What is a Seller of Record in Europe?

A Seller of Record is responsible for VAT, compliance, invoicing, and consumer obligations for sales within the European Union. EuroSOR acts as the official seller for non-EU brands so they can enter Europe without forming a local company.

Do I need a European company to start selling in the EU?

No. A non-EU brand can operate in the EU without opening a BV or GmbH by using a compliant Seller of Record model. EuroSOR provides the regulatory layer while the brand continues to own the customer and pricing.

How does EuroSOR handle VAT across Europe?

EuroSOR manages VAT registrations, filings, invoice compliance, and audit support. The objective is to give one consistent VAT framework for selling across multiple EU markets.

How does EuroSOR handle VAT deferment for imports into Europe?

EuroSOR uses the Dutch Article 23 VAT deferment scheme. This allows VAT to be postponed at import and settled later through VAT returns instead of paying it at the border.

Can EuroSOR support Importer of Record requirements?

Yes. EuroSOR works with an Importer of Record partner to manage customs clearance, duty calculation, and compliant entry of goods into the EU.

What delivery timelines can brands expect?

From our Netherlands hub, EU deliveries follow standard European timelines through integrated carrier networks, providing fast access to major markets across the EU.

Who controls pricing, brand, and customer experience?

The brand controls pricing, marketing, customer relationships, and product strategy. EuroSOR manages compliance, VAT, import coordination, and fulfilment.

Does EuroSOR support both B2C and B2B shipments?

Yes. EuroSOR supports both direct-to-consumer deliveries and wholesale shipments to retailers or distributors.

How does EuroSOR handle pet food FBO and GPSR RP for a mixed catalogue?

EuroSOR acts as EU FBO for pet food and GPSR RP for accessories under one Seller of Record contract, coordinating IoR, VAT, and EPR registrations within the same structure.

EU Pet Food Regulations for Non-EU Brands: Essential Steps Before Your First EU Sale

EuroSOR · Pet Products Series

EU Pet Food Regulations
for Non-EU Brands: FBO,
Labelling, and What Most Brands Miss

EU pet food regulation is stricter than most non-EU brands expect - because it follows human food law. The Food Business Operator requirement that applies to human food under Regulation (EC) 178/2002 applies identically to pet food. The labelling rules are different, but the FBO obligation, the IoR structure, and the EPR requirements are the same framework.

€25B+

EU pet food market, the second largest in the world after the US

767

Regulation (EC) 767/2009 - the EU's dedicated pet food labelling and marketing law

Separate compliance obligations most non-EU pet brands miss before first sale

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EU entity capital required with a Seller of Record structure

Pet Products EU Pet Food Regulations Seller of Record FBO GPSR EPR

EU pet food regulations non-EU brand compliance starts from the same place as human food: an EU-established Food Business Operator must be appointed, named on the label, and holding product safety documentation before a single unit goes on sale. What changes is the specific labelling regulation - Regulation (EC) 767/2009 - which adds analytical constituent declarations, species-specific requirements, and life stage claims on top of the general food law framework.

The FBO Requirement: How Human Food Law Applies to Pet Food

Under Regulation (EC) 178/2002, pet food is explicitly included in the definition of "food" for regulatory purposes. The FBO framework applies to pet food with the same force as human food. Every pet food product placed on the EU market must have an EU-established FBO named on the label, holding product safety documentation, and legally accountable to food authorities. For non-EU brands, this is not conditional on volume or distribution channel.

Regulation (EC) 178/2002

General Food Law - applies to pet food

FBO appointment and labelling requirement. Traceability obligations. Product withdrawal and recall responsibilities. Notification to food authorities. Applies to all feed for companion animals.

Regulation (EC) 767/2009

Pet Food Marketing - specific requirements

Analytical constituent declarations per product type. Species and life stage labelling. Permitted feed material descriptions. Nutritional claims for pet food. Complete vs complementary feed classification.

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The FBO for pet food carries the same liability as for human foodThe FBO named on a pet food label is legally accountable if the product is found to be unsafe, incorrectly labelled, or in breach of EU feed safety law. This includes responding to national authority queries and cooperating with recalls. An address-only service that cannot produce documentation does not meet this standard.

EU Pet Food Labelling: Analytical Constituents, Species, and Life Stage

EU pet food labelling under Regulation (EC) 767/2009 differs substantially from US, UK, and Australian label formats. For most non-EU brands, existing packaging requires significant rework before it can legally be placed on the EU market.

