{"id":48767,"date":"2026-08-11T13:18:13","date_gmt":"2026-08-11T06:18:13","guid":{"rendered":"https:\/\/first-reach.org\/en\/?p=48767"},"modified":"2026-08-11T13:18:13","modified_gmt":"2026-08-11T06:18:13","slug":"chicken-allergy-protein-fraction-recipe-design","status":"publish","type":"post","link":"https:\/\/first-reach.org\/en\/contents\/chicken-allergy-protein-fraction-recipe-design\/","title":{"rendered":"OEM Design of Dog Food for Suspected Chicken Allergy: Meat, Poultry Meal, Chicken Fat, and Egg"},"content":{"rendered":"\n<p class=\"wp-block-paragraph\">\u201cA lot of dogs are allergic to chicken, so please take out every chicken-related ingredient.\u201d When we are approached about dog food formulated with allergies in mind, the conversation often opens with exactly that sentence.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The question that always follows is how far \u201cevery\u201d goes. Chicken meat, poultry meal, chicken fat and egg are all chicken-related ingredients, but they differ in what they are as raw materials and in the risks that need to be checked. On top of that, there are routes that are easy to miss if you only read the main ingredients on a formulation sheet, such as digests, hydrolysates and palatant coatings.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">To put the conclusion first: when you design a product around a suspected chicken allergy, the first thing you have to define is the range of chicken-derived ingredients you are excluding. \u201cNo chicken meat,\u201d \u201cchicken-free\u201d and \u201cfree from chicken-derived ingredients\u201d do not cover the same scope. Until the exclusion scope is fixed, you cannot settle the recipe, the ingredient specifications, the checklist for the factory, or the wording on the pack.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The hardest call of all is chicken fat. For the protein that remains in chicken fat, we could not identify any common standard \u2014 within published regulations or primary research \u2014 that would let you say \u201cbelow this level it will not trigger an allergic reaction.\u201d It is not that the measurement is impossible; it is that no common standard linking a measured result to clinical safety in dogs has been published.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">For that reason you cannot label chicken fat as uniformly \u201csafe\u201d or \u201cunsafe.\u201d Equally, you cannot conclude that heating, refining or hydrolysis on their own remove the concern. What the product development side can do is set out the intended use and the label wording, then specify the exclusion scope, ingredient specifications, manufacturing process, testing conditions and record-keeping in concrete terms.<\/p>\n\n\n\n<h4 id=\"toc-1\" class=\"wp-block-heading\">What this article covers<\/h4>\n\n\n\n<ul class=\"wp-block-list is-style-item__arrow has-dark-white-background-color has-background\">\n<li>Chicken-derived ingredients need to be considered in four categories: fresh meat, poultry meal, chicken fat and egg. There are also ingredients that require a separate check, such as digests and coating materials.<\/li>\n\n\n\n<li>\u201cNo chicken meat,\u201d \u201cchicken-free\u201d and \u201cfree from chicken-derived ingredients\u201d each cover a different range of excluded ingredients.<\/li>\n\n\n\n<li>For residual protein in chicken fat and for the degree of hydrolysis, there is no common standard that would let you judge clinical safety in dogs.<\/li>\n\n\n\n<li>\u201cNot used,\u201d \u201cno cross-contamination\u201d and \u201cclinically hypoallergenic\u201d each require a different kind of evidence.<\/li>\n<\/ul>\n\n\n\n<div class=\"epb-triangle\"><\/div>\n\n\n\n<h2 id=\"toc-2\" class=\"wp-block-heading\">Think of chicken-derived ingredients in four categories<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Chicken-derived ingredients need to be considered in at least four categories \u2014 groupings by the part or fraction that is taken out. For as long as they are all lumped together as \u201cchicken,\u201d no design decision is possible.<\/p>\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\">\n<p class=\"wp-block-paragraph\">The single word \u201cchicken\u201d houses ingredients with very different characters: meat, meal, fat and egg.<\/p>\n<\/blockquote>\n\n\n\n<h3 id=\"toc-2_1\" class=\"wp-block-heading\">Chicken-derived ingredients | fresh meat, meal, chicken fat, egg<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In this article we treat chicken-derived ingredients in four groups: (1) fresh meat (chicken meat, chicken liver and so on), (2) poultry meal (a dried protein ingredient that has been through rendering \u2014 heating, defatting and grinding), (3) chicken fat (also traded under names such as chicken oil, though the name alone does not guarantee an identical process or specification), and (4) egg. Groups (1), (2) and (4) are protein-led; only (3) is fat-led. That asymmetry matters later.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\">First Reach\u2019s view<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">In our view, this four-way split is a practical framework this article has reorganised for OEM recipe design; it is not an industry-standard classification. It matches neither the regulatory ingredient categories nor the academic allergen classifications.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Alongside it, put a fifth check route into your working practice: digests, hydrolysates, gravies and palatant coatings. It is not a fifth biological category, but if you only look at the main ingredients on the formulation sheet you will miss chicken-derived material that enters at the coating stage.<\/p>\n\n\n\n<h3 id=\"toc-2_2\" class=\"wp-block-heading\">How often is chicken allergy reported?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">As a matter of record, in a systematic review that collected elimination-diet and re-exposure studies (Mueller et al. 2016, BMC Vet Res 12:9), chicken was reported as involved in 45 (15%) of 297 dogs with confirmed adverse food reactions \u2014 third after beef (102 dogs, 34%) and dairy (51 dogs, 17%).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">This is a reported frequency with confirmed food-allergic dogs as the denominator, not a prevalence figure for dogs in general; and the subject was chicken meat, not refined chicken fat.<\/p>\n\n\n\n<h2 id=\"toc-3\" class=\"wp-block-heading\">About the protein contained in chicken fat<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The first thing to be clear about is that, in the dog pet food field, we found no common standard for the protein remaining in chicken fat \u2014 nothing that says \u201cbelow this level you need not declare it\u201d or \u201cbelow this level it will not trigger an allergic reaction.\u201d<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">That does not mean residual protein cannot be measured. Measurement is possible; what is missing is a unified basis on which to judge the number.<\/p>\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\">\n<p class=\"wp-block-paragraph\">In the dog pet food field, there is at present neither a published rule setting how much protein may remain in chicken fat, nor published data tying such a figure to clinical safety.<\/p>\n<\/blockquote>\n\n\n\n<h3 id=\"toc-3_1\" class=\"wp-block-heading\">There is no obligation to declare crude protein<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">As a matter of record, the EU and Canadian feed ingredient provisions do not uniformly require crude protein to be measured or declared for animal fats.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">For \u201cAnimal fat\u201d in the EU Catalogue of feed materials, the declarations required are crude fat, and moisture where the content exceeds 1%. There is no obligation to declare crude protein.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In the Canadian feed ingredients table as well, what must be declared for animal fats are maximum levels for moisture, insoluble impurities, unsaponifiable matter and free fatty acids. No crude protein guarantee is required. Note, however, that this ingredients table covers livestock feed and does not apply directly to dog and cat pet food.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In other words, protein ingredients such as meals are required to declare crude protein, while animal fats are not. That does not mean \u201cfat contains no protein at all\u201d; it means no common basis for measuring and declaring residual protein has been established.<\/p>\n\n\n\n<h3 id=\"toc-3_2\" class=\"wp-block-heading\">There is no published data on residual protein<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In this review we could not identify peer-reviewed papers or official analytical data measuring how much protein remains in refined chicken fat.