Pet Businesses — Why Does Pet Food Require Food Manufacturing Registration?

Hello, this is Administrative Agent Jean.

Over the weekend, on my way to Itaewon, I came across an unmanned tobacco store.
Near university areas, I also noticed more unmanned claw machine shops.

New forms of business are growing quickly: unmanned stores, drones, game development, AI services, pet businesses, and shared kitchens. At first glance, it is easy to think, “Business registration should be enough.” In reality, however, many of these businesses require separate registration, permission, or notification.

Licensing and permits are often called the heart of administrative agent work.
In this series, we are looking at licensing procedures that are easy to miss when starting a new type of business, and where an administrative agent can help.

1. Unmanned stores — 3 licensing issues people often miss
2. Drone business — 3 registration steps before business registration
3. Game development — required registration before uploading to app stores
4. AI services — one business code can determine eligibility for government support
5. Pet businesses — why pet food may require food manufacturing registration ← This article
6. Shared kitchens — licensing changes once the structure becomes outsourced

Read Part 1: https://blog.naver.com/attorney_jean/224335126223
Read Part 2: https://blog.naver.com/attorney_jean/224339040711
Read Part 3: https://blog.naver.com/attorney_jean/224346285490
Read Part 4: https://blog.naver.com/attorney_jean/224357704165

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A wants to make and sell handmade dog treats.

The product is dried chicken breast made into jerky. A goes to the tax office and registers the business as “pet supplies retail.” A uploads photos to Instagram and starts taking orders.

“Handmade” “Homemade” “The same thing I feed my own dog”

The response is good.
Within two weeks, 50 orders come in.

But in the third week, an acquaintance says:

“Shouldn’t you first register as a feed manufacturer under the Feed Management Act?”

A is surprised.

“I’m not making feed. I’m making treats. Why would the Feed Management Act apply?”

It may apply.

The Feed Management Act defines “feed” as something that provides nutrition to animals or is necessary for their health maintenance or growth. Pet treats may fall within this scope.

Whether it is a treat or a main meal, if you make and sell something animals eat, you should first check whether the Feed Management Act applies.

Unregistered manufacturing and sales are not just an administrative mistake.
They can lead to criminal penalties under the Feed Management Act.

In September 2025, Jeonbuk State publicly reminded pet cafes that pet treats can also be considered feed and that feed manufacturing registration may be required. Reports have also pointed out cases where pet beverages and desserts such as “dog-puccino” or “dog-gelato” were manufactured and sold without feed manufacturing registration.

This is separate from food service business licensing, such as cafe business notification.
The act of making and selling something for companion animals to eat may itself be subject to the Feed Management Act.

According to the Ministry of Agriculture, Food and Rural Affairs, the number of households raising companion animals in Korea nearly doubled from 3.64 million in 2012 to 6.74 million in 2024. As of the end of 2024, the companion animal population reached 15.46 million, about 30% of the total population, and registered companion animals continued to increase.

Companion animal-related businesses are also growing quickly. The market is expected to expand from about KRW 4 trillion in 2023 to around KRW 6 trillion by 2027.

The market is growing, but many people still start without knowing which laws apply.

Today, let’s organize the boundary into three points.

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1. Why Do I Need Feed Manufacturing Registration If I Make Pet Treats?

The legal basis is Article 8(1) of the Feed Management Act.

Anyone who intends to operate a feed manufacturing business must register with the provincial governor or metropolitan authority in accordance with the relevant rules.

The key point is that this is not tax office business registration.

Feed manufacturing registration is a separate registration with the relevant livestock or feed department of the metropolitan or provincial government.

Also, the law generally does not distinguish “feed” and “treats” based only on what the seller calls the product. If the product is something a companion animal eats, you should first review whether it qualifies as feed under the Feed Management Act.

A September 2025 amendment to the Feed Standards and Specifications further subdivided companion animal feed into categories such as complete feed, nutrition-control feed, diet-control feed, and treats. But regardless of the category, if the structure involves manufacturing and sales, registration and labeling obligations must be checked.

