Always read the label – experts guide us through equine healthcare products
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By Lissa Oliver
We all want what’s best for our horse and we are happy to pay a price for the benefit of a happy, healthy and peak-performing horse. But what if that price is a hefty fine, suspension or even serious health consequences for us and our staff? How much trust can we afford to place in the claims of manufacturers, and do we pay enough attention to instructions?
Ultimately, the responsibility for what goes into our horses lies fully with us. In this article, we’ll focus on the nutritional product labelling as well regulation of products which are promoted to consumers.
Nutrition
Dr Corinne Hills is an equine veterinarian with more than 20 years’ experience in practice in Canada, the Middle East, Europe, New Zealand and Australia, leading her to develop Pro-Dosa BOOST, manufactured from her own purpose-built, GMP-registered laboratory in New Zealand.
Ingredient listings
“We all want to make good choices and support our horses in the best way we can, with the best use of our finances,” Dr Hills agrees. “Horsemen always ask me about ingredients, but nobody ever asks about quality management. Similar products might appear to contain the same ingredients, but if the quality of the ingredients is poor, they will provide no benefit. Think about what you are spending your money on, and learn to read labels critically.
“It’s important to know the nutrient content of your feed and forage. In a perfect world everyone would consult their nutritionist and have forage tested, knowing exactly what their horse requires, what it is receiving and what supplements, if any, are needed. Horsemen don’t always feed a ready-prepared balanced feed. If they are mixing their own, they should be analysing the components of their feed. It’s easy and inexpensive, and your vet will know where you can send samples for analysis. Good feed companies provide the service for free.
“Simply reading the label of feed and supplements could save you quite a bit of money. In my experience most people way over-supplement. A balanced feed manufactured by a reputable company should provide all of a horse’s requirements. Adding supplements could disturb the balance of the nutrients being fed. It is worth taking the time to understand nutrition to effectively support equine health. You can go to your feed company and ask their in-house nutritionist to suggest a tailored balanced diet that will suit most horses in your stable. If the feed company doesn’t have a nutritionist, it might be worth looking around for a new feed supply.
“Metabolism is quite complex, requiring a broad range of essential nutrients to function optimally. A lot of one nutrient doesn’t make up for deficiencies in another. The balance between nutrients is important. Some nutrients are required for the uptake and function of other nutrients. Too much or too little of one nutrient may result in deficiencies or toxicities of other nutrients. Imbalances can adversely affect health, performance and recovery. At a minimum, imbalances in a feed or supplement can render a product ineffective.
“For instance, vitamin C is required for the absorption of iron from the gut. Without vitamin C, iron passes straight through the gut and out in the faeces. Vitamin E, on the other hand, has a negative interaction with iron. It binds with iron and reduces its absorption, causing much of it to be wasted. So, in order for horses to use dietary iron effectively, it must be administered with vitamin C and without vitamin E. Iron balance is also closely related to zinc, manganese, cobalt, and copper.”
Nutrients Ratio
Ca:P 1-2:1
Zn:Mn 0.7-1.1
Zn:Cu 3-4:1
Fe:Cu 4:1
“B vitamins are known to work better when administered in optimal balance with each other. Amino acids are another good example of how nutrient balance is important. The balance of amino acids in a feed is as important as the amount of protein. Imbalances in amino acids limit the amount of protein in a feed that is usable in the horse to produce proteins and muscle cells, and the wasted amino acids that can’t be used for protein synthesis create a load on kidneys, elevate body temperature and elevate heart rates.
“It is also important to adhere to the instructions on the label. If insufficient doses are given, then no impact or a negative impact on the overall health of horses may result.
“If you are buying a supplement that doesn’t contain what the label says, then at best, it’s a waste of money. At worst, it could be detrimental to your horses’ health. Giving too much of some nutrients is dangerous.”
Reading the label isn’t always an easy fix, however, as Dr Hills points out.
“Standing in a feed store, I couldn’t easily choose a good one as I couldn’t work out what was in each one by just looking at the labels. I had to photograph the labels and then put the information into a spreadsheet, convert all the quantities and units to a single standard, and then compare those contents to equine nutrient requirements.
“How many horsemen do that? And if they don’t know what they are feeding their horses, aren’t they worried?”
Dr Hills has one simple tip. “If labels are easy to understand so that you can tell at a glance what you are giving your horse, then the manufacturer is probably proud of their formulation and believe it will stand up to scrutiny.
