This affects all koi foods sold after 1st September 2011.
As koi keepers, we are interested in maintaining the health of our koi. After water quality, the food we feed our koi has the greatest influence on their health, growth and well being. We can take advice from fellow koi keepers and koi dealers as to what food they recommend and use themselves, as well as trying various brands ourselves. Another source of more detailed information when choosing & comparing koi foods is the information found on the label of the food itself.
We are probably quite used to interpreting and understanding the information detailed on koi food packaging, such as the protein content, vitamin levels and any specific ingredients listed in descending order. If you have been a koi keeper for some time, then it is routine to know where to look and how to gain the most useful information from the label.
Unfortunately, due to a new EU regulation (EC 767/2009) introduced on 1st September 2011, the way we read koi food labels is now going to change. All koi food brands have faced extensive costs as they have updated their labels to meet the new regulation by the September 2011 deadline. Against the background of that ‘cost’ it is a challenge to find any real benefits for koi keepers as a result of the new regulation. In fact, it could be argued that the new format gives less useful information than previously and in a form that is now arguably less easy to understand. EC 767/2009 was initially drafted for commercial animal feeds, but ornamental fish foods (and all pet foods) have also been swept along by this legislation.
What has changed?
Some of the changes are cosmetic – being largely changes in wording and headings. Other changes could be misleading.
1. ‘Analysis’ now becomes ‘Analytical Constituents’.
The declaration under ‘Analytical Constituents’ now uses the following headings:
Crude Protein (used to be protein)
Crude Oils and Fats (used to be oil)
Crude Fibres (used to be fibre)
Crude Ash (used to be ash)
Other wording is permitted: Protein, Fat Content and either Incinerated Residue or Inorganic Matter for what was previously described as Ash.
Moisture is to be declared if levels are >14%. As dry koi foods have a moisture content of less than 10% then moisture will not be declared.
2. ‘Ingredients’ now becomes ‘Composition’.
All feed materials used are to appear in descending order and quantified with % inclusion if associated with an on-pack claim (eg ‘with spirulina’).
Ingredients are listed by category (eg meat and animal derivatives) or specific name (eg krill meal). The two methods should not be mixed unless:
a. the feed material does not belong to any categories (eg Herbs)
b. a specific ingredient appears as part of a claim
3. New Section – ‘Additives’
Certain additives that have a legal maximum (due to potential toxicity issues in some animal species – not necessarily koi) now have to be declared when added. For nutritional additives these are currently Vitamin A, Vitamins D2 and D3, Iron, Cobalt, Iodine, Copper, Manganese, Zinc, Molybdenum and Selenium. Manufacturers can also choose to declare other additives – such as Vitamin C.
4. ‘Preservatives, antioxidants and colorants’
Ornamental fish foods are not required to list the nature of the preservative, antioxidant or colorants used in a formulation. This means that you will no longer see the type of preservative, antioxidant or colorant (either natural or artificial), unless a specific claim or % inclusion rate is mentioned on the label as part of a marketing claim.
3 Fundamental and potentially unhelpful changes.
A. Additives (Vitamins and Minerals)
We are used to seeing on a label the level of vitamins that are guaranteed to be present until a ‘vitamins present until’ date. This has now changed as the regulation is now concerned with the levels of vitamins and minerals added (rather than what can be found in the finished food). This gives us less useful information than before.
For example, previously a brand may have declared Vitamin C 300g/Kg within the food. Because a proportion of vitamins are lost during the manufacturing process, an overage would be added – perhaps a total of 400mg/Kg. The new regulation therefore requires the brand to declare the 400mg/Kg even though only 300 mg/kg may be present in the finished food. In this way, we are no longer told the levels of vitamins or minerals our koi can expect to find in the food.
A further area that might mislead is that the label no longer states vitamin levels in the food. As there is no declaration and no vitamin level guarantee, there is no way a food can be tested and be found ‘deficient’ against a level that is no longer stated.
B. No ‘Vitamins present until’ date.
Because there is no longer a declaration of the vitamin levels within the food, there is no requirement for a ‘Vitamins present until’ date. This has been replaced by a Best Before date. Up to that date, the food must offer koi complete nutrition.
C. Mineral declarations
You may be used to seeing minerals such as copper declared on a koi food label (eg Copper 20mg/Kg). The new format labels will declare:
a. How much copper (and other additives) are added – rather than the levels found in the food.
b. The ingredient that is added to contribute the copper into the food (eg copper sulphate pentahydrate (CSP)). To confuse things even further, as the copper content of CSP is only 25% copper, a previous declaration of copper 25mg/Kg will now be a declaration of copper sulphate pentahydrate: 100mg/kg – even though the food and formulation has not changed.
5. Things that have not changed, and will appear the same on the new labels.
Thankfully, there are some details that have not changed on the label. These include:
• Product description including animal species (eg: Complete food for koi)
• Instructions for proper use (feeding guide, storage conditions)
• Batch code and manufacturer’s registration number
• Business address and contact details (website, email address, free phone number etc)
• Net Weight of pack.
In conclusion
The change in labelling brought about by EC 767/2009 is likely to confuse, if we do not appreciate what the new format is now describing. Those who have been using the same food for many years may suddenly see the label declarations of their favourite koi food appear to change. This does not necessarily mean the food has changed, but rather the brand has now changed the label to meet the new regulations. Opinion is very much divided as to whether these changes can be described as progress or a helpful improvement for koi keepers.
