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Most Important Food Safety Regulation in 70 Years Delayed

Most Important Food Safety Regulation in 70 Years Delayed

New food safety regulation is taking more than a year to be approved, frustrating many

Every year, a whopping 48 million Americans are struck by foodborne illness often caused by contamination and mishandling of food. President Obama fought to improve the safety and cleanliness of the nation’s food supply as he signed the Food Safety Modernization Act (FSMA) last year. Although this act has had incredible support by food production companies, consumer health groups, and the government, it has yet to be fully approved. To date, America’s health is still at risk.

The intention of FSMA is to target food at the source and hold food suppliers accountable for distributing clean, safe food under stricter regulations. It will allow the Food and Drug Administration to hire more food-safety inspectors and issue mandatory recalls.

The Office of Management and Budget is responsible for making sure the new law is consistent with administration policies and giving it the final approval before it takes action. But it has been sitting on OMB’s desk for seven months now, and the approval date is unforeseen.

USA Today cites three very important rules that are waiting to be approved.

One of these rules discusses safety standards for sources of contamination, including irrigation water, manure, worker hygiene, and wildlife. Another rule requires foreign suppliers to undergo food safety verification programs to ensure that only safe food is entering the country. The third most important rule demands that food companies have a specific plan to identify and eliminate sources of contamination.

Politicians and food safety groups are outraged by the delay in approval and are pushing Obama to publish the rules. Many are frustrated and confused about the extremely lengthy approval process. But according to an OMB spokesperson, the approval has been delayed because they recognize the great importance of this regulation. They want a law of this gravity and complexity to be flawless.


Regulation

In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

Ingredients Used in Pet Food

An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

Federal Regulation

The Food Safety Modernization Act

With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

With few exceptions, just as with human food, FSMA requires pet food makers to:

  • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
  • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
  • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
  • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

Click here for more information on FSMA requirements related to pet food.

PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

State Regulation

Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

States requirements for those following the AAFCO models include:

  • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
  • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
    • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
    • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
    • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
    • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
    • Provision of calorie content.
    • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
    • Name and address of manufacturer/distributor.
    • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

    States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

    State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

    Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


    Regulation

    In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

    Ingredients Used in Pet Food

    An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

    Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

    An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

    Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

    In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

    Federal Regulation

    The Food Safety Modernization Act

    With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

    The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

    With few exceptions, just as with human food, FSMA requires pet food makers to:

    • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
    • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
    • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
    • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

    Click here for more information on FSMA requirements related to pet food.

    PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

    State Regulation

    Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

    States requirements for those following the AAFCO models include:

    • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
    • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
      • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
      • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
      • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
      • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
      • Provision of calorie content.
      • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
      • Name and address of manufacturer/distributor.
      • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

      States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

      State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

      Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


      Regulation

      In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

      Ingredients Used in Pet Food

      An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

      Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

      An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

      Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

      In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

      Federal Regulation

      The Food Safety Modernization Act

      With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

      The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

      With few exceptions, just as with human food, FSMA requires pet food makers to:

      • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
      • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
      • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
      • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

      Click here for more information on FSMA requirements related to pet food.

      PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

      State Regulation

      Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

      States requirements for those following the AAFCO models include:

      • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
      • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
        • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
        • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
        • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
        • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
        • Provision of calorie content.
        • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
        • Name and address of manufacturer/distributor.
        • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

        States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

        State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

        Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


        Regulation

        In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

        Ingredients Used in Pet Food

        An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

        Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

        An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

        Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

        In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

        Federal Regulation

        The Food Safety Modernization Act

        With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

        The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

        With few exceptions, just as with human food, FSMA requires pet food makers to:

        • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
        • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
        • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
        • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

        Click here for more information on FSMA requirements related to pet food.

        PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

        State Regulation

        Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

        States requirements for those following the AAFCO models include:

        • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
        • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
          • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
          • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
          • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
          • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
          • Provision of calorie content.
          • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
          • Name and address of manufacturer/distributor.
          • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

          States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

          State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

          Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


          Regulation

          In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

          Ingredients Used in Pet Food

          An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

          Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

          An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

          Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

          In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

          Federal Regulation

          The Food Safety Modernization Act

          With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

          The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

          With few exceptions, just as with human food, FSMA requires pet food makers to:

          • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
          • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
          • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
          • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

          Click here for more information on FSMA requirements related to pet food.

          PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

          State Regulation

          Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

          States requirements for those following the AAFCO models include:

          • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
          • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
            • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
            • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
            • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
            • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
            • Provision of calorie content.
            • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
            • Name and address of manufacturer/distributor.
            • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

            States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

            State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

            Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


            Regulation

            In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

            Ingredients Used in Pet Food

            An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

            Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

            An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

            Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

            In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

            Federal Regulation

            The Food Safety Modernization Act

            With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

            The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

            With few exceptions, just as with human food, FSMA requires pet food makers to:

            • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
            • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
            • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
            • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

            Click here for more information on FSMA requirements related to pet food.

            PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

            State Regulation

            Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

            States requirements for those following the AAFCO models include:

            • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
            • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
              • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
              • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
              • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
              • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
              • Provision of calorie content.
              • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
              • Name and address of manufacturer/distributor.
              • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

              States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

              State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

              Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


              Regulation

              In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

              Ingredients Used in Pet Food

              An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

              Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

              An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

              Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

              In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

              Federal Regulation

              The Food Safety Modernization Act

              With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

              The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

              With few exceptions, just as with human food, FSMA requires pet food makers to:

              • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
              • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
              • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
              • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

              Click here for more information on FSMA requirements related to pet food.

              PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

              State Regulation

              Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

              States requirements for those following the AAFCO models include:

              • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
              • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
                • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
                • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
                • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
                • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
                • Provision of calorie content.
                • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
                • Name and address of manufacturer/distributor.
                • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

                States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

                State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

                Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


                Regulation

                In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

                Ingredients Used in Pet Food

                An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

                Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

                An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

                Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

                In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

                Federal Regulation

                The Food Safety Modernization Act

                With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

                The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

                With few exceptions, just as with human food, FSMA requires pet food makers to:

                • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
                • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
                • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
                • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

                Click here for more information on FSMA requirements related to pet food.

                PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

                State Regulation

                Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

                States requirements for those following the AAFCO models include:

                • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
                • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
                  • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
                  • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
                  • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
                  • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
                  • Provision of calorie content.
                  • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
                  • Name and address of manufacturer/distributor.
                  • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

                  States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

                  State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

                  Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


                  Regulation

                  In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

                  Ingredients Used in Pet Food

                  An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

                  Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

                  An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

                  Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

                  In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

                  Federal Regulation

                  The Food Safety Modernization Act

                  With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

                  The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

                  With few exceptions, just as with human food, FSMA requires pet food makers to:

                  • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
                  • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
                  • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
                  • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

                  Click here for more information on FSMA requirements related to pet food.

                  PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

                  State Regulation

                  Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

                  States requirements for those following the AAFCO models include:

                  • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
                  • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
                    • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
                    • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
                    • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
                    • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
                    • Provision of calorie content.
                    • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
                    • Name and address of manufacturer/distributor.
                    • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

                    States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

                    State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

                    Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.


                    Regulation

                    In the United States, pet food is among the most highly regulated of all food products, and must meet federal and state requirements. The U.S. Food and Drug Administration (FDA) regulates both finished pet food products (including treats and chews) and their ingredients. Nearly all states also require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

                    Ingredients Used in Pet Food

                    An ingredient must meet key criteria needed to be considered acceptable for use in a pet food recipe. There are four ways for an ingredient to acceptable for use:

                    Ingredients may be approved through AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

                    An ingredient may have gone through the process to receive a Food Additive Petition from FDA which would be listed on the FDA website.

                    Also on the FDA website, there exists a list of ingredients which are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.

                    In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

                    Federal Regulation

                    The Food Safety Modernization Act

                    With regard to federal regulation, p et food makers and their suppliers have always been required to market safe products under the Food Drug and Cosmetic Act (FD&CA) of 1938, which regulates both human and animal food. In this regard, PFI members adopted good manufacturing practices decades ago.

                    The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&CA and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. The focus for human and animal food under the law is prevention of illness, rather than reacting and correcting issues that arise. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

                    With few exceptions, just as with human food, FSMA requires pet food makers to:

                    • Implement current good manufacturing practices (cGMPs) that include requirements for employees, facility design, equipment upkeep and maintenance
                    • Identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make, and put into place procedures (“preventive controls”) that address those hazards
                    • Develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed
                    • Comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished food pet food/treats and ingredients.

                    Click here for more information on FSMA requirements related to pet food.

                    PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI are continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as FDA and state officials conducting FSMA compliance and surveillance.

                    State Regulation

                    Most states regulate pet food products under their animal feed laws. An easy way for states to keep their feed laws current is to adopt the Association of American Feed Control Officials (AAFCO) model bills and regulations mentioned above, which set out, for example, cGMPs, ingredient definitions and requirements for pet food labels and product claims.

                    States requirements for those following the AAFCO models include:

                    • Registration of each pet food product before it can be sold in the state. This enables regulators to know what and where products are sold are sold in their respective state important information to have at hand in the case of a recall.
                    • Product label review and approval. Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:
                      • Review of label format to ensure required information is present, e.g., the brand name, intended species, quantity of product, GA (see details below), ingredient statement, nutritional adequacy statement (also below), and feeding directions. Many of these pieces of information have state-specific language requirements.
                      • Examine for allowable ingredients – ingredients approved by AAFCO or GRAS – through FDA or self-affirmation or ingredients that have received a food additive petition (FAP) .
                      • A guaranteed analysis (GA) of specific measurable levels – usually a minimum and maximum for: crude protein, crude fat, crude fiber, moisture, ash other mineral supplements.
                      • A nutritional adequacy statement (i.e. complete and balanced). Only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.
                      • Provision of calorie content.
                      • Assurance that the use of certain terms is not misleading (e.g., “light, lean, low fat” or comparisons between products on the market). There are regulations in place that define such terms.
                      • Name and address of manufacturer/distributor.
                      • Review of product claims. There are guidelines in place that must be followed to make product claims such as: tartar control formula or “natural.”

                      States can also adopt the AAFCO cGMPs. These have been in place for a while, and AAFCO is currently in the process of adopting the federal cGMPS required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

                      State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

                      Federal and state regulators (on FDA’s behalf) are now inspecting facilities for compliance with FSMA requirements.