What Must Be Checked for Feed Manufacturing Registration

| Requirement | Details | Note | |---|---|---| | Manufacturing facilities | Facility standards for manufacturing and storage must be met | A home kitchen may not satisfy the standards | | Quality inspection system | Self-quality inspection or other inspection system | Product safety management required | | Feed ingredient registration | Ingredients and components must be registered by product | Manufacturing description and test report may be required | | Labeling obligation | Ingredient registration number, feed name, ingredient name, expiration date, manufacturer information, etc. | Must be reflected in packaging design |

The point many people miss is feed ingredient registration.

For domestically manufactured feed such as handmade treats, the following process may be required:

1. Submit a feed ingredient registration application
2. Prepare a product-specific manufacturing method description
3. State which ingredients are used, in what ratio, and by what process
4. Obtain an analysis report from a feed testing institution
5. For animal protein, separately indicate the heat-treatment process
6. Receive suitability review from the relevant metropolitan or provincial department
7. Reflect ingredient registration and labeling information on the packaging

In other words, even selling one chicken breast jerky product may involve a manufacturing method description, testing institution analysis, ingredient registration, and packaging label review.

Facility standards are also a major barrier.

A home kitchen often cannot satisfy feed manufacturing facility standards. Manufacturing and storage facilities may need to be separated, and quality inspection systems may also be required.

Suppose you are making dog treats at home and selling them through Instagram.

You may be using “handmade” and “homemade” as marketing points, but legally, several issues may arise at the same time:

• Unregistered feed manufacturing
• Unregistered feed ingredients
• No feed testing or analysis
• Incomplete packaging labels

Registration is not the end either.

If standards for harmful substances such as heavy metals, pesticide residues, mycotoxins, veterinary drugs, or preservatives are violated, heavier sanctions may apply.

Here is a summary by violation type.

| Violation | Legal Basis | Penalty or Sanction | Type | |---|---|---|---| | Unregistered feed manufacturing business | Feed Management Act Articles 8 and 34 | Up to 1 year imprisonment or fine up to KRW 10 million may apply | Criminal | | Violation of harmful substance standards | Provisions on harmful feed under the Feed Management Act | Up to 3 years imprisonment or fine up to KRW 30 million may apply | Criminal | | Missing or incorrect labeling | Labeling obligations under the Feed Management Act | Administrative disposition and criminal penalty may apply | Administrative and criminal | | Failure to register feed ingredients | Feed ingredient registration provisions | Administrative disposition and criminal penalty may apply | Administrative and criminal | | Sale of feed past expiration date | Sales restriction provisions under the Feed Management Act | Up to 1 year imprisonment or fine up to KRW 10 million may apply | Criminal |

Pet food may begin as a cute brand, but legally it is a feed manufacturing and sales business.

That is why the licensing structure should be checked from the beginning.

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2. Why Does the Food Sanitation Act Apply If I Say “Human Grade”?

This is the most confusing point and the part where costs can increase quickly.

If pet feed is labeled with expressions such as “food edible by humans,” “human grade,” or “Human Grade,” looking only at the Feed Management Act may not be enough.

The moment you claim that humans can eat it, standards under the Food Sanitation Act and other human food-related laws may also become relevant.

In other words, if you want to use “human grade” for pet food, you need to review both sides.

| Labeling | Applicable Laws | Permit or Review Issue | |---|---|---| | General pet food | Feed Management Act | Feed manufacturing registration, feed ingredient registration, labeling | | Human-edible or human-grade labeling | Feed Management Act + Food Sanitation Act, etc. | Feed manufacturing registration + whether human food manufacturing standards are met | | Organic labeling | Feed Management Act + environment-friendly agriculture and fishery laws, etc. | Feed manufacturing registration + organic certification review |

For example:

You plan to launch a premium pet food brand.
The core marketing phrase is “made only with ingredients humans can eat.”

You finish the package design and print 5,000 packages. The cost is KRW 3 million.