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Nor could we identify studies feeding chicken fat alone to dogs to examine allergic reactions, or research directly testing whether chicken fat can be used in an elimination diet for food allergy. Ingredient specifications and general composition tables may carry an indicative crude protein figure, but we found no reliable published data that also states the measurement method and the limit of detection.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">That said, this does not mean \u201cprotein remaining in fats and oils cannot be measured.\u201d In human food research, trace cashew protein in heated vegetable oil has been reported as measurable by an analytical method called LC-MS\/MS. In oil spiked with 100 ppm of cashew protein, over 90% was still detected and recovered after 30 minutes at 138\u00b0C, and over 50% at 166\u00b0C.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">However, that study was an experiment using vegetable oil, not an investigation of animal fats such as chicken fat. It therefore cannot serve as direct evidence for how much protein remains in chicken fat or what the effect on dogs would be. It is simply a case showing that measuring trace protein in fats and oils at the ppm level is itself feasible.<\/p>\n\n\n\n<div class=\"epb-box epb-has-box-margin-item is-style-epb-border-headline\" style=\"--epb-box-padding-top:16px;--epb-box-padding-right:16px;--epb-box-padding-bottom:16px;--epb-box-padding-left:16px;--epb-box-margin-item:8px;--epb-box-padding-background-color:#ffffff;--epb-box-border-style:solid;--epb-box-border-color:#cf2e2e;--epb-box-border-width-top:2px;--epb-box-border-width-bottom:2px;--epb-box-border-width-left:2px;--epb-box-border-width-right:2px;--epb-box-radius:3px\"><div class=\"epb-box__headline icon-lightbulb \" data-fontweight=\"normal\" style=\"text-align:left;--epb-box-headline-background-color:#cf2e2e;--epb-font-sp:14px;--epb-font-tablet:14px;--epb-font-pc:16px;line-height:1;letter-spacing:0.05em;color:#ffffff\">Scope and limitations of this review<\/div><div class=\"epb-box__body\">\n<p class=\"wp-block-paragraph\">This review was carried out on 1 August 2026, with an additional search on 3 August. We checked Crossref, Europe PMC and EUR-Lex, as well as material published by government agencies and industry bodies in various countries, and took peer-reviewed papers and official analytical data as the scope of the review.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The fact that we could not identify relevant data on this occasion does not allow us to assert that no such data exists. Nor does the absence of data demonstrate that chicken fat is safe.<\/p>\n<\/div><\/div>\n\n\n\n<h3 id=\"toc-3_3\" class=\"wp-block-heading\">Residual protein cannot be judged on \u201camount\u201d alone<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">You cannot simply conclude that \u201cchicken fat contains little protein, so the allergy concern is small too.\u201d What matters is not only the total amount of protein but which kinds of protein remain.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In the study by Olivry &amp; Bexley (2018), serum IgE from corn-reactive dogs reacted to corn flour in 20 of 30 samples (67%), while none of 40 samples reacted to cornstarch. The protein concentration of the extracts used in the test had been adjusted to the same 5 \u00b5g\/mL in both cases.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The difference in reactivity therefore cannot be explained by a simple difference in protein quantity. The authors reason that the kinds and composition of the proteins present are likely to differ.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The study concludes that refined cornstarch is less allergenic than corn flour. But you cannot explain that solely as \u201crefining reduced the amount of protein.\u201d The kinds of protein that remain matter too.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">For chicken as well, Olivry et al. (2022) identified seven major chicken allergens and one minor allergen recognised by canine serum IgE. One of them is serum albumin, which has the property of binding fatty acids.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">However, that study was a blood-based test, not an analysis of chicken fat itself. It therefore cannot tell us whether these allergens remain in refined chicken fat, or to what extent if they do. We could not confirm this from published data either.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Note that the 2018 study was carried out by Avacta Animal Health with funding from Royal Canin. The authors\u2019 relationships with both companies are disclosed, so this should be taken into account when assessing the findings.<\/p>\n\n\n\n<h2 id=\"toc-4\" class=\"wp-block-heading\">Design decisions for each chicken-derived ingredient<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The categories differ in regulatory treatment, in whether primary canine data exists, and in the design questions they raise. The dividing line for design quality is whether you can write \u201cwhich category, and why we are excluding it\u201d rather than just \u201cremove chicken.\u201d<\/p>\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\">\n<p class=\"wp-block-paragraph\">Meat, meal, fat, egg and hydrolysis each require a separate judgement, because the strength of the evidence differs.<\/p>\n<\/blockquote>\n\n\n\n<figure class=\"wp-block-table is-style-table__scroll\" style=\"font-size:12px\"><table class=\"has-fixed-layout\"><thead><tr><th class=\"has-text-align-left\" data-align=\"left\">Category (fraction \/ processing)<\/th><th class=\"has-text-align-left\" data-align=\"left\">Treatment in regulations and reference sources<br>(jurisdictions checked)<\/th><th class=\"has-text-align-left\" data-align=\"left\">Primary data in dogs<\/th><th class=\"has-text-align-left\" data-align=\"left\">Design question<\/th><\/tr><\/thead><tbody><tr><td class=\"has-text-align-left\" data-align=\"left\">Fresh meat<\/td><td class=\"has-text-align-left\" data-align=\"left\">Declared as an ingredient name<\/td><td class=\"has-text-align-left\" data-align=\"left\">Seven major allergens plus one minor (serum IgE)<\/td><td class=\"has-text-align-left\" data-align=\"left\">Findings on protein fractions cannot be extrapolated to fat<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">Poultry meal<\/td><td class=\"has-text-align-left\" data-align=\"left\">Defined in AAFCO and the Canadian CFIT, but naming the species is optional<\/td><td class=\"has-text-align-left\" data-align=\"left\">Non-hydrolysed meal is recognised by serum IgE<\/td><td class=\"has-text-align-left\" data-align=\"left\">\u201cPoultry\u201d does not reveal whether it is single-species or mixed<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">Chicken fat<\/td><td class=\"has-text-align-left\" data-align=\"left\">In the EU and Canadian provisions checked, no requirement to declare or guarantee crude protein<\/td><td class=\"has-text-align-left\" data-align=\"left\">No published data identified<\/td><td class=\"has-text-align-left\" data-align=\"left\">Define by specification in an area that has no common standard<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">Egg<\/td><td class=\"has-text-align-left\" data-align=\"left\">Declared as an ingredient name<\/td><td class=\"has-text-align-left\" data-align=\"left\">Only whole-egg extract-level reports identified<\/td><td class=\"has-text-align-left\" data-align=\"left\">Treated as a separate item from chicken meat in several primary studies<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">Hydrolysis (processing)<\/td><td class=\"has-text-align-left\" data-align=\"left\">In the EU provisions checked, no numerical molecular-weight requirement<\/td><td class=\"has-text-align-left\" data-align=\"left\">Indicative molecular weights conflict between sources<\/td><td class=\"has-text-align-left\" data-align=\"left\">No common standard; define by specification<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n<h3 id=\"toc-4_1\" class=\"wp-block-heading\">(1) Fresh meat<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">This area has comparatively more research data. Care is needed, however, when switching to duck or turkey in order to avoid chicken.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In a study of 30 dogs with detectable chicken-specific IgE, all reacted to chicken meat, and 97% reacted to duck meat and to turkey meat respectively (Olivry et al., 2017). In other words, canine serum IgE recognised duck and turkey meat in much the same way as chicken meat.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">This was a blood-based test result, however. No provocation test was carried out to see whether dogs actually develop symptoms when fed. Egg was also not examined in that study.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The finding suggests that simply switching chicken for duck or turkey may not differentiate a product sufficiently as a \u201cnovel protein.