How to Stay Ahead of AAFCO’s Labeling Rules and Avoid Major Compliance Headaches

A mid-sized pet food brand decided to get a jumpstart on AAFCO’s Pet Food Label Modernization (PFLM) updates. They swapped out their guaranteed analysis for the new Pet Nutrition Facts box and started using updated ingredient formatting. They were getting ahead of 2029 requirements that every pet food label will need to fully meet PFLM requirements - so smart and proactive, right?

But during a routine review, a state regulator flagged their packaging for partial compliance. Because the company hadn’t updated all elements of their labels in one go, they were found to be out of compliance. This meant pulled products, regulatory headaches, and costly relabeling. What a nightmare!

Regulators aren’t allowing a piecemeal approach. When it comes to PFLM updates, it’s all or nothing.

Here’s what you need to know to stay ahead of the updates and how to get (and stay) compliant.

What is AAFCO’s Pet Food Label Modernization (PFLM)?

The PFLM is a sweeping update to pet food labeling requirements in the U.S., led by the Association of American Feed Control Officials (AAFCO). These updates aim to make pet food labels clearer, more informative, and more consistent with human food labeling standards.

States are currently operating under a six-year discretionary compliance period, which began in 2023. That means by 2029, every pet food label will need to fully meet PFLM requirements. 

But if you make any updates to your labels before then, you must bring your entire label into compliance all at once.

You can certainly wait to make changes until closer to the deadline. Or you can start making changes now to reduce stress, but you should be ready to implement all changes simultaneously.

Key changes you need to make to your pet food labels

Here are the major updates required under PFLM. Keep in mind this is a high-level overview; AAFCO provides detailed formatting and phrasing rules for each.

1. Intended Use Statement

This statement defines the purpose of your product (e.g., complete diet, treat, supplement). It must follow specific formatting and placement rules:

• Placed in the bottom 30% of the principal display panel (PDP)
• At least as large, and styled the same, as the net quantity statement
• On the same background color as the net quantity statement
• Spaced from other text by strict margins based on the height and width of the letter “N”

2. Pet Nutrition Facts Box

This replaces the traditional guaranteed analysis. The formatting is not optional. It must follow AAFCO's verbatim layout, including indentations, line breaks, and bolded sections.

3. Ingredient Statement

You’re now allowed to use parentheses to clarify vitamin and mineral inclusions. For example:

Chicken, barley, brown rice, blueberries, Minerals (Copper Sulfate, Sodium Selenite), Vitamins (Vitamin B12 Supplement, Vitamin D3 Supplement, Vitamin E Supplement), inulin, rosemary extract

4. Handling and Storage Instructions

This section must appear under a clear header: Handling and Storage Instructions. If your total printable area is under 40 square inches, a header is optional. Icons may be used but must be from AAFCO's approved list.

Don’t risk a violation: get your claims right

With label updates come questions about what you can and can’t say. The rules here are just as strict. For example:

Acceptable claims:

• “Maintains a healthy digestive system”
• “Supports hip & joint health”

Unacceptable claims:

• “Improves skin condition”
• “Prevents urinary tract infections”
• “Lessens anxiety”

Why? Terms like "improves" and "prevents" are often classified as drug claims, which require FDA approval.

If your label mentions human-grade ingredients or includes statements like "Made in a USDA facility," be cautious. These claims require substantiation and may not be permitted at all depending on the phrasing.

For more details, see AAFCO’s guidance on claims and the FTC requirements for "Made in the USA" labels.

Ingredients: what’s allowed and what’s not

The PFLM doesn’t change ingredient approval rules, but it’s a