“If you have to perform too many calculations to figure out what you are giving, there is a fair chance that the formulation isn’t great. Some companies don’t actually want you to know how much or little of each nutrient is in their product. Take the time to do the maths and make sure you are making a true comparison before picking the cheapest or prettiest product on the shelf.
“When reading labels, it is important to consider all aspects of the nutrient composition—including balance, form and dose—in relation to the nutrient requirements of your horse.
“I found a huge number of products listing different combinations of nutrients that were included in different forms. For example, calcium could be provided as calcium carbonate, tricalcium phosphate, or calcium gluconate. They were also quantified with different units of measure, such as mg/kg, %, ppm, to name only a few. Then, they were to be given in different doses.
“The most confusing paste I found listed contents in terms of parts per million (ppm), percentages, and mg/kg. Then, the syringe was in pounds and the recommended dose in ounces.”
Quality control
“How do you know if a product is manufactured safely and meets label claims?” Dr Hills asks. “This information frequently isn’t on the label, but it’s just as important as the ingredients list; so it’s well worthwhile to make the effort to source the information.
“You could look for a statement on the website about quality management, or you might have to ask the manufacturer some questions. Does the manufacturer have a quality management programme? GMP or ISO certification provides hard evidence of this.
“Be sure to ask every rep that visits your stable about quality management as they will almost certainly be the most readily available source for this information. Any rep that can’t talk competently about their company’s quality management programme probably represents a company that doesn’t have one.
“GMP stands for Good Manufacturing Practice, and this is a specific standard required for pharmaceutical producers. It is, however, voluntary for feed supplement manufacturers. A generic version of good manufacturing practice, abbreviated with small “gmp,” is a reference to a quality management system that is not government specified and inspected. It could be the same as GMP or it could be applied to a non-standardised or less complete quality system.
“If a company has either ISO or GMP certification, you can be sure that the supplements they produce will be safe, secure and generally meet label claims.
“Once you have selected a good quality, safe and healthy feed, then you can probably feed it to most of the horses at your stable. Spelling horses and smaller horses will need to eat less of it with more hay or grass. Racehorses or broodmares will need to eat more of it.”
Veterinary Medicines Directorate
The Veterinary Medicines Directorate (VMD) is the regulator of veterinary medicines in the UK. Louise Vodden and James Freer, from the Enforcement Department of the VMD, guide us through the draft documentation outlining the legislation behind the manufacture, sale and labelling of equine health and welfare products.
Guidance for advertising non-medicinal veterinary products
When advertising a non-medicinal veterinary product, it must not, by presentation or claims, suggest that it is medicinal.
This applies to any advert—be it in magazines, online, at trade events or through client meetings and listing materials—that is aimed in part or in full at a UK audience. It is the responsibility of anyone engaged in marketing activities to comply with the VMD.
A veterinary medicinal product is legally defined as:
Any substance or combination of substances presented as having properties for treating or preventing disease in animals.
Any substance or combination of substances that may be used in, or administered to, animals with a view either to restoring, correcting or modifying physiological functions by exerting a pharmacological, immunological or metabolic action, or to making a medical diagnosis.
Medicinal by presentation
The first part of the definition above covers products that indicate they have a beneficial effect on an animal’s state of health. This is known as “medicinal by presentation”.
Prevention
This includes the destruction of parasitic infestations on an animal that may cause a medical condition, such as flea allergic dermatitis; hence, products that kill fleas on an animal are also classified as medicines.
Disease
This is considered to cover a broad range of conditions ranging from those caused by bacterial, viral or parasitic infections, to disorders resulting from various systemic dysfunctions, or deficiencies of substances essential for survival. We generally use the catch-all term “adverse health condition” for something wrong with an animal’s state of health. This includes injuries that pose a significant risk to wellbeing or would require more than the most superficial of management.
Medicinal by function
The second part of the definition covers two further aspects. The first relates to products containing substances with a recognised medicinal effect, commonly referred to as “medicinal by function”. The second covers the purpose of putting something in, or on, an animal to effect a change (restoring, correcting, modifying) in the way a bodily system works.
Restoring
This covers claims of restoration of function in any system within an animal that, for any reason, is not functioning within the normal range for an animal of good health. Even if there is no claim, be careful not to present before and after treatment expectations in your advert. For example, in one picture the dog can barely walk, and in another the same dog scampering along apparently healed. Such an advert would be considered medicinal by presentation.
Correcting
This covers any product used to address any deficiency or dysfunction in an animal’s systems. This includes issues like nutritional deficiencies in an animal, hormone imbalances, immunomodulation to address allergic reactions and correction of digestive dysfunction.
