that goes beyond pure nutrient supply, it is legally considered a veterinary medicinal product – subject to authorisation and pharmacy-only supply 1.
This is why feed must not carry disease-related claims to heal or relieve. Such “borderline products” are a common reason for objections from the authorities.
- No statements such as “heals”, “against EMS”, “relieves osteoarthritis”.
- In online retail, analytical constituents and additives must be visible before purchase 1.
- Complementary feed only covers requirements together with the basic ration.
An example from case law
How strictly the production chain is regulated is shown by a ruling of the Bavarian Higher Administrative Court (2022): using zinc oxide as an example, it confirmed the “premix requirement” – sensitive additives may not be mixed in in pure form but must be processed via certified premixtures 3.
Sources & studies
The content is based on the references listed below. It does not replace individual veterinary or feeding advice.
Show list of sources (4)
- Verordnung (EG) Nr. 767/2009Placing on the market and use of feed, labelling and claims; definitions of complete feed (Art. 3(2)(i)) and complementary feed (point (j)), content of feed additives (Art. 8), feeding instructions (Annex II No. 4). Link to the current EUR-Lex consolidated version (as of 26 December 2018).
- Verordnung (EG) Nr. 1831/2003Feed additives – authorisation and use; “daily ration” based on 12% moisture (Art. 2(2)(f)), renewal of authorisation and automatic continuation (Art. 14(4)), general conditions of use (Annex IV: natural plus added amount; complementary feed, diluted as specified, at most at the level for complete feed). Link to the current EUR-Lex consolidated version (as of 27 March 2021).
- Bayerischer Verwaltungsgerichtshof (2022): Zinkoxid und VormischzwangConfirms the premixture requirement under Implementing Regulation (EU) 2016/1095: sensitive additives only via certified premixtures
- Deutscher Verband Tiernahrung e.V.Guidance on feed law and industry practice