Label Element	EU Requirement	Typical Non-EU Gap
FBO address	EU-established FBO name and full address on all packaging	No EU address on existing label
Analytical constituents	Mandatory declaration of crude protein, crude fat, crude ash, and crude fibre as percentage of product weight. Moisture if above 14%.	US "Guaranteed Analysis" format differs in structure and terminology; direct conversion not permitted
Feed materials list	Ingredients listed using EU-approved feed material names from Reg (EU) 68/2013 catalogue, descending order by weight.	Marketing ingredient names ("real chicken") used without EU catalogue designation
Complete vs complementary	Product must be classified as "complete pet food" or "complementary pet food." Classification must appear on label.	"Complete and balanced" AAFCO statement is not the EU equivalent
Species and life stage	Species must be stated. Life stage claims must be substantiated by nutritional profile meeting EU guidelines.	US AAFCO life stage statements do not map directly to EU nutritional guidelines
Language	Mandatory fields in the official language of each country of sale	English-only for DE, FR, IT, ES markets

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Raw and freeze-dried pet food: additional requirementsRaw and minimally processed pet food is subject to Regulation (EC) 1069/2009 (animal by-products) alongside the general pet food rules. Products containing raw meat or bone from specific animal species must meet EU origin and processing requirements. This applies in addition to FBO, labelling, and EPR obligations.

Permitted Ingredients and the EU Feed Materials Register

Ingredients used in EU pet food must appear in the EU catalogue of feed materials established by Regulation (EU) 68/2013. An ingredient used in a US formulation that does not appear in the catalogue, or that is listed with conditions that differ from how it is used in the product, creates a compliance barrier before market entry. AAFCO ingredient definitions do not translate directly to EU catalogue names. Feed additives (preservatives, vitamins, trace elements added for nutritional purposes) are governed by Regulation (EC) 1831/2003 and must be individually authorised.

Verify every ingredient against the EU feed materials catalogue (Reg (EU) 68/2013) before label work begins
Ensure the ingredient name used on the EU label matches the catalogue designation, not the marketing name
Review novel functional ingredients (probiotics, specific botanical extracts, algae-based proteins) against current EU authorisation status
For raw meat ingredients, confirm species eligibility and origin documentation requirements under Reg (EC) 1069/2009
Check that feed additives are individually authorised under Reg (EC) 1831/2003

Pet Accessories and GPSR

Since 13 December 2024, Regulation (EU) 2023/988 requires every non-EU brand placing consumer products on the EU market to appoint an EU-established Responsible Person with their contact details on the product or packaging. Pet accessories - collars, leads, toys, beds, grooming tools, and electronic accessories - fall within GPSR's scope. For brands with a mixed catalogue, the same EU entity acting as FBO for pet food products can hold the GPSR RP role for accessories, provided both roles are explicitly accepted.

Physical Accessories

Collars, toys, beds, grooming gear

GPSR Responsible Person on product or label. Packaging EPR per country of sale. REACH compliance for rubber, plastic, and treated materials. No CE marking unless the product includes electrical components.

Electronic Accessories

GPS trackers, smart feeders, monitors

GPSR Responsible Person required. CE marking under applicable directives (RED for wireless, LVD if powered). Technical file held by EU Authorised Representative. WEEE producer registration per country of sale.

Compliance Checklist Before Stock Enters the EU

Requirement	What It Involves	Timing
Ingredient and feed material review	Check all ingredients against the EU feed materials catalogue (Reg (EU) 68/2013) and feed additives register (Reg (EC) 1831/2003). Any ingredient not in the catalogue requires resolution before label work can proceed.	First
FBO appointment	EU-established entity under Reg (EC) 178/2002 and Reg (EC) 767/2009. Name and address on all labels. Holds product safety and traceability documentation. Required for Amazon EU pet food category listings.	Before first sale
EU label rework	Full label redesign to meet Regulation (EC) 767/2009: analytical constituent declarations in EU format, EU feed material names, complete/complementary classification, species and life stage, local language translations, metric units, and FBO address.	Before label print
GPSR Responsible Person	EU-established RP mandatory since December 2024 for non-food products in the range. Can be the same entity as the FBO if both roles are explicitly accepted.	Before first sale
Importer of Record	EU entity with EORI and VAT registration to file customs declarations and pay import duties at EU entry.	Before first inbound
EU VAT registration	Storing inventory in the EU creates a VAT obligation. Fiscal representative required for non-EU companies.	Before stock ships
EPR - packaging	Registration with national packaging EPR scheme per country. Pet food packaging (pouches, cans, bags, cartons) often spans multiple material categories. No minimum volume exemption.	Before first sale

Feed materials review must precede label rework. FBO, GPSR RP, IoR, VAT, and EPR can run concurrently once Step 1 is clear.