But later, you discover that the “Human Grade” label was used without satisfying Food Sanitation Act standards.

The result may be disposal and reprinting of all packaging.

The printing cost is not the only problem.
If products have already been distributed, product recall may also need to be reviewed.

There is one more point that is easy to miss.

If food for humans and feed for companion animals are produced in the same workplace, HACCP certification may need to be reviewed separately.

Food HACCP and feed HACCP are separate systems.
The responsible agencies and standards are different.

You should not assume that food HACCP automatically covers feed.

The pet food market is becoming more premium. Functional feed, premium treats, customized diets, and human-grade labeling are increasing.

But one label phrase can connect to the Feed Management Act, Food Sanitation Act, and advertising regulations.

Considering the amended standards scheduled for full enforcement in September 2028, it is better to organize packaging language and labeling requirements while preparing the brand now.

Before starting a pet business, check whether the Feed Management Act, Food Sanitation Act, or Animal Protection Act applies.

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3. Pet Sitting, Pet Grooming, and Animal Sales — Where Is Permission Required?

Pet food is not the only issue.

The entire pet business sector has different registration, notification, and permission structures depending on the business type.

After the full amendment to the Animal Protection Act took effect on April 27, 2023, regulation of companion animal businesses became stronger. Some businesses that were previously registration-based were converted to permission-based businesses.

| Business Type | Permit or Registration | Legal Basis | Note | |---|---|---|---| | Animal sales business | District office permission | Animal Protection Act | Strengthened from registration to permission | | Animal import business | District office permission | Animal Protection Act | Strengthened from registration to permission | | Animal funeral business | District office permission | Animal Protection Act | Strengthened from registration to permission | | Animal production business | District office permission | Animal Protection Act | Breeders, etc. | | Animal grooming business | District office registration | Animal Protection Act | Registration | | Animal consignment management business | District office registration | Animal Protection Act | Pet sitter, pet hotel, etc. | | Animal transportation business | District office registration | Animal Protection Act | Registration | | Animal exhibition business | District office registration | Animal Protection Act | Registration |

Permission and registration have different legal weight.

Registration is closer to filing once certain requirements are met, but permission requires passing administrative review. If the requirements are not met, the business cannot begin.

Sanctions also differ between unpermitted and unregistered operation.

| Violation | Legal Basis | Penalty or Sanction | |---|---|---| | Unpermitted animal sales, import, funeral, or production business | Animal Protection Act | Up to 3 years imprisonment or fine up to KRW 30 million may apply | | Unregistered animal grooming, consignment management, transportation, or exhibition business | Animal Protection Act | Administrative fine up to KRW 5 million may apply | | Violation of prohibition on breeding or giving birth for dogs and cats under 12 months | Animal Protection Act | Criminal fine may apply | | Violation of prohibition on selling dogs and cats under 2 months | Animal Protection Act | Criminal fine may apply | | Abandonment of companion animals | Animal Protection Act | Criminal fine may apply |

For example, suppose you want to start as a pet sitter.

You provide paid care for someone else’s companion animal.
This may fall under animal consignment management business under the Animal Protection Act, and district office registration may be required.

You may think, “I am just doing this as a small side job.”

But if the service is provided repeatedly for payment, it may be considered a business.
The boundary between one-time help and business is usually judged by repetition and profit-making nature.

What if you start as a pet sitter and then expand into selling pet supplies?

Animal consignment management business registration may be required, and animal sales business permission may also become an issue separately. If one part is missing, that part of the business may be illegal.

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Does This Apply to You?

If two or more of the following apply, you should review your permits and registrations.

• You are making and selling, or preparing to make and sell, pet treats or feed.
• You have never registered as a feed manufacturer.
• You have never registered feed ingredients or obtained feed testing analysis.
• You use or plan to use terms such as “handmade,” “homemade,” or “human grade.”
• You sell through Instagram, Smart Store, or another online channel.
• You also operate another pet business such as pet sitting, pet grooming, or animal sales.
• You do not know whether OEM manufacturing or in-house manufacturing is better.
• You do not know the difference between feed HACCP and food HACCP.
• You are designing product labels yourself.