\u201d If avoiding cross-reactivity with chicken is the priority, choosing a non-avian species is a more consistent approach to ingredient selection.<\/p>\n\n\n\n<h3 id=\"toc-4_2\" class=\"wp-block-heading\">(2) Poultry meal<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">For this category, note that the ingredient name alone tells you little about what is inside.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Under the definitions on the AAFCO official site and in the Canadian CFIT, \u201cPoultry Meal\u201d and \u201cPoultry By-Product Meal\u201d are defined as separate ingredients. In both cases, however, stating the specific bird species \u2014 chicken, turkey and so on \u2014 is optional. So when a label says only \u201cpoultry,\u201d you cannot determine whether a single bird species was used or several were mixed.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">There is also data on protein after processing. In the serum IgE testing by Olivry et al. (2017), 73% of sera from chicken-sensitised dogs reacted to an extract of non-hydrolysed rendered chicken meal. Reactivity to chicken meat was 100%, and to the beef comparator 3%.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">This result indicates that chicken-derived protein recognised by canine IgE may remain even in chicken meal that has undergone heat processing such as rendering. You therefore cannot say \u201cit has been heated, so there is no allergy concern.\u201d<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">What was used in the test, however, was the protein fraction of chicken meal after fat had been removed with acetone. It was not a study of protein remaining in refined chicken fat, so the result cannot be transferred as-is to chicken fat.<\/p>\n\n\n\n<h3 id=\"toc-4_3\" class=\"wp-block-heading\">(3) Chicken fat<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">As explained in the previous section, there is no published common standard for the protein remaining in chicken fat. In product design, therefore, judgements should not rest on the ingredient name alone: checking the ingredient specification and controlling the manufacturing process become important.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">It is possible that the amount of residual protein varies with the refining method. But as long as no published data confirming this can be identified, there is insufficient basis for claiming that \u201cthis chicken fat is low in residual protein.\u201d<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Two real formulation examples follow.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">For one veterinary hydrolysed-protein diet sold in the North American market, the ingredient listing on the manufacturer\u2019s official site runs \u201crice, hydrolysed soy protein, chicken fat,\u201d with chicken fat third. This is no more than one example of chicken fat being used in a hydrolysed-protein diet. It is not data showing that chicken fat is safe or that it does not cause allergic reactions, and the inclusion rate is not published.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In another veterinary diet for the UK market, the oil is declared as \u201canimal fats\u201d without specifying the species, and \u201chydrolysed poultry liver\u201d is listed separately as the protein source. Because EU and UK labelling rules do not require the source species of oils and fats to be stated, the label alone cannot tell you whether these \u201canimal fats\u201d are chicken-derived.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">It should be added that using hydrolysed protein is a basic design approach for this kind of veterinary diet. The presence of poultry-derived ingredients in the listing is therefore not in itself inconsistent with the product\u2019s design. These are simply real formulation examples; note that they do not demonstrate the safety or the allergenicity of chicken fat.<\/p>\n\n\n\n<h3 id=\"toc-4_4\" class=\"wp-block-heading\">(4) Egg<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In research, egg is treated as a separate ingredient from chicken meat. In the several primary studies collated by Mueller et al. (2016) as well, chicken meat and chicken egg were each challenge-tested as separate ingredients.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">That, however, shows only that the individual studies examined chicken meat and egg separately. We were not able to identify a textbook or guideline stating that \u201cegg must always be assessed separately from chicken meat.\u201d<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Nor could we identify research using actual feeding provocation tests to establish what proportion of dogs reactive to chicken meat also react to egg.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Accordingly, neither \u201cdogs that react to chicken meat also react to egg\u201d nor \u201cegg is separate from chicken meat, so it can be used\u201d can be determined from current canine research data.<\/p>\n\n\n\n<h3 id=\"toc-4_5\" class=\"wp-block-heading\">(5) Hydrolysis<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Hydrolysis is not a type of ingredient but a processing method that breaks protein into smaller pieces. It is nonetheless an important consideration when designing allergy-conscious products.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">For hydrolysed protein, there is no common standard that would let you conclude \u201cbring the molecular weight below this figure and it is safe.\u201d The indicative molecular weights given in peer-reviewed papers also differ between sources.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Trace those figures back further and the sources include not only systematic reviews in dogs but also non-peer-reviewed conference abstracts and reviews in humans. In other words, they are not thresholds derived from trials that fed dogs protein at different molecular weights and doses to establish the level at which reactions begin (Lesponne et al., 2018 \/ Masuda et al., 2020).<\/p>\n\n\n\n<div class=\"epb-linkcard is-style-epb-radius__0 is-style-epb-hover__floating wp-block-emanon-premium-blocks-linkcard epb-margin-top__default epb-margin-top__default-sp epb-margin-top__default-tablet\" style=\"--epb-linkcard-arrow-size:16px\"><div class=\"epb-linkcard_label icon-edit\" data-fontweight=\"normal\" style=\"font-size:12px;letter-spacing:0.15em\">Related article<\/div><a class=\"epb-linkcard_link\" href=\"https:\/\/first-reach.org\/en\/contents\/hydrolyzed-protein-for-pet-foods\/\" target=\"_blank\" rel=\"noopener noreferrer\"><div class=\"epb-linkcard_inner epb-arrow-effect-right is-style-epb-arrow__01\" style=\"padding-top:16px;padding-bottom:16px;padding-left:24px;border-style:solid;border-top-width:0;border-bottom-width:2px;border-left-width:0;border-right-width:0;border-color:#e5e7e8\"><div class=\"epb-linkcard_heading\"><div class=\"epb-linkcard_title\" data-fontweight=\"normal\" style=\"--epb-title-font-sp:16px;--epb-title-font-tablet:16px;--epb-title-font-pc:16px;letter-spacing:0.04em;color:#333333\">Animal Protein Hydrolysates: An Essential Ingredient in Dog and Cat Food<\/div><\/div><\/div><\/a><\/div>\n\n\n\n<h2 id=\"toc-5\" class=\"wp-block-heading\">Product design and allergy diagnosis are different things<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">When you design an allergy-conscious food, you do not investigate the allergic trigger of each individual dog before development. What the product development side decides is \u201cwhich ingredients to exclude, and what kind of use the product is for.\u201d Whether that product suits an individual dog is judged separately, through a diet trial under veterinary supervision.<\/p>\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\">\n<p class=\"wp-block-paragraph\">The development side decides what the product excludes; the veterinarian judges what the dog reacts to.<\/p>\n<\/blockquote>\n\n\n\n<h3 id=\"toc-5_1\" class=\"wp-block-heading\">What the development side decides<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In product development you do not identify an allergic trigger common to all dogs and then build the recipe. You decide which ingredients to exclude and which protein sources to use on the basis of conditions such as the following.<\/p>\n\n\n\n<ul class=\"wp-block-list is-style-item__checkmark--square has-dark-white-background-color has-background\">\n<li>What intended use to assume<\/li>\n\n\n\n<li>Which ingredients to exclude<\/li>\n\n\n\n<li>Whether to adopt novel protein or hydrolysed protein<\/li>\n\n\n\n<li>What to declare and claim on the pack and in advertising<\/li>\n\n\n\n<li>Whether the factory can segregate ingredients and control cross-contamination<\/li>\n\n\n\n<li>How far the origin of ingredients and the manufacturing process can be verified<\/li>\n\n\n\n<li>How much risk remains even after those measures<\/li>\n<\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">The phrase \u201callergy-conscious\u201d therefore does not by itself determine a recipe. The exclusion scope and control level have to be set out concretely, in line with the intended use and the label wording.