Shun Nagai“Animal by-products” are commonly mentioned as pet food ingredients, yet misconceptions persist—such as the idea that they may contain diseased animals or even feces and urine.
In reality, the EU strictly classifies animal by-products (ABPs) into Categories 1 to 3 based on risk, and only low-risk Category 3 materials are permitted for use in pet food.
Category 3 ABPs are limited to by-products from healthy animals or fish that have passed ante- and post-mortem inspection, and to safe parts that were simply not used for human food. In this article, we explain how the EU ABP regulation works, how animal-based ingredients such as chicken meal are actually controlled, and we clarify common misunderstandings that often trigger concern.
Animal By-Products (ABPs) in the EU
Animal by-products (ABPs) are animal-derived materials obtained from livestock and seafood that are not used as food for humans.
Specifically, ABPs include unused parts such as skin, bones, blood, fat, and organs that arise at slaughterhouses; livestock carcasses that die on farms; manure and feathers; and former foodstuffs (e.g., milk or eggs that become non-compliant during production).
In the EU, more than 20 million tonnes of these by-products are generated annually. While they are valuable resources, improper processing could increase transmission risks such as BSE, which is why ABPs are regulated under strict rules.
EU law (Regulation (EC) No 1069/2009) classifies ABPs into three categories (Cat. 1 to Cat. 3) according to risk level and sets safety requirements depending on the intended use. Cat. 1 is the highest risk category (e.g., specified risk material and animals suspected of transmissible disease), Cat. 2 is medium risk (e.g., animals that died from infectious disease, manure), and Cat. 3 is the lowest risk category.
Category 1 and 2 (Higher Risk) and Why They Are Restricted
Category 1 (Cat. 1)
Highest-risk materials requiring the strictest controls
- Parts from animals suspected of TSE (Transmissible Spongiform Encephalopathies), including specified risk material (SRM)
- Carcasses of experimental animals; zoo/circus animals
- Pet carcasses; wild animals (potential disease risk)
- Materials containing prohibited substances or environmental contaminants
Processing requirement:
In principle, incineration or only highly controlled approved methods are allowed. Use in pet food is not permitted.
Category 2 (Cat. 2)
Materials presenting a moderate level of risk
- Carcasses of livestock/poultry that died from infectious disease
- Meat or organs with drug residues due to medical treatment
- Livestock that died before slaughter or were dead on arrival at slaughterhouses
- Feces; digestive tract contents; stomach and intestinal contents
- Unfertilized eggs and dead poultry
Processing requirement:
After high-temperature, high-pressure sterilization, materials may be used for certain technical purposes or as organic fertilizers. Use in pet food is generally not permitted.
Because Cat. 1 and Cat. 2 materials present risks such as BSE and infectious diseases, they are not allowed for pet food in principle. Cat. 2 includes items such as carcasses of animals confirmed positive for infectious disease in inspection, diseased animals discarded from slaughterhouses, dead hatchlings and unhatched eggs, animals culled for disease control, livestock that died naturally on farms, as well as manure and gastrointestinal contents.
Feces and digestive tract contents are classified as Cat. 2 under EU rules and are not permitted as pet food raw materials. They are subject to strict processing and disposal requirements depending on the route—incineration/co-incineration or compliant high-temperature/high-pressure sterilization, anaerobic digestion, and similar methods (limited to uses such as biogas or compost).
Importantly, if Cat. 2 material is mixed with Cat. 3 material, the mixture is treated as the higher-risk category (Cat. 2). In other words, animals suspected of disease, manure, and digestive tract contents fall under Cat. 2 or above and are clearly excluded from pet food raw materials under EU law.
Category 3 ABPs (Low Risk): Key Characteristics
Category 3 (Cat. 3)
Lowest-risk materials, permitted for pet food manufacturing
- Slaughter-derived materials from healthy animals (fit for human consumption and inspection-approved)
- Meat and organs not used as food for commercial reasons
- Parts not suitable for food processing (e.g., eggshells, feathers, hides, fur)
- Foods rejected at the point of sale (defects) with no health risk
Processing requirement:
If appropriate heat treatment and microbiological testing and other hygiene standards are met, materials may be used in pet food manufacturing. Category 3 materials also tend to have high nutritional and energy value.
Cat. 3 is classified as “low risk,” and its use is permitted for pet food and, under certain conditions, for animal feed. Cat. 3 includes the following types of materials.
Materials included in Cat. 3
- Carcasses and organs that passed inspection at slaughterhouses and were originally fit for human consumption but were not used as food due to commercial reasons
- By-products arising from the manufacturing process of foods intended for human consumption (e.g., defatted bones, press cakes, residues from dairy production)
- Foods originally intended for human consumption but withdrawn from the market due to returns or manufacturing defects (e.g., meat/fish processed products, egg products)
- Fishery products and invertebrates
- Eggshells and hatchery waste (including unhatched eggs and dead chicks)
- Feathers, wool, hair, hooves, horns, and similar products obtained from animals showing no signs of disease
Feathers, in particular, are included in Cat. 3, but EU law limits them to feathers collected from healthy animals with no sign of infectious disease. In other words, Cat. 3 materials are restricted to parts and by-products from healthy animals confirmed as safe through veterinary assessment; diseased animals are not included.
