International Regulatory Divergence: Exports at Risk

Global pet food exporters are navigating a complex and quickly changing regulatory landscape, where increasing fragmentation across international markets makes it harder to use a one-size-fits-all compliance approach. In addition, these regulations are not static and are continually updated to reflect changes in ingredient supply, market conditions, political pressures, and animal disease outbreaks. US brands, once confident that meeting domestic standards such as those set by AAFCO or the FDA Center for Veterinary Medicine would suffice, are now discovering that these standards no longer ensure access to profitable overseas markets.  

Countries like China now require formal registration of foreign pet food manufacturing facilities through the GACC (General Administration of Customs of the People’s Republic of China) Decree 248, which demands comprehensive documentation, hazard analyses, and proof of sanitary standard equivalence. This bureaucratic requirement can delay market entry by six to 12 months and creates an increasing burden of paperwork, money, and time, especially for small and mid-sized exporters.  

Meanwhile, the European Union (EU) continues to tighten controls over new proteins and animal-derived ingredients, enforcing a strict pre-approval process even for substances that are widely accepted and safely used in the US. Under EU Regulation 142/2011, pet food containing animal byproducts must be heat-treated to a minimum of 90°C (194°F) throughout or use ingredients that have been treated accordingly. For companies using emerging ingredients, such as insect proteins or regionally sourced meat by-products, the EU’s cautious stance can significantly limit innovation and market flexibility. These standards are a critical flashpoint in this growing divergence, and the expectations of other countries trump those of the EU. 

Australia and New Zealand, governed by the Australian Department of Agriculture guidelines and MPI (Ministry for Primary Industries) standards, enforce some of the world's strictest biosecurity protocols. Their systems require not only detailed documentation of ingredient origins and processing methods, but also complete traceability throughout the supply chain. These standards often go beyond those in the United States. The thermal processing requirements of pet food are not publicly available documents due to the need for a complete assessment. However, one standard processing expectation that brands encounter is that non-retorted pet foods must undergo a heat treatment of 100°C (212°F) for a full 30 minutes, and this must be documented in the APHIS Form 16-4  and related USDA export health certificate guidance. This requirement must be explicitly noted on health certificates, which are scrutinized at ports of entry. These standards stem not only from food safety concerns but also from efforts to control the transmission of potential zoonotic diseases, which is an increasingly prioritized area in global regulatory circles. 

For many US-based processors, meeting these foreign standards presents significant technical and financial challenges. Traditional American processing methods, such as baking, smoking, or dehydration, focus on reducing water activity (aw) while maintaining sustained core heat, making them unsuitable for compliance with EU or Australian heat-treatment requirements.  

Consequently, many manufacturers must invest in new equipment, reformulate their products to withstand higher temperatures, and conduct costly validation studies. Besides the initial capital costs, these adjustments can impact product texture, shelf life, and consumer appeal, especially in premium markets where quality is closely tied to brand identity. 

The commercial risks are equally steep. Companies that fail to meet these stringent foreign requirements may lose access to high-margin export destinations, such as the EU and Australia. Even when products meet technical specifications, shipment delays or rejections due to minor certificate phrasing errors can result in financial losses and damage to the brand's reputation. Many exporters are adopting dual-spec production models, developing separate SKUs and documentation workflows for both domestic and international markets. However, this strategy increases operational complexity, traceability burdens, and the cost of goods sold, further pressuring already tight margins. 

Looking ahead, the trend of regulatory divergence shows no signs of reversing. In fact, other major markets, such as South Korea, Canada (CFIA) , and GCC nations, are signaling an intent to adopt stricter import controls, with an increased focus on ingredient origin, disease risk mitigation, and antimicrobial resistance. In such a landscape, reactive compliance is no longer sufficient. Exporters must embrace a proactive strategy that includes validating thermal processes in advance, precisely aligning certificate language with the importing country’s expectations, and implementing digital monitoring and traceability systems capable of meeting diverse regulatory frameworks. 

This is where companies like BSM Partners deliver vital strategic value. With extensive expertise in markets like the US, EU, China, Australia, and New Zealand, we assist exporters in decoding complex regulations, redesigning processes to meet international standards, and reviewing documentation with meticulous attention to detail.  

In a world where regulatory compliance can determine the success or failure of global expansion, the question is no longer if you should invest in these systems, but when and with whom. Pet food brands that see compliance as a competitive advantage rather than a cost center will be better positioned for resilient, long-term growth in a fragmented regulatory world. 

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About the Author

Dr. Emily Taylor is Manager of BSM Assurance, BSM Partners' Food Safety, Quality Assurance, and Regulatory Services team. Dr. Taylor is a nutritionist with over 14 years in the animal industry. She resides in Lafayette, Indiana, with her family, showing dressage horses.