Modification
This includes any effect that changes the way an animal functions that is not covered by restoration or correction effects. In most cases, these tend to be enhancement claims such as “boosting”, “better”, “stronger”. Where such claims are made, the immediate question is, “better than what?” If the answer is, “better than normal,” then the product is considered medicinal by presentation. If the answer is, “better than an animal with condition X,” then it is considered as claiming to be medicinal by function.
Making medicinal claims
Non-medicinal products cannot claim to treat, prevent or control any adverse health condition. Nor can it refer, expressed or implied, to the treatment or prevention of a disease or adverse condition, or to improving the state of health of the animal treated.
For example, medicinal claims include a reference to the treatment or prevention of scours, colic, footrot, laminitis, sweet itch or pathological nervous conditions—or any other condition which is not the normal state of a healthy animal. This includes references to symptoms or any indication that the product is for use in an animal which is not in a normal healthy state.
References to the nutritional maintenance of a healthy animal, healthy digestive system or healthy respiratory system would not normally be regarded as medicinal claims. Though this does not extend to claims for preventing the occurrence of an adverse health condition or its symptoms.
Any implication that the product for use in an unhealthy animal and is intended for purpose of, or has the consequential outcome of, preventing a detrimental health state in an animal would predispose the product for a medicinal purpose for which it would require a marketing authorisation. Exceptions to this include particular nutritional purpose feeds, however, there are also specific restrictions on the claims these products can make.
Things to avoid in the advertising of non-medicinal products
These products can only be presented for the maintenance of health in healthy animals.
The basic premise is that the purchaser of the product has a healthy animal and will be using it to support their animal’s state of health. Health maintenance does not include attempting to halt or slow the progression of a detrimental health state.
Association with an adverse health condition
Narratives may not be used to suggest some terrible disease will or may happen, nor using statements like “4 out of 5 get” to present the product as the solution. This is considered a medicinal claim. Occasionally this approach is prefaced with the overtly medicinal company statement of intent that “we believe prevention is better than cure”.
Reference to specific diseases may be made in the form of a safety warning where use of the product may pose a risk, for example “WARNING: Not to be fed to horses with PPID”.
Comparisons and presentation of equivalency to authorised medicines
A product not authorised as a veterinary medicine must never be presented, in any capacity, in comparison to any form of authorised medication. Marketing material for a non-medicinal product must not indicate or imply that the product can, or is intended to, be used as a substitute for authorised veterinary medicines. Nor should the use of a non-medicinal product be presented as resulting in the reduction of the use of any authorised medication. To do so is considered a medicinal claim for the product.
Disclaimers do not provide a remedy to the misrepresentation of a product in a medicinal capacity.
Testimonials, quotes and endorsements
If customer testimonials are used in connection with the marketing of a product and report results containing medicinal claims, the claims will be regarded as those of the company marketing the product.
Claims made by a third party, such as magazine reviews or articles published by independent analysts, will be regarded as those of the company marketing the product where evidence confirms that the third party has a connection to the marketing company via solicitation, endorsement, sponsorship or funding.
If, for example, a vet who has been using a product for years expresses an opinion that is not being given in support of marketing a product, then it would just be an opinion. Any material published in support of marketing the product is considered to be marketing material. Whether that material is based on professional opinion, peer review studies, customer feedback, folkloric tradition or an “everybody knows”claim is not relevant. It must still adhere to the rules governing marketing material.
Herbal or “natural” products
Herbal products, “nutraceuticals”, or any products sourced in a way generally described as “natural” are treated like any other products. A natural origin provides no exemption from these requirements; they require authorisation if they are medicinal by function or presentation.
Biocides, insecticides and repellents
The following are always medicinal products requiring a marketing authorisation due to their use on animals:
Veterinary product that contains substances that kill insects or external parasites (e.g., pyrethrins, pyrethroids or organophosphate compounds) as they are medicinal by function
Veterinary product claiming to have, or which has, the function and control of internal parasites
Veterinary product claiming to treat or prevent a disease caused by a viral, bacterial or fungal infection
The following do not require an authorisation, provided they do not claim to treat or prevent disease:
Product containing a repellent, such as diethyltoluamide or ethylhexanediol, provided it claims only to repel external insects
Product applied only to housing or bedding
Topical disinfectant applied to intact skin provided it does not claim to treat or prevent disease, including infection prevention (e.g., shampoos)
The marketing of these products is covered by legislation on biocides.
For further information regarding non-medicinal products, email enforcement@vmd.gov.uk or call +44 (0) 1932 338308 or +44 (0) 1932 338410
