FDA pet food regulations, are they adequate?


Are you concerned about your pet’s nutrition? You are not alone.

Over the last decade, there has been a proliferation of different types of pet food, including plant-based, vegetarian, natural, organic, gluten-free, grain-free, raw diet, a novel protein, and made in the United States.

Some brands promote their pet food as the “healthiest” or most nutritious available, and many of these products can cost twice as much as traditional pet foods.

As a result, pet owners are spending an average of $250 to $300 annually on food for their pets and more than half admit they would spend even more money if they thought it would improve their pet’s health.

Consumers have less faith in pet food labels than in those for human meals.

The United States Food and Drug Administration (FDA) is the federal agency responsible for ensuring product safety and precise labeling of both human and animal foods under the Federal Food, Drug, and Cosmetic Act (FDCA) of 1938.

However, the pet food provisions of this legislation were added in 1960, and the FDA’s Center for Veterinary Medicine (CVM) does not have the same regulatory authority over pet foods as it does human foods.

This is because Congress included a loophole in the FDCA that exempts “customary” or “usual” ingredients from being required to be named on a pet food label.

In the late 1960s, the Association of American Feed Control Officials (AAFCO) a nonprofit organization that establishes “voluntary manufacturing and labeling requirements” for pet food producers, tried to address some of the FDCA’s shortcomings and suggested more detailed definitions and criteria.

The AAFCO continues to develop pet food safety and labeling standards. However, the AAFCO’s standards are not mandatory and only represent the minimum legal requirements for any product listed as “complete and balanced” on a pet food label.

For example, in 2015, the AAFCO revised its definition of “crude protein,” yet this is not implemented into law or regulation.

The AAFCO Model Regulations for Pet Food have been adopted by many states, but enforcement varies because local authorities conduct all enforcement.

After tainted ingredients from China were found to have killed over a dozen dogs and cats and poisoned thousands of others in 2007, calls for federal involvement in pet food regulation increased.

Congress passed the Food Safety and Modernization Act (FSMA), which was signed into law in January 2011.

This legislation mandated the FDA regulate production practices at pet food manufacturing facilities by requiring risk-based preventive controls to guard against adulteration, an act that is likely to cause harm

However, this provision has not been implemented due to disagreements between the FDA and regulation opponents over who should pay for the inspections.

The Preventive Controls for Animal Food Rule, one of the FSMA’s key provisions, requires pet food manufacturers to follow “current good manufacturing practices.”

However, these minimal pet food safety and sanitation standards, including cleaning, pest control, and record-keeping requirements, are only minimum requirements.

Furthermore, certain businesses that manufacture small or homemade batches of pet food are exempt from these regulations.

Pet food companies must keep records about their production process for one year, but the FDA does not verify them or perform unannounced inspections.

Advocates of the FSMA claim that tying pet food safety and sanitation standards to current good manufacturing practices, was a legislative “stroke of genius.”

These supporters say that this link gives manufacturers the flexibility to use modern technology and determine for themselves which safety measures to put in place to assure compliance.

The Pet Food Institute, which is made up of virtually the entire US pet food industry, disagrees. According to the group, while the FSMA is a step in the right direction, FDA has not provided enough information.

The Institute also claims that funding shortages stifle federal oversight and slow downstate regulators who “bear much of FSMA compliance and enforcement.”


Pet food does not require FDA pre-market approval. However, before a brand may use certain components known as “food additives,” they must first obtain authorization from the agency.

FDA, on the other hand, classifies food additives broadly: “any substance that becomes a component of a food or influences a food’s properties directly or indirectly.”

Manufacturers of pet food may avoid the FDA’s procedures for evaluating components that fall under the broad scope of food additives by utilizing substances that are “generally recognized as safe.”

A substance seeking GRAS approval must either have been in animal feed prior to 1958 and commonly used since, or show safety through a scientific study published in a reputable journal.

According to the FDA, the GRAS standard “is more difficult to fulfill than the food additive requirement.”

However, it is ultimately up to each pet food producer to determine whether each component fulfills the GRAS standard or should be considered a “food additive.”

Propylene glycol, for example, was once considered an acceptable ingredient that was “generally recognized as safe.”

However, in 2010, the FDA issued a warning letter stating that propylene glycol was no longer GRAS for use in pet foods.

The agency also said it would take regulatory action against companies continuing to use this ingredient unless they provided evidence of its safety.

After production, pet food must meet a variety of labeling rules under the FDA and the FTC. Pet food packaging must contain certain percentages of named ingredients, the manufacturer’s name and address, and feeding instructions based on the animal’s weight according to FDA rules.

The FTC has published the Dog and Cat Food Guides, which clarify what constitutes a misleading statement on pet food labels and advertisements that will become a pet food scam.

A company’s false claim that its pet food won an award is one example of misrepresentation, as is an incorrect claim that its pet food is “suitable for human consumption.”

As seen in the figures below, however, even when health-related issues arise, pet owners are hesitant to cut costs.

According to a survey by Market Force Strategy (MFS), 33 percent of consumers admitted that they would be willing to pay more for organic food simply because it was healthier for their pets.

However, according to the same study, 61 percent of consumers would not switch brands even if their pets developed food sensitivities.

Some veterinarians, on the other hand, are demanding additional studies of pet food ingredients to prevent harmful products from reaching consumers in the first place.

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