<\/p>\n\n\n\n<h3 id=\"toc-5_2\" class=\"wp-block-heading\">Suitability for an individual dog is judged by a diet trial<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Reviews as of 2026 still hold that the most reliable way to diagnose adverse food reactions in dogs and cats is the combination of an elimination diet trial and a provocation test.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In an elimination diet trial, a diet free of the suspected ingredients is fed for a set period to see whether the signs improve. In the provocation test that follows, the suspect ingredient is fed again to see whether the signs recur.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Tests using serum IgE and IgG, saliva or hair are concluded to lack sufficient reliability and not to substitute for these diet trials (Mueller &amp; Olivry, 2017 \/ Udraite Vovk &amp; Mueller, 2026). This is an overall conclusion covering dogs and cats.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Diet trials carry their own uncertainty, however. In a double-blind, placebo-controlled trial in 12 dogs, half also reacted positively to placebo. The authors themselves note that doubts remain about interpreting provocation tests with single food items (Sofou et al., 2026).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In short, even a product designed as an allergy-conscious food will not necessarily suit every dog. Suitability for an individual dog cannot be settled from the product name or the ingredient list; it has to be confirmed under veterinary supervision.<\/p>\n\n\n\n<h3 id=\"toc-5_3\" class=\"wp-block-heading\">Feeding duration also matters for a diagnostic elimination diet<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In a systematic review pooling case data from 209 dogs, more than 95% of dogs showed improvement in skin signs within eight weeks of starting the elimination diet. To detect over 90% of adverse food reactions presenting with skin signs, continuing the elimination diet trial for at least eight weeks is recommended (Olivry et al., 2015).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">That said, the researchers did not test 209 dogs under identical conditions. The analysis pooled, from several earlier studies, the cases for which the timing of improvement after starting the elimination diet was known. It therefore does not directly prove through a comparative trial that eight weeks is the optimal duration.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">So if you are developing a product to be used as a diagnostic elimination diet, the pack size and sales unit that allow eight weeks of continuous feeding also become design considerations. For a general \u201callergy-conscious food,\u201d by contrast, designing for eight weeks\u2019 supply is not a requirement.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The role of the product development side is not to diagnose individual dogs. It is to make the intended use, the excluded ingredients, the label wording and the scope of manufacturing control explicit \u2014 and to state concretely what can be controlled and what cannot be guaranteed.<\/p>\n\n\n\n<h2 id=\"toc-6\" class=\"wp-block-heading\">A \u201cnot used\u201d claim is backed by process control<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Since there is no common standard for residual protein or contamination levels, the ingredient name alone cannot tell you at which steps the ingredient in question is used, or how much contamination risk remains.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">To make a \u201cnot used\u201d claim, you need to substantiate \u2014 through ingredient specifications, process control, test results, manufacturing records and the like \u2014 that the ingredient concerned is not used at any stage of manufacture.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">A \u201cnot used\u201d claim does not, however, guarantee the complete absence of the substance including unintended cross-contamination, nor that no dog will develop allergic signs.<\/p>\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\">\n<p class=\"wp-block-paragraph\">\u201cWhat is not used\u201d cannot be substantiated by ingredient names alone. Ingredient verification, contamination prevention, testing and records have to be combined to determine what can legitimately be declared.<\/p>\n<\/blockquote>\n\n\n\n<h3 id=\"toc-6_1\" class=\"wp-block-heading\">Ingredients absent from the label are sometimes detected<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In a 2018 systematic review pooling 18 studies on labelling discrepancies in dog and cat pet food, the proportion of products in which an unlabelled ingredient was detected ranged from 0% to 83% between studies, with a median of 45%.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Even restricting the view to elimination-diet products claiming \u201cnovel protein\u201d or \u201climited ingredient,\u201d unlabelled ingredients were detected in 33% to 83%.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Only a subset of ingredients was tested in each study, however. The authors note that the real rate of labelling discrepancy could be higher still if the range of ingredients tested were widened. Note also that the review covers studies published up to January 2018.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">On the other hand, detecting an unlabelled ingredient does not mean that the product actually causes allergic signs. As of August 2026 we could not identify any study that fed products with confirmed labelling discrepancies to dogs or cats allergic to the ingredient concerned and examined whether signs occurred.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">\u201cA component derived from an ingredient was detected\u201d and \u201ca dog develops signs\u201d therefore have to be kept apart.<\/p>\n\n\n\n<h3 id=\"toc-6_4\" class=\"wp-block-heading\">A brand can set its own control criteria<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">In the study by Lesponne et al. (2018), a tolerance level of 0.5% was set for unintended incidental protein contamination in one extensively hydrolysed diet product line.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">A corresponding total DNA concentration of 2.1 \u00b5g\/g was then given a safety margin, and 1.2 \u00b5g\/g adopted as the product acceptance criterion.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">However, 0.5% and 1.2 \u00b5g\/g are internal criteria set for that product line. They are neither a statutory standard nor a common standard applicable across the pet food industry. The authors themselves state that there is no clear consensus on how much contamination is acceptable. Note also that employees of Royal Canin \/ Mars are among the authors of that study.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">As this shows, if the analytical method and the acceptance criteria are set out concretely, it is possible for a brand owner and an OEM factory to establish their own contractual control criteria for lot-by-lot release decisions.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">What you cannot do is position those figures as \u201ca safety threshold at which no dog will develop allergic signs.\u201d What can be set are control criteria for ingredients, manufacturing and testing \u2014 not a common threshold guaranteeing clinical safety.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Residual protein may be reducible<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">The possibility that manufacturing steps can reduce the protein remaining in oil has been reported in human food research.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In a small-scale trial close to real production, 70\u2013130 ppm of cashew protein was detected in shared oil after 15 batches of cashews had been fried. When that oil continued to be used, 23.0 ppm was detected from peanuts and 193.5 ppm from potato chips.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">On the other hand, treating the oil with 11 \u00b5m or 25 \u00b5m filters or with diatomaceous earth was reported to bring protein levels of over 200 ppm down to below 10 ppm (Chen, Baumert &amp; Downs, 2026).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">This indicates that process controls such as filtration may reduce the protein contained in oil.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The subject of that research, however, was shared vegetable frying oil used in human food, not chicken fat. The same study also concludes that the concentrations detected could pose a health risk to people with food allergies.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">You therefore cannot transfer this result directly to chicken fat, nor conclude that \u201cfiltration makes it safe.