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This Is the General Rule So Far

The points that can be stated clearly are as follows:

• Manufacturing and selling companion animal treats or feed may require feed manufacturing registration under the Feed Management Act.
• Unregistered manufacturing and sales can lead to criminal penalties.
• Violation of harmful substance standards may be more heavily sanctioned than unregistered operation.
• Feed ingredient registration may require a manufacturing method description and analysis results from a testing institution.
• Human-edible or human-grade labeling may require review under both the Feed Management Act and human food-related laws such as the Food Sanitation Act.
• If food and feed are produced in the same workplace, HACCP may need to be reviewed separately.
• Animal sales, import, funeral, and production businesses are permission-based.
• Animal grooming, consignment management, transportation, and exhibition businesses are registration-based.
• Online sales may require separate mail-order business notification.
• OEM sales structures may require specialized distribution seller labeling.

The following points require individual review:

• Whether your product qualifies as feed
• Whether it is a toy or decoration, or a product animals eat
• What Food Sanitation Act standards must be met if “human grade” labeling is used
• Whether in-house manufacturing or OEM manufacturing is more appropriate
• Whether the OEM manufacturer handles ingredient registration and labeling
• Which feed testing institution should analyze the product
• Whether separate registration or permission is needed for multiple businesses such as pet sitting, grooming, or animal sales
• Whether animal health-related services may constitute veterinary practice under the Veterinarians Act
• Whether online sales require mail-order business notification

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Where Do People Get Stuck When Preparing Alone?

Let’s return to A’s case.

A realized the issue after selling 50 handmade treat orders through Instagram. To correct the process later, A would need to review the following steps.

1. Stop sales
   Products already sold may have been sold in an unregistered state.

2. Decide the manufacturing structure
   If a home kitchen cannot meet facility standards, choose between securing a proper facility and OEM manufacturing.

3. Request analysis from a feed testing institution
   Ingredient and component analysis may be required.

4. Prepare a manufacturing method description
   The document must explain which ingredients are used, in what ratio, and through what process.

5. Register feed ingredients
   File registration with the relevant metropolitan or provincial authority using the analysis report and manufacturing method description.

6. Register as a feed manufacturer
   If manufacturing in-house, check facility standards and apply for registration.

7. Reflect required labeling on packaging
   Include ingredient registration number, feed name, ingredient name, expiration date, manufacturer information, etc.

8. Review mail-order business notification
   Separate notification may be required for online sales.

9. Review human-grade labeling
   If using this expression, check Food Sanitation Act and related standards.

A business can appear to operate simply by uploading photos to Instagram and shipping packages.
But legally, these procedures may need to come first.

What would have been different if A had checked with an administrative agent from the beginning?

The first step would have been deciding whether in-house manufacturing or OEM manufacturing was the right structure.

| Category | In-House Manufacturing | OEM Manufacturing | |---|---|---| | Feed manufacturing registration | Required under A’s name | OEM manufacturer’s registration may be used | | Facility standards | A must meet standards directly | OEM facility is used | | Initial cost | High | Relatively low | | Feed ingredient registration | A handles directly | OEM may support or use existing registered ingredients | | Labeling obligation | A’s information must be displayed | OEM and A information may need to be displayed together | | Quality control | Direct control | Depends on OEM manufacturer | | HACCP | If required, A bears the burden | OEM certification may be used if held |

The 2025 amendment to the Feed Standards and Specifications also made the concept of a specialized distribution seller important.

If a company does not directly manufacture but distributes and sells products under its own brand through OEM, it may qualify as a specialized distribution seller. From September 2028, the name of this seller may need to be separately displayed on the product package.

If A sells “my brand” treats through OEM, this point should be reflected in packaging from the beginning.

