About PFI - Codes
PFI CODE - PRODUCT CONTROL / POLICING
A.1 To on a random basis check that all pet food products in the market meet the necessary registration standards including labeling, nutritional quantitative standard and that the products are what they claim to be with respect to ingredient make-up
A.2 To collect new products, those that appear from time to time on the market and evaluate them as per A.1
A.3 To evaluate those products in the market that is reported as problem products from time to time. Problems being that they are not manufactured to standard or that they have been reported as causing a feed related problem with the pet that has consumed the food. Or there is no indication of the correct mandatory information required on the packaging, including product registration under Act 36, or the claims that appear on the packaging are in your opinion false or misleading.
STEP 1 Sampling
1.1 The PFI Executive or a PFI Member will, on a regular basis:
a) Purchase a new product launched on the market
b) Purchase a reputed poor quality product
c) Purchase a product from the membership of the PFI or non-members.
d) A PFI Member may draw the PFI Executive attention to a product that should in their opinion be investigated, as well for the PFI Executive to proceed further.
e) ALL PURCHASES, by the PFI or by a Member, will be funded by the PFI and so any record of the purchase available must be supplied to the PFI.
1.2 From the bag, draw 3 x 500g samples.
1.3 Mark samples with the product name, bag analysis and other claiming statements.
1.4 Empty the bag and include the empty bag with the samples in a parcel delivered to the PFI
1.5 The PFI Member will either courier samples to the PFI Office via the Post Office (counter to counter) at their expense to: The PFI
P O Box 1027
or, make arrangements with the PFI Executive to collect the samples.
1.6 Any concerned pet owner or non-Member may also send samples to the PFI.
1.7 All costs incurred in this process are refundable from the PFI and should be claimed by presenting the original purchase and postal receipt or invoicing the PFI with the attached proof.
STEP 2 Testing
2.1 PFI Executive to select:
a) All suspected problem products.
b) A selection of competitor products.
(Note: Selection to be on a Rotational basis, according to a register, of all PFI Members.)
2.2 The PFI Executive will supply the samples directly to an approved laboratory for analysis at the PFI’s cost.
The remaining product samples and the empty bag will be kept for future testing and as reference samples, pending the results, either by the PFI or the complainant.
2.3 The type of analysis required is to be requested by the PFI Executive. This will, as a standard, mainly be Protein, Crude Fibre, Crude Fat and Ash for nutritional standard testing. Other tests may be performed upon request, provided there is justification.
2.4 If a PFI Member Company is requested by the PFI Executive, to assist by doing analyses, these tests are at their own cost.
2.5 Results are to be kept confidential and returned to the PFI Executive.
3.1 PFI Executive to collate data.
3.2 Problem products, identified from analysis received, are handled as follows:
Take the remaining sample, if marginal and there is some doubt, and send to another PFI Company or to an approved laboratory for additional testing.
3.3 If the PFI is satisfied that the results are out of specification for product belonging to non-Members of the PFI, will be handled on it’s merits involving either a) or b) or c):
a) Write a letter to Act 36 Registrar, registering an official complaint.
b) Write a letter to the Company whose product was tested advising them of the testing, the results and the pending notification to the Registrar.
c) Lodge a complaint with the ASA
If the product is from a Member of the PFI, write a letter to:
c) The PFI Member / Company whose product has been tested.
(NOTE: withhold the letter to Act 36 Registrar if the sample is from a PFI Member. The PFI Member is to be given time to rectify the problem as per 3.5 and 3.6 below before notifying the Registrar Act 36 or ASA)
The letter must inform of the results and the problems, actions to be taken.
3.4 Arrangements must be made with Act 36/1947 Inspectors to take official samples from the Company, should it be decided to follow the route of notifying Act 36/1947. Note if a known contravention of Act 36 exists the PFI is obliged in terms of the Act to advise the Registrar of Act 36
PFI Members Product
3.5 A problem Member Company will be given time to rectify its products, and informed that re-sampling will take place in 60 days. (Samples will be taken, by the PFI Executive, either, in the market place or at the manufacturing plant).
3.6 The 60 days sample may be tested at any one of the approved laboratories (NLO, ARC, CAL and/or PMB University)
3.7 If the product is still out of specification, inform the company that the problem still continues, and request Act 36 to schedule a plant visit. All product at the company to be sampled, tested and reported.
3.8 If products are found to be out of specification, the company must submit product samples from product produced for a period of 1 month, to be tested continuously to ensure that it remains within specifications. Act 36 is to be supported in the analyses they require.
3.9 If the product is found to be out of specification, request the Registrar to ensure the product is withdrawn from the market place.
3.10 If this is not carried out, PFI is to liaise with the Registrar Act 36 to ensure that prosecution is pursued. But if the product is found to be within specification, a written warning must be served.
3.11 If the product conforms, a 90 day specification check is to be carried out. If the product is “OK”, no further action will be taken. If the product is “not OK”, move straight to Prosecution process as per point 3.9.
4.1 Testing during Step 3 period can be assisted by PFI companies if permitted to reduce cost on the PFI.
[C] OTHER AVENUES OF PROCESS
Consumer complaints and product claims:
A PFI Member can require that a product test is performed according to the steps outlined above, so as to substantiate consumer complaints or product claims.
Advertising Standards Authority:
Should it be justified in the opinion of the Executive Director he may alert the Directors that he proposes to tackle a problem by reporting it to the ASA. This would be in cases such as no action by Act 36 or to enable a problem that is persisting to be quickly brought into the public domain.
[D] PACKAGING, ADVERTISING AND LABEL COMPLAINTS
All complaints with respect to packaging, advertising and label complaints, where these do not conform to Act 36 or standard advertising standards, may be brought to the attention of the PFI Executive. Submit samples of the material against which the complaint has been raised, to the PFI. The PFI Executive needs to check that in terms of Act 36 Regulations there is a valid complaint.
a) PFI Members
Where this involves a PFI Member and the complainant is a PFI Member, the complainant can choose to:
(i) first address the complaint directly with the alleged defaulter
or (ii) request the PFI Executive to address the complaint to the alleged
If no positive corrective action is forthcoming (using the time frames as for specification/analytical complaints) then the PFI Executive must address the complaint in writing to the Act 36 Registrar for his attention and action. (The PFI Executive has an agreed procedure with the Act 36 Registrar in terms of lodging complaints, follow-up on progress with complaints lodged, and report back on the outcome of the action taken with respect to the complaint) All correspondence to the Act 36 Registrar must be copied immediately to the alleged defaulter.
b) Non-PFI Members
A complaint regarding a non-member of the PFI must be brought to the PFI Executive. In this case the PFI Executive will, in writing, inform the Act 36 Registrar of the substance of the complaint directly, and copy this correspondence together with a letter, to the alleged defaulter.