Cat. 3 also includes PAP (Processed Animal Proteins), which corresponds to what is commonly called animal by-product meals. Nutrient-dense materials such as defatted bone and press residues from animal fats are also included in Cat. 3 and play an important role as pet food ingredients.
Use and Regulation of Animal By-Product Meals
Article 35 of Regulation (EC) No 1069/2009 clearly defines which materials may be used in pet food. It states that marketable pet food must, in principle, be produced from Category 3 materials (with certain exceptions defined under Article 10(n), (o), and (p)). This means Cat. 3 materials may be used provided that proper processing and controls are in place.
This applies not only to raw meat-based diets (RMBD) but also to rendered meals used in dry pet food. Under EU law, pet food must be manufactured from Cat. 3-derived materials—meaning there is also a clear legal basis for excluding higher-risk materials (Cat. 1 and Cat. 2) from pet food.
In addition, Cat. 3 animal by-product meals are processed under strict hygienic conditions mandated by EU law, including heat and pressure treatments (rendering) designed to inactivate pathogens. For example, under Regulation (EU) No 142/2011, Method 1 requires 133°C, 3 bar, for 20 minutes. For Cat. 3 materials, Methods 1–5 or 7 apply depending on the raw material and product type.
For this reason, Cat. 3 pet food ingredients can be described as “animal by-products managed safely under statutory hygiene standards.”
What Meals Do—and Do Not—Contain
Based on the above, “meal” used in dry pet food (rendered animal proteins and fats) has the following characteristics.
Derived from diseased animals?
Because Cat. 3 is limited to materials from healthy animals, diseased animals or animals suspected of disease are excluded from the beginning. This is confirmed through inspections and documentation at export/import. If an infectious disease is suspected, the material is treated as Cat. 2 within the regulatory framework.
Feathers, wool, and similar materials
Feathers are included in Cat. 3, but only when collected from healthy animals. Feathers are high in protein and fiber, and they may be rendered into feather meal (which is different from meat meal) and used in some pet foods.
However, as noted above, the original materials are low-risk by definition, and hygienic processing inactivates viruses and bacteria. Therefore, fears such as “large amounts of feathers being mixed in unsafely” are unfounded. Rather, Cat. 3 materials—including feathers—are strictly screened and controlled.
Feces and intestinal contents
These are classified as Cat. 2 and cannot be used as pet food raw materials. Meals do not contain fecal components, and using feces or intestinal contents as raw materials is legally prohibited.
Other components (e.g., meat and bone meal)
Meals from meat-processing residues (meat and bone meal) can also be produced from Cat. 3 materials. In addition, many high-value Cat. 3 materials are used, such as defatted bones (bone meal) and press residues.
These are by-products of food processing and originate from materials produced for human consumption and considered safe from a public health perspective.
Taken together, this shows that meals used in dry pet food are not made from diseased animals or feces/urine; they are Cat. 3-derived materials processed under statutory standards.
Processing, Hygiene Requirements, and Scientific/Legal Assessment
EU regulations impose strict hygiene controls on the manufacturing process for Cat. 3 animal by-products as well. For example, EFSA (European Food Safety Authority) has discussed raw meat products for pets (RMBD) and noted that Cat. 3-derived materials are subject to rigorous microbiological control standards under Regulations 1069/2009 and 142/2011.
These controls include inactivation of pathogens such as Salmonella through heat/pressure processing (rendering), as well as measures to prevent contamination during the transport and handling of raw materials. In addition, Cat. 3 materials originate only from animals that passed veterinary inspection before slaughter, and international transport requires certification—meaning the public health risk is extremely low.
In past EFSA opinions (e.g., assessments of hatchery waste), EFSA concluded that “after appropriate processing, use as a pet food ingredient is possible and does not increase health risk” (EFSA, 2011).
In short, EU law and EFSA’s scientific assessments effectively recognize the use of Cat. 3 animal by-products as safe when processed and managed correctly. After the BSE crisis, the EU strengthened PAP controls for TSE risk management, but Cat. 3 animal by-products are now widely used in pet food under regulatory compliance. Imported products must meet the same standards, and safety is supported through health certification.
Conclusion: EU-Sourced Animal By-Products Are Valuable Ingredients
Under the EU animal by-products regulation, pet food ingredients are restricted to low-risk Category 3 materials, and strict hygiene requirements must be met. Cat. 3 animal by-products originate from healthy animals and are processed under mandated heat treatments that inactivate pathogens.
Therefore, concerns such as “large amounts of diseased animals, feces, or unhygienic materials being mixed in” have no factual basis—and, in practice, such use is not permitted. EFSA and the European Commission conduct scientific safety assessments on the premise that Cat. 3 materials are used under regulation, indicating that Cat. 3 animal by-products, when properly processed, are safe and highly useful pet food ingredients.
These facts support the conclusion that there is no fundamental problem with the use of Cat. 3 animal by-products.