Some OEM manufacturers provide ingredient registration and label review as a package, while others only manufacture. Which OEM partner you choose can completely change the difficulty of compliance.

If you choose an OEM that supports ingredient registration, A may not need to personally request analysis from a feed testing institution. But if the OEM only manufactures, A must handle ingredient registration, label design, and specialized distribution seller labeling.

Making this decision in advance is the key to avoiding a situation where all packaging must be discarded later because labeling standards were violated.

Therefore, if A was making handmade treats at home and cannot meet facility standards, switching to OEM manufacturing may be more realistic.

But OEM cannot be chosen casually.

The following must be checked:

• Whether the OEM manufacturer has feed manufacturing registration
• Whether the OEM manufacturer has feed HACCP certification
• How quality responsibility is allocated in the outsourcing agreement
• How A’s brand and the OEM manufacturer should be displayed together
• Who handles ingredient registration
• Who is responsible for label review
• How specialized distribution seller labeling will be reflected

OEM selection, outsourcing agreement review, feed ingredient registration, label design, specialized distribution seller labeling, feed manufacturing registration, and mail-order business notification should be handled as one connected flow.

If each item is searched and handled separately, the order can get tangled.
If the order gets tangled, you may finish the packaging only to discard all of it due to labeling violations.

Jeonbuk State has already begun enforcement, and the National Agricultural Products Quality Management Service has repeatedly conducted special inspections of online feed sales.

If you are selling without registration, you may be included in an inspection. Registering after detection and registering before detection are very different.

After detection, an administrative disposition record may remain.
That record can disadvantage you later when applying for government support, signing franchise agreements, or entering major distribution channels.

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What Changes When You Work With an Administrative Agent?

Pet businesses often involve several overlapping laws.

• Feed Management Act
• Food Sanitation Act
• Animal Protection Act
• E-commerce and mail-order business regulations
• Veterinarians Act
• Labeling and advertising regulations

The key is not simply filing one document.

The business structure must be reviewed first.

1. Whether the product qualifies as feed
2. Whether it is in-house manufacturing or OEM manufacturing
3. Whether feed manufacturing registration is required
4. Who must handle ingredient registration
5. Whether packaging labels are correct
6. Whether human-grade labeling is permissible
7. Whether pet sitting, grooming, or animal sales are operated together
8. Whether online sales notification is required
9. Whether there is risk of being treated as veterinary practice

Under Article 2 of the Certified Administrative Agents Act, preparing and submitting documents to administrative agencies can fall within the scope of administrative agent work.

Feed manufacturing registration, feed ingredient registration, animal business registration or permission under the Animal Protection Act, and mail-order business notification are all connected to documents submitted to administrative agencies.

Check first, for free, which laws apply to the pet business you are preparing.

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Preparing a Pet Business?

A pet business can start small and cute.
But legally, it is not light.

Pet treats may be feed under the Feed Management Act, and human-grade labeling may connect to the Food Sanitation Act. Pet sitting may be animal consignment management business, pet grooming may be animal grooming business, and animal sales may require permission.

Business registration may be the starting point.
But in pet business, it is not the end.

Check at least the following questions:

• Does the product I make qualify as feed?
• Is feed manufacturing registration required?
• Are feed ingredient registration and testing required?
• Is home manufacturing possible under facility standards?
• Is OEM manufacturing more realistic?
• Do the package labels meet legal standards?
• Can I use human-grade labeling?
• Which is needed, feed HACCP or food HACCP?
• Is registration or permission required for pet sitting, grooming, or animal sales?
• Is mail-order business notification required for online sales?

Checking these questions first is much safer than stopping sales later, discarding packaging, and starting the registration process again.

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The next article is Part 6: Shared Kitchens — Licensing Changes Once the Structure Becomes Outsourced.

Did you know that if you prepare kitchen facilities and rent space to delivery food founders, it may need to be registered not simply as a leasing business but as a shared kitchen operation?

Unregistered operation by the operator can affect the legality of every tenant’s business structure. We will cover that structure in the next article.