\u201d For chicken fat, the treatment method, test target, limit of detection, testing frequency and acceptance criteria all have to be set individually.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">What a specification can fix, and what it cannot decide<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Setting figures and test conditions in a specification does not by itself rule out every risk. You need to separate what can be controlled from what the results cannot tell you.<\/p>\n\n\n\n<figure style=\"font-size:12px\" class=\"wp-block-table\"><table class=\"has-fixed-layout\"><thead><tr><th>Issue<\/th><th>What a specification can fix<\/th><th>What the result alone cannot decide<\/th><\/tr><\/thead><tbody><tr><td>Chicken fat<\/td><td>Analytical method, target protein, limit of quantification, testing frequency, reporting format<\/td><td>That no allergen is present, or that no dog will react<\/td><\/tr><tr><td>Species of origin of the ingredient<\/td><td>Single-species declaration, specifying species-specific testing<\/td><td>A single-species guarantee based on a declaration such as \u201cpoultry\u201d alone<\/td><\/tr><tr><td>Line changeover<\/td><td>Cleaning procedure, changeover records, handling of the preceding flush lot<\/td><td>That cross-contamination is completely zero<\/td><\/tr><tr><td>Testing<\/td><td>Target species, analytical method, limit of detection, testing frequency, acceptance criteria<\/td><td>Treating a negative result as complete absence of the ingredient concerned<\/td><\/tr><tr><td>Hydrolysis<\/td><td>Origin of the ingredient, definition of the degree of hydrolysis, measurement method<\/td><td>That below a given molecular weight no dog will react<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n<h3 id=\"toc-6_5\" class=\"wp-block-heading\">Ten points to check with an OEM factory<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Verification supporting \u201cfree from chicken-derived ingredients\u201d splits into two parts: checking the recipe and ingredients, and checking the manufacturing process.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The first thing to check is the recipe and ingredient specification for each product. Even within the same \u201chydrolysed diet\u201d range, the ingredients used differ by SKU. In practice there are cases where one product lists hydrolysed chicken liver and chicken gizzard while another product in the same range does not.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">So a range name or product category such as \u201chydrolysed diet\u201d or \u201climited ingredient diet\u201d cannot tell you whether poultry-derived ingredients are present. The ingredient declaration, formulation sheet and ingredient specification have to be checked SKU by SKU.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">It is not only main ingredients such as meat and meal that need checking. Sub-ingredients and processing aids like the following are also in scope.<\/p>\n\n\n\n<ul class=\"wp-block-list is-style-item__arrow has-dark-white-background-color has-background\">\n<li>Main and sub-ingredients<\/li>\n\n\n\n<li>Carriers<\/li>\n\n\n\n<li>Digests<\/li>\n\n\n\n<li>Coating materials<\/li>\n<\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">Next comes the manufacturing process. Even where the recipe contains no chicken-derived ingredient, the same factory or equipment may be producing other products that do. The ingredient declaration alone cannot tell you about the potential for cross-contamination via shared equipment, production sequence, cleaning or rework.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">So check, at every step \u2014 intake, storage, weighing, charging, mixing, forming, drying, coating and packing \u2014 whether chicken-derived ingredients may be used or introduced.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The ten points below are not a checklist laid down uniformly by law. They are practical examples of how to substantiate that \u201cthe ingredient concerned is not used at any stage of manufacture,\u201d adapted to the factory\u2019s equipment and production conditions.<\/p>\n\n\n\n<figure style=\"font-size:12px\" class=\"wp-block-table\"><table class=\"has-fixed-layout\"><thead><tr><th>Point to check<\/th><th>Why it matters<\/th><\/tr><\/thead><tbody><tr><td>(1) Dedicated tank or shared tank<\/td><td>If shared, you need to check the residue risk from the previously manufactured product<\/td><\/tr><tr><td>(2) Extent of shared pipework and weighing systems<\/td><td>Without knowing the shared extent, you cannot define what to clean or what to record<\/td><\/tr><tr><td>(3) Sharing of coating equipment<\/td><td>Coating materials such as digests are an easily overlooked contamination route<\/td><\/tr><tr><td>(4) Production changeover sequence<\/td><td>Residue risk changes depending on whether it follows a product containing chicken-derived ingredients<\/td><\/tr><tr><td>(5) Cleaning procedure and cleaning validation<\/td><td>You need to confirm not just that a cleaning procedure exists but that it works<\/td><\/tr><tr><td>(6) Handling of flush material<\/td><td>Disposal, re-charging or use in other products each send the residue somewhere different<\/td><\/tr><tr><td>(7) Whether rework may be charged, and its records<\/td><td>Rework can bring in ingredients that are meant to be excluded<\/td><\/tr><tr><td>(8) Notification conditions for change control<\/td><td>If an ingredient or process changes, the basis for the free-from claim changes<\/td><\/tr><tr><td>(9) Sampling plan<\/td><td>Without fixed sampling locations, timing and number of samples, test results cannot be evaluated properly<\/td><\/tr><tr><td>(10) Record retention period and how records are provided<\/td><td>Check that the evidence supporting the claim is retained for the prescribed period and can be produced on request<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n<p class=\"wp-block-paragraph\">If testing is carried out, writing \u201cPCR tested\u201d is not enough. The target species, whether DNA or protein is being examined, the analytical method, the limit of detection, the testing frequency and the acceptance criteria all have to be specified.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In addition, Article 11 of the Fair Competition Code on Pet Food Labelling sets retention periods for the material underpinning a claim, such as formulation design documents, spec sheets and analytical data.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">It does not, however, prescribe the format in which that material is to be provided. So OEM contracts and quality specifications should set out, alongside the retention period, how the material will be provided, by when, and how changes will be notified.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">These ten points are examples of the evidence and controls that support a \u201cnot used\u201d claim. Rather than demanding every item uniformly, work back from the wording you want to use and from the factory\u2019s equipment and production situation to decide the necessary scope of verification and level of control.<\/p>\n\n\n\n<h2 id=\"toc-7\" class=\"wp-block-heading\">The line a claim must not cross<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Allergy-related claims require different evidence depending on what they say. To state \u201cchicken-free,\u201d for example, you need not only to keep chicken out of the recipe but to confirm that it is not used at any stage of manufacture.<\/p>\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\">\n<p class=\"wp-block-paragraph\">\u201cNot used,\u201d \u201czero cross-contact\u201d and \u201cclinically hypoallergenic\u201d are separate propositions. The evidence that lets you write each of them is different.<\/p>\n<\/blockquote>\n\n\n\n<h3 id=\"toc-7_1\" class=\"wp-block-heading\">Four types of claim<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">The following is organised on the basis of the Fair Competition Code on Pet Food Labelling (Japan Fair Trade Commission \/ Consumer Affairs Agency Notification No. 4 of 30 September 2024, in force 1 October 2024) and its Enforcement Regulations. It binds businesses participating in the Code. It governs labelling for the Japanese market; other markets are governed by their own rules.