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Amazon EU pet food listings require FBO details before creationAmazon EU's pet food and pet nutrition categories require the EU-established FBO name and address at listing setup. The physical label on FBA stock must carry the FBO address before inventory is accepted at the fulfilment centre. This applies to all pet food categories including dry, wet, raw, and freeze-dried products.

How EuroSOR Handles This

A US premium dog food brand entering Germany, France, and the Netherlands needs an EU FBO on the label with product safety documentation, label rework to Regulation 767/2009 format in three languages, a GPSR RP for any accessories, an IoR at Rotterdam, VAT registration in at least two jurisdictions, and packaging EPR in three countries. Running these as separate providers means no single entity accountable when a food authority requests traceability records or Amazon suppresses a listing for a missing EPR number.

EuroSOR acts as the EU FBO on your pet food labels, holds your product safety documentation, serves as GPSR Responsible Person for accessories, acts as Importer of Record, and handles VAT and EPR registrations. One contract covers both sides of the catalogue.

One EuroSOR contract covers pet food FBO, GPSR RP for accessories, IoR, VAT, EPR, and Amazon EU marketplace compliance.

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In practice: a US premium dog food brand, three marketsFive food SKUs and a range of accessories across Germany, France, and the Netherlands means FBO label registration, Regulation 767/2009 label rework in three languages, GPSR RP on all accessories, EPR in three countries, an IoR via Rotterdam, and VAT in two jurisdictions. EuroSOR coordinates the full stack under one contract.

Book an intro call with EuroSOR →

Frequently Asked Questions

Do EU pet food regulations require an FBO the same way human food does?

Yes. Under Regulation (EC) 178/2002, pet food is included in the definition of food for regulatory purposes. Every pet food product placed on the EU market must have an EU-established FBO named on the label, holding product safety documentation, and accountable to food authorities. Non-EU brands must appoint an EU-established FBO before any product goes on sale.

What labelling does EU Regulation 767/2009 require that US labels do not have?

Analytical constituent declarations in EU format (crude protein, crude fat, crude ash, crude fibre as percentage), ingredient names using EU feed materials catalogue designations, a complete or complementary classification, species and life stage declarations, mandatory fields in the local language, and metric net quantity. The US Guaranteed Analysis format and AAFCO ingredient definitions do not satisfy these requirements.

Do pet accessories require a GPSR Responsible Person?

Yes. Regulation (EU) 2023/988 applies to all consumer products including pet accessories. The RP's name and contact details must appear on the product or packaging. The same EU entity acting as FBO for pet food can hold the GPSR RP role for accessories if both roles are explicitly accepted.

Are there special requirements for raw or freeze-dried pet food?

Yes. Raw and minimally processed pet food containing raw meat or bone is subject to Regulation (EC) 1069/2009 (animal by-products) alongside the general pet food rules. Products must meet EU origin and processing requirements. These apply in addition to FBO, labelling, and EPR obligations.

Can I sell pet food on Amazon EU without a European company?

Yes. You need an EU-established FBO, EU-compliant packaging under Regulation 767/2009, an Importer of Record, EPR registration numbers per Amazon EU marketplace, and a GPSR RP for any accessories, but not your own EU legal entity. EuroSOR's Seller of Record structure covers all of these under one arrangement.

How does EuroSOR handle both pet food FBO and GPSR RP for a mixed catalogue?

EuroSOR acts as EU FBO for pet food products and GPSR Responsible Person for accessories under one Seller of Record contract. IoR, VAT, and EPR registrations per country are coordinated within the same structure - one contract replacing separate FBO, customs, VAT, and EPR provider relationships.

This page is updated periodically. Nothing here constitutes legal, regulatory, or tax advice. Verify all requirements with a qualified EU adviser before acting.

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EU Pet Food Regulationsfor Non-EU Brands: FBO,Labelling, and What Most Brands Miss