Understanding Act 36 Compliance for Pet Food Brands in South Africa

Launching a pet food or nutraceutical product in South Africa involves far more than formulation and packaging design. One of the most critical, and often misunderstood, parts of the process is compliance under Act 36 of 1947, administered by the Department of Agriculture, Land Reform and Rural Development (DALRRD).

For both local and imported pet food products, compliance is essential before products can legally enter the South African market. Whether you are developing a fresh food range, launching therapeutic support products, importing treats, or manufacturing complete and balanced diets, understanding the regulatory landscape early can save brands substantial time, money, and frustration.

At CNP Pet Nutrition, we regularly assist local and international brands with regulatory strategies, technical dossiers, label reviews, and DALRRD applications. One of the biggest challenges we see is that many companies only begin considering compliance once production or branding has already started - often resulting in delays, redesigns, or reformulations.

This guide explains the fundamentals of Act 36 compliance and what pet brands need to know before launching in South Africa.

What Is Act 36 for Pet Food Compliance?

Act 36 refers to the Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (Act No. 36 of 1947).

In the pet food industry, this legislation governs:

• Pet foods

• Complementary feeds

• Functional treats

• Nutraceuticals

• Supplements

• Imported pet products

• Certain functional additives and health-support products

Products approved under Act 36 receive a registration number commonly referred to as a “V-number.”

This V-number indicates that the product has been reviewed and accepted by DALRRD according to the formulation, dosage levels, intended use, and labelling information submitted within the application.

Which Pet Products Require Registration?

Many brands are surprised to discover that even low-inclusion functional products may require registration.

Products commonly requiring registration include:

• Complete and balanced pet foods

• Complementary pet foods

• Functional treats

• Supplements and nutraceuticals

• Powders and toppers

• Electrolyte products

• Probiotics and digestive aids

• Imported pet foods and treats

• Therapeutic or condition-support products

Even products marketed as “natural” or “holistic” are not exempt from regulatory oversight.

The classification of a product often depends on:

• Intended use

• Ingredient composition

• Functional claims

• Feeding instructions

• Product positioning

This is why strategic regulatory planning during development is so important.

Complete vs Complementary Pet Foods

One of the most important distinctions in Act 36 applications is whether a product is classified as:

Complete & Balanced

These products are intended to provide the total daily nutritional requirements of the animal.

They must meet recognised nutritional standards such as:

• AAFCO

• FEDIAF

• NRC

Complete products generally require:

• Full nutritional substantiation

• Macro and micronutrient validation

• Feeding guides

• Guaranteed analysis declarations

• Detailed formulation reviews

Complementary Products

Complementary products are designed to supplement the existing diet.

Examples include:

• Functional toppers

• Joint support products

• Digestive aids

• Nutraceutical powders

• Supplement sachets

• Functional treats

These products still require careful formulation and compliant claims positioning.

Many brands incorrectly assume complementary products are “easier” to register. In reality, unsupported claims or incorrect classifications can significantly delay approval.

Common Documentation Required

Depending on the product category, DALRRD applications may require:

• Product formulation

• Ingredient specifications

• Technical dossiers

• Nutritional rationale

• Proposed labels and artwork

• Guaranteed analysis

• Feeding guidelines

• Stability information

• Manufacturing details

• Packaging information

• Certificate documentation for imported products

The quality and structure of this documentation play a major role in application success.

Understanding Regulatory Timelines

One of the biggest misconceptions in the industry is the expectation of quick approvals.

Regulatory timelines can vary substantially depending on:

• Departmental workload

• Product category

• Complexity of claims

• Quality of submission documents

• Imported versus local products

• Requested amendments

In many cases, brands should realistically plan for several months when preparing for market launch.

This is why regulatory planning should happen in parallel with:

• Product development

• Manufacturing onboarding

• Packaging design

• Commercial planning

• Retail negotiations

Brands that leave compliance until the end of development often face unnecessary delays.

Common Label Mistakes That Delay Registrations

Labels are one of the most frequent causes of application delays. Common issues seen in Act 36 pet food compliance include:

Unsupported Claims

Claims such as:

• “Treats kidney disease”

• “Prevents arthritis”

• “Clinically cures allergies”

may trigger additional scrutiny or rejection.

Incorrect Ingredient Listings

Ingredients should typically be listed in descending order by weight.

Missing Mandatory Information

Labels may require:

• Feeding instructions

• Guaranteed analysis

• Registration information

• Species indication

• Storage instructions

Therapeutic Positioning

Products positioned too aggressively as medical treatments may fall outside acceptable regulatory frameworks. This is particularly important for functional nutrition products.

Why Early Regulatory Planning Matters

Strong compliance strategies do more than satisfy legal requirements.

They also:

• Reduce reformulation risks

• Protect brand reputation

• Support retailer acceptance

• Improve export readiness

• Prevent costly packaging redesigns

• Strengthen manufacturing handovers

• Improve investor confidence

At CNP Pet Nutrition, we often help brands integrate regulatory strategy directly into the product development process from day one.

This creates smoother commercialisation pathways and reduces long-term costs.

Importing Pet Products into South Africa

Imported products introduce additional considerations.

Depending on the product type, importers may require:

• Local registrations

• Import permits

• Free Sale Certificates

• Ingredient documentation

• Country-of-origin documentation

• Local label adaptation

Imported labels frequently require modification to align with South African regulations.

This is especially important when products were originally designed for:

• Europe

• The United Kingdom

• The United States

• Asia

International compliance does not automatically equal South African compliance.

The Future of Compliance in the Pet Industry

The South African pet industry continues to evolve rapidly.

As premiumisation, therapeutic nutrition, and functional ingredients become more mainstream, regulatory scrutiny is also increasing.

Brands entering the market today are expected to demonstrate:

• Greater technical substantiation

• Transparent labeling

• Responsible claims

• Improved ingredient traceability

• Stronger manufacturing controls

Regulatory compliance is no longer simply an administrative step, it is becoming part of brand credibility.

Closing Thoughts

Act 36 compliance can feel overwhelming, particularly for startups and emerging pet brands. However, with proper planning and technical guidance, the process becomes significantly more manageable.

The most successful brands are those that integrate:

• Product development

• Regulatory planning

• Manufacturing strategy

• Label compliance

• Commercial readiness

from the beginning.

Whether you are launching a fresh food range, a therapeutic support product, a nutraceutical line, or an imported pet food brand, understanding the regulatory landscape early can help position your business for long-term success.

Need Support with Act 36 Compliance?

CNP Pet Nutrition assists local and international pet brands with:

• Regulatory strategies

• DALRRD applications

• Technical dossiers

• Label compliance

• Product development

• Nutritional substantiation

• Manufacturing handovers

• Commercialisation support

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