<\/p>\n\n\n\n<figure class=\"wp-block-table is-style-table__scroll\" style=\"font-size:12px\"><table class=\"has-fixed-layout\"><thead><tr><th class=\"has-text-align-left\" data-align=\"left\">Type of claim<\/th><th class=\"has-text-align-left\" data-align=\"left\">Typical product type<\/th><th class=\"has-text-align-left\" data-align=\"left\">Basis in the Code<\/th><th class=\"has-text-align-left\" data-align=\"left\">What must be satisfied<\/th><\/tr><\/thead><tbody><tr><td class=\"has-text-align-left\" data-align=\"left\">(1) Emphasising the use or inclusion of chicken<\/td><td class=\"has-text-align-left\" data-align=\"left\">General products<\/td><td class=\"has-text-align-left\" data-align=\"left\">Article 7 of the Code<\/td><td class=\"has-text-align-left\" data-align=\"left\">Unless the ingredient accounts for 5 per cent or more of the net content, its use may not be indicated in the product name, illustrations, photographs, descriptive text and the like<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">(2) Chicken \/ chicken-derived ingredients not used<\/td><td class=\"has-text-align-left\" data-align=\"left\">Limited-ingredient products \/ chicken-free products<\/td><td class=\"has-text-align-left\" data-align=\"left\">Article 8(4) of the Code + Article 7(4)(a) of the Enforcement Regulations<\/td><td class=\"has-text-align-left\" data-align=\"left\">The name of the ingredient stated as not added must be clearly indicated alongside the claim, and it must be verifiable that the ingredient is not used at any stage of manufacture of the pet food<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">(3) Hypoallergenic \/ allergy-conscious<\/td><td class=\"has-text-align-left\" data-align=\"left\">General products claiming allergy consideration<\/td><td class=\"has-text-align-left\" data-align=\"left\">No direct definition in the Fair Competition Code; judged case by case under the Premiums and Representations Act and the general prevention-of-misleading-claims principle in Article 10 of the Code<\/td><td class=\"has-text-align-left\" data-align=\"left\">Prepare reasonable grounds corresponding to the claim, and do not imply treatment, prevention or improvement of disease<\/td><\/tr><tr><td class=\"has-text-align-left\" data-align=\"left\">(4) Treatment or improvement of disease<\/td><td class=\"has-text-align-left\" data-align=\"left\">Elimination diets and veterinary diets used under veterinary supervision<\/td><td class=\"has-text-align-left\" data-align=\"left\">Article 3(4) and Article 6 of the Code \/ Article 5 of the Enforcement Regulations \/ Article 8(3) of the Enforcement Regulations<\/td><td class=\"has-text-align-left\" data-align=\"left\">There is a route to state the disease or health condition for which the product applies as a \u201cveterinary diet\u201d and to report it to the Fair Trade Council. Conversely, labelling that claims or implies the efficacy of a veterinary medicinal product, or comparable efficacy, is a category of improper representation<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n<p class=\"is-style-paragraph__lines-right wp-block-paragraph\" style=\"font-size:18px\"><strong>Notes on the table\u2019s categories and labelling terms<\/strong><\/p>\n\n\n\n<h4 class=\"wp-block-heading\">\u201cTypical product type\u201d is a classification used for explanation<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">The \u201ctypical product type\u201d column is a classification created to make the explanation clearer in this article; it is not a formal category under the Code. The formal purpose categories under Article 4(2) of the Fair Competition Code on Pet Food Labelling are the following four.<\/p>\n\n\n\n<ul class=\"wp-block-list is-style-item__arrow has-dark-white-background-color has-background\">\n<li>Complete and balanced food<\/li>\n\n\n\n<li>Treats<\/li>\n\n\n\n<li>Veterinary diet<\/li>\n\n\n\n<li>Food for other purposes<\/li>\n<\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">Article 10(2) of the Code also prohibits, as an improper representation, any labelling that does not conform to the labelling standards in Article 7 or Article 8.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\">For the EU, do not swap \u201cintolerance\u201d for \u201callergy\u201d<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">For products aimed at the EU, the terms you may use also require care.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Part B, entry 13 of the Annex to Commission Regulation (EU) 2020\/354 sets out the official wording \u201cReduction of ingredient and nutrient intolerances.\u201d<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Footnote (6) permits the words \u201cingredient and nutrient\u201d to be replaced with the name of the specific intolerance concerned. It does not, however, extend to replacing \u201cintolerance\u201d with \u201callergy.\u201d<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The term \u201cdietetic\u201d is likewise not a freely usable expression. Under Article 18 of Regulation (EC) No 767\/2009, it is reserved for feed intended for particular nutritional purposes.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\">\u201cNo chicken meat\u201d and \u201cno chicken-derived ingredients\u201d cover different scopes<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">\u201cNo chicken meat\u201d normally indicates that the flesh of the chicken is not used. \u201cFree from chicken-derived ingredients,\u201d by contrast, is a broader expression covering all ingredients derived from chicken.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">If you are going to claim \u201cfree from chicken-derived ingredients,\u201d you have to define in advance whether the exclusion extends beyond chicken meat to the following ingredients.<\/p>\n\n\n\n<ul class=\"wp-block-list is-style-item__arrow has-dark-white-background-color has-background\">\n<li>Chicken fat<\/li>\n\n\n\n<li>Egg<\/li>\n\n\n\n<li>Poultry meal<\/li>\n\n\n\n<li>Digests<\/li>\n\n\n\n<li>Coating materials<\/li>\n\n\n\n<li>Other chicken-derived sub-ingredients<\/li>\n<\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">Rather than fixing the label wording first, decide the range of ingredients to exclude and then check the ingredient specifications and the manufacturing process. This is the point at which the factory checklist set out in the previous section matters.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In the EU market there are in fact products claiming a \u201csingle animal protein source\u201d while listing poultry oil and poultry hydrolysate among the ingredients (verified 3 August 2026).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Under EU dietetic feed rules, oils and hydrolysates may be treated as outside the scope of a \u201csingle protein source\u201d claim. The labelling alone therefore cannot be judged as false.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">What this example shows is that a product category or claim such as \u201csingle protein source\u201d cannot by itself tell you that poultry-derived oils and sub-ingredients are absent. Note that the inclusion rates for the product concerned are not published.<\/p>\n\n\n\n<h3 id=\"toc-7_2\" class=\"wp-block-heading\">\u201cNot used\u201d is a process requirement<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">This is the most practically consequential point in this article. Whether you can write \u201cchicken-free\u201d is not a recipe question but a manufacturing process question.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Article 7(4)(a) of the Enforcement Regulations provides that terms such as \u201cno added\u201d or \u201cnot used\u201d may be applied to non-additive ingredients only where the name of the ingredient stated as not added is clearly indicated alongside, and where \u201cit can be verified that the ingredient concerned is not used at any stage of manufacture of the pet food.\u201d What the provision requires is a state of being verifiable; it does not lay down a uniform list of specific tests. The ten points in the previous section are practical examples for assembling that substantiation.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">\u201cThe ingredient concerned is not used,\u201d \u201ccross-contact is zero\u201d and \u201cthe product is clinically hypoallergenic\u201d are separate propositions. Article 7(4)(a) requires the first; it does not guarantee the second or the third.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Note also that emphasising \u201cnot used\u201d for an ingredient or additive that would not normally be used, in a way that misleads consumers into thinking the product is superior in quality, may fall within the category of improper representation under Article 8(1)(a) of the Enforcement Regulations (relating to Article 10(6) of the Code), even where Article 7(4)(a) is satisfied.<\/p>\n\n\n\n<h3 id=\"toc-7_3\" class=\"wp-block-heading\">Where \u201chypoallergenic\u201d stands<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">\u201cHypoallergenic\u201d is a term for which no definition exists in the EU feed labelling Regulation (EC) 767\/2009, the PARNUT list Regulation (EU) 2020\/354, the FEDIAF labelling code (October 2019 edition), or the AAFCO model regulations for pet food (2023 approved version; verified against the AAFCO public PDF version).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Whether it may be used is therefore judged case by case: in the EU under the general prevention-of-misleading-claims and claim requirements of Articles 11 and 13 of 767\/2009, and in the United States within the framework of misbranding and drug claims.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Japan\u2019s Fair Competition Code contains no definition either. Article 7(1) of the Enforcement Regulations sets criteria for terms such as \u201clow,\u201d but these apply to the presence or amount of particular nutrients and do not apply directly to allergens.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\">Regulatory note<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">Expressions suggesting the treatment, prevention or improvement of disease cannot be used in Japan, the EU or the United States. In Japan, Article 8(3) of the Enforcement Regulations makes labelling that claims or implies the efficacy of a veterinary medicinal product, or comparable efficacy, a category of improper representation.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In the United States, the FDA has formally taken the position that express or implied claims to treat, prevent or mitigate disease require approval as a new animal drug. In the EU, Article 13(3)(a) of Regulation (EC) No 767\/2009 prohibits claiming that feed will prevent, treat or cure a disease.<\/p>\n\n\n\n<h3 id=\"toc-7_4\" class=\"wp-block-heading\">Retention of supporting material<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Article 7(2) of the Premiums and Representations Act provides that, where the Consumer Affairs Agency has requested submission of reasonable material substantiating a representation in connection with an order for action, and the business does not submit it, the representation is deemed \u2014 for the purposes of that order \u2014 to be a misleading representation of superior quality (falling under Article 5(1)).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Article 11 of the Pet Food Fair Competition Code likewise provides that material underpinning a representation \u2014 formulation design documents, spec sheets, analytical data and the like \u2014 is to be retained for two years from the final manufacturing date of the product concerned where the best-before period is within two years, and until the expiry of the best-before date of the final manufactured product where it exceeds two years.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In practice it makes sense to design the process records for a free-from claim into that same retention scope.<\/p>\n\n\n\n<h2 id=\"toc-9\" class=\"wp-block-heading\">Frequently asked questions (FAQ)<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\" id=\"toc-9_1\"><strong><em>Q1. Can chicken fat be included in an elimination diet?<\/em><\/strong><\/p>\n\n\n\n<p class=\"has-dark-white-background-color has-background wp-block-paragraph\">Within published regulations and primary research, we could not identify a generalisable declaration threshold or clinical threshold for residual protein in chicken fat. It is not that measurement is impossible; it is that, in the dog pet food field, no common standard converting a measured result into clinical safety has been published. Whether to include it is therefore a matter for the attending veterinarian. On the product side, the realistic step is to make the presence or absence of chicken fat clear in the ingredient declaration.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\" id=\"toc-9_2\"><strong><em>Q2. Can an ingredient declared as \u201cpoultry meal\u201d be assumed to be chicken only?<\/em><\/strong><\/p>\n\n\n\n<p class=\"has-dark-white-background-color has-background wp-block-paragraph\">No, it cannot be determined. Under both the AAFCO and Canadian CFIT definitions, naming the species is optional (CFIT is an ingredients table for livestock feed). If you need to work on a single-species basis, you have to specify the species in the ingredient specification and require evidence.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\" id=\"toc-9_3\"><strong><em>Q3. Can I put \u201cchicken-free\u201d on the pack?<\/em><\/strong><\/p>\n\n\n\n<p class=\"has-dark-white-background-color has-background wp-block-paragraph\">Beyond not using chicken as an ingredient, verification of the process is a requirement. Article 7(4)(a) of the Enforcement Regulations of the Fair Competition Code provides that terms such as \u201cno added\u201d or \u201cnot used\u201d may be applied only where the name of the ingredient stated as not added is clearly indicated alongside, and where it can be verified that the ingredient concerned is not used at any stage of manufacture of the pet food.<br><br>What the provision requires is a state of being verifiable; it does not uniformly designate particular tests. Note also that \u201cnot used\u201d does not mean zero cross-contact or clinical hypoallergenicity.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\" id=\"toc-9_4\"><strong><em>Q4. How often do animal species not on the ingredient list turn up in the product?<\/em><\/strong><\/p>\n\n\n\n<p class=\"has-dark-white-background-color has-background wp-block-paragraph\">In a 2018 systematic review pooling 18 reports, the proportion of products in which an unlabelled ingredient was detected ranged from 0\u201383% between studies (median 45%), and 33\u201383% even when restricted to \u201cnovel \/ limited ingredient\u201d products for elimination diets. The authors themselves state, however, that the real non-conformity rate is very likely to be higher than this. As set out in the main text, detection and the onset of signs are not linked.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\" id=\"toc-9_5\"><strong><em>Q5. Can I write \u201chypoallergenic\u201d on the pack?<\/em><\/strong><\/p>\n\n\n\n<p class=\"has-dark-white-background-color has-background wp-block-paragraph\">\u201cHypoallergenic\u201d is a term for which no definition exists in the EU\u2019s 767\/2009 or 2020\/354, the FEDIAF labelling code, or the AAFCO model regulations. Japan\u2019s Fair Competition Code contains no definition either.<br><br>It is not a prohibited word, but the supporting evidence is yours to prepare. In Japan, Article 7(2) of the Premiums and Representations Act imposes a regime on unsubstantiated advertising, so you need material you can submit on request (for retention periods, please see \u201cRetention of supporting material\u201d in the main text).<br><br>Used in a context suggesting the treatment or improvement of allergy, however, it may amount to an improper representation under Article 8(3) of the Enforcement Regulations. Because whether a claim is permissible is judged case by case, please consult the Pet Food Fair Trade Council before finalising the wording.<\/p>\n\n\n\n<p class=\"is-style-paragraph__lines-right wp-block-paragraph\" id=\"toc-10\"><strong>References and sources<\/strong><\/p>\n\n\n\n<ol class=\"wp-block-list is-style-item__num--zero has-dark-white-background-color has-background\">\n<li>Mueller RS, Olivry T, Pr\u00e9laud P. \u201cCritically appraised topic on adverse food reactions of companion animals (2): common food allergen sources in dogs and cats,\u201d BMC Veterinary Research 12:9, 2016 https:\/\/doi.org\/10.1186\/s12917-016-0633-8 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Olivry T, Mueller RS, Pr\u00e9laud P. \u201cCritically appraised topic on adverse food reactions of companion animals (1): duration of elimination diets,\u201d BMC Veterinary Research 11:225, 2015 https:\/\/doi.org\/10.1186\/s12917-015-0541-3 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Mueller RS, Olivry T. \u201cCritically appraised topic on adverse food reactions of companion animals (4): can we diagnose adverse food reactions in dogs and cats with in vivo or in vitro tests?,\u201d BMC Veterinary Research 13:275, 2017 https:\/\/doi.org\/10.1186\/s12917-017-1142-0 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Olivry T, Mueller RS. \u201cCritically appraised topic on adverse food reactions of companion animals (5): discrepancies between ingredients and labeling in commercial pet foods,\u201d BMC Veterinary Research 14:24, 2018 https:\/\/doi.org\/10.1186\/s12917-018-1346-y (accessed 2026-08-01)<\/li>\n\n\n\n<li>Olivry T, Pucheu-Haston CM, Mayer U, Bergvall K, Bexley J. \u201cIdentification of major and minor chicken allergens in dogs,\u201d Veterinary Dermatology 33(1):46-e16, 2022 https:\/\/doi.org\/10.1111\/vde.13029 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Olivry T, Bexley J, Mougeot I. \u201cExtensive protein hydrolyzation is indispensable to prevent IgE-mediated poultry allergen recognition in dogs and cats,\u201d BMC Veterinary Research 13:251, 2017 https:\/\/doi.org\/10.1186\/s12917-017-1183-4 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Olivry T, Bexley J. \u201cCornstarch is less allergenic than corn flour in dogs and cats previously sensitized to corn,\u201d BMC Veterinary Research 14:207, 2018 https:\/\/doi.org\/10.1186\/s12917-018-1538-5 (accessed 2026-08-01. This study was conducted by Avacta Animal Health with funding from Royal Canin)<\/li>\n\n\n\n<li>Masuda K, Sato A, Tanaka A, Kumagai A. \u201cHydrolyzed diets may stimulate food-reactive lymphocytes in dogs,\u201d Journal of Veterinary Medical Science 82(2):177-183, 2020 https:\/\/doi.org\/10.1292\/jvms.19-0222 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Lesponne I, Naar J, Planchon S, Serchi T, Montano M. \u201cDNA and Protein Analyses to Confirm the Absence of Cross-Contamination and Support the Clinical Reliability of Extensively Hydrolysed Diets for Adverse Food Reaction-Pets,\u201d Veterinary Sciences 5(3):63, 2018 https:\/\/doi.org\/10.3390\/vetsci5030063 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Sofou EI, Samuel E, Aleksandrova S, Chatzis M, Saridomichelakis MN. \u201cRandomised, Double-Blinded, Placebo-Controlled Challenge Test With Single Food Items in Dogs With Atopic Dermatitis and Adverse Food Reactions,\u201d Veterinary Dermatology 37(2):247-256, 2026 https:\/\/doi.org\/10.1111\/vde.70041 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Udraite Vovk L, Mueller RS. \u201cAdverse Food Reactions in Dogs and Cats,\u201d Veterinary Clinics of North America: Small Animal Practice 56:579-589, 2026 https:\/\/doi.org\/10.1016\/j.cvsm.2025.11.003 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Pagani E, Soto del Rio MdlD, Dalmasso A, Bottero MT, Schiavone A, Prola L. \u201cCross-contamination in canine and feline dietetic limited-antigen wet diets,\u201d BMC Veterinary Research 14:283, 2018 https:\/\/doi.org\/10.1186\/s12917-018-1571-4 (accessed 2026-08-01)<\/li>\n\n\n\n<li>Chen S, Downs ML. \u201cDevelopment of a Mass Spectrometry-Based Method for Quantification of Total Cashew Protein in Roasting Oil,\u201d Journal of AOAC International 107(3):443-452, 2024 https:\/\/doi.org\/10.1093\/jaoacint\/qsae019 (accessed 2026-08-03)<\/li>\n\n\n\n<li>Chen S, Baumert JL, Downs ML. \u201cQuantification, Risk Assessment, and Mitigation of Cashew Allergen Cross-Contact in Shared Roasting Oil Systems,\u201d Journal of Food Protection 89(1):100678, 2026 (online ahead of print 2025) https:\/\/doi.org\/10.1016\/j.jfp.2025.100678 (accessed 2026-08-03)<\/li>\n\n\n\n<li>Canadian Food Inspection Agency, \u201cCanadian Feed Ingredients Table (CFIT)\u201d (a document incorporated by reference in the Feeds Regulations, 2024), date modified: 2026-06-26 https:\/\/inspection.canada.ca\/en\/animal-health\/livestock-feeds\/documents-incorporated-reference\/canadian-feed-ingredients-table (accessed 2026-08-03)<\/li>\n\n\n\n<li>Canadian Food Inspection Agency, \u201cRG-1 Regulatory Guidance: Feed Registration Procedures and Labelling Standards,\u201d date modified: 2026-04-15 https:\/\/inspection.canada.ca\/en\/animal-health\/livestock-feeds\/regulatory-guidance\/rg-1 (accessed 2026-08-03)<\/li>\n\n\n\n<li>European Commission, \u201cCommission Regulation (EU) 2017\/1017 amending Regulation (EU) No 68\/2013 on the Catalogue of feed materials (Annex Part C Chapter 9),\u201d 2017 https:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/HTML\/?uri=CELEX:32017R1017 (accessed 2026-08-01)<\/li>\n\n\n\n<li>European Commission, \u201cCommission Regulation (EU) 2022\/1104 amending Regulation (EU) No 68\/2013 on the Catalogue of feed materials,\u201d 2022 https:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/HTML\/?uri=CELEX:32022R1104 (accessed 2026-08-01)<\/li>\n\n\n\n<li>European Parliament and Council, \u201cRegulation (EC) No 767\/2009 on the placing on the market and use of feed (consolidated text 02009R0767 \u2014 26.12.2018),\u201d 2018 https:\/\/publications.europa.eu\/resource\/celex\/02009R0767-20181226 (accessed 2026-08-01)<\/li>\n\n\n\n<li>European Commission, \u201cCommission Regulation (EU) 2020\/354 establishing a list of intended uses of feed intended for particular nutritional purposes (consolidated text 02020R0354 \u2014 22.04.2025),\u201d 2025 https:\/\/publications.europa.eu\/resource\/celex\/02020R0354-20250422 (accessed 2026-08-01)<\/li>\n\n\n\n<li>AAFCO, \u201cWhat\u2019s in the Ingredients List?\u201d (definitions of Poultry Meal \/ Poultry By-Product Meal) https:\/\/www.aafco.org\/consumers\/understanding-pet-food\/whats-in-the-ingredients-list\/ (accessed 2026-08-01)<\/li>\n\n\n\n<li>AAFCO, \u201cModel Regulations for Pet Food and Specialty Pet Food Under the Model Bill (20230403 final; approved by members 2023-07-31),\u201d 2023 https:\/\/www.aafco.org\/wp-content\/uploads\/2023\/04\/9._FINAL_PFC_MBRC_for_Pet_Food_and_Specialty_Pet_Food.pdf (accessed 2026-08-01) (Public PDF version; the text carries a \u201cDRAFT!!\u201d marking. The authoritative version is the paid AAFCO Official Publication, 2026 edition)<\/li>\n\n\n\n<li>U.S. Food and Drug Administration, \u201cAnimal Food Labeling and Pet Food Claims,\u201d content current as of 2026-03-02 https:\/\/www.fda.gov\/animal-veterinary\/animal-food-feeds\/animal-food-labeling-and-pet-food-claims (accessed 2026-08-03)<\/li>\n\n\n\n<li>FEDIAF, \u201cCode of Good Labelling Practice for Pet Food,\u201d October 2019 https:\/\/europeanpetfood.org\/wp-content\/uploads\/2022\/02\/FEDIAF_labeling_code_2019_onlineOctober2019.pdf (accessed 2026-08-01)<\/li>\n\n\n\n<li>Pet Food Fair Trade Council, \u201cFair Competition Code on Pet Food Labelling (Japan Fair Trade Commission \/ Consumer Affairs Agency Notification No. 4 of 30 September 2024, in force 1 October 2024) and its Enforcement Regulations\u201d https:\/\/pffta.org\/pdf\/regulations.pdf \/ Consumer Affairs Agency, \u201cAct against Unjustifiable Premiums and Misleading Representations (Act No. 134 of 1962)\u201d https:\/\/laws.e-gov.go.jp\/law\/337AC0000000134 (accessed 2026-08-01)<\/li>\n<\/ol>\n\n\n\n<div class=\"epb-linkcard is-style-epb-radius__0 is-style-epb-hover__floating wp-block-emanon-premium-blocks-linkcard epb-margin-top__default epb-margin-top__default-sp epb-margin-top__default-tablet\" style=\"--epb-linkcard-arrow-size:16px\"><div class=\"epb-linkcard_label icon-edit\" data-fontweight=\"normal\" style=\"font-size:12px;letter-spacing:0.15em\">Related article<\/div><a class=\"epb-linkcard_link\" href=\"https:\/\/first-reach.org\/en\/contents\/food-allergy-for-dogs\/\" target=\"_blank\" rel=\"noopener noreferrer\"><div class=\"epb-linkcard_inner epb-arrow-effect-right is-style-epb-arrow__01\" style=\"padding-top:16px;padding-bottom:16px;padding-left:24px;border-style:solid;border-top-width:0;border-bottom-width:2px;border-left-width:0;border-right-width:0;border-color:#e5e7e8\"><div class=\"epb-linkcard_heading\"><div class=\"epb-linkcard_title\" data-fontweight=\"normal\" style=\"--epb-title-font-sp:16px;--epb-title-font-tablet:16px;--epb-title-font-pc:16px;letter-spacing:0.04em;color:#333333\">What You Should Know About Canine Food Allergies Before Developing Dog Food<\/div><\/div><\/div><\/a><\/div>\n","protected":false},"excerpt":{"rendered":"<p>\u201cA lot of dogs are allergic to chicken, so please take out every chicken-related ingredient.\u201d When we are approached about dog food formulated with allergies in mind, the conversation often opens with exactly that sentence. The question that always follows is how far \u201cevery\u201d goes. Chicken meat, poultry meal, chicken fat and egg are all [&hellip;]<\/p>\n","protected":false},"author":5,"featured_media":48771,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"emanon_ad_label_edit":"no_display","emanon_featured_entry":"","emanon_hide_featured_image":"","emanon_disabled_overlay":"","emanon_hide_title":"","emanon_hide_sidebar":"","emanon_hide_breadcrumb":"","emanon_hide_toc":"","emanon_hide_sns":"","emanon_hide_follow":"","emanon_hide_author_card":"","emanon_hide_entry_tag":"","emanon_hide_pre_nex":"","emanon_hide_related_post":"","emanon_hide_ad":"","emanon_disabled_background_color":"","emanon_hide_floating_hamburger_menu":"","emanon_hide_footer_section":"","emanon_hide_fixed_footer_menu":"","get_emanon_reviewer_name":[],"emanon_subtitle":"","emanon_cta_id":"","emanon_cta_floating_id":"","emanon_cta_newsletter_id":"","emanon_noindex":"","emanon_nofollow":"","emanon_meta_description":"Dog food for suspected chicken allergy: how meat, poultry meal, chicken fat and egg differ, what residual-protein evidence does not settle, and the process control behind a labelling claim.","footnotes":""},"categories":[12],"tags":[],"class_list":["post-48767","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-ingredients-formulation"],"_links":{"self":[{"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/posts\/48767","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/users\/5"}],"replies":[{"embeddable":true,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/comments?post=48767"}],"version-history":[{"count":4,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/posts\/48767\/revisions"}],"predecessor-version":[{"id":48772,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/posts\/48767\/revisions\/48772"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/media\/48771"}],"wp:attachment":[{"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/media?parent=48767"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/categories?post=48767"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/first-reach.org\/en\/wp-json\/wp\/v2\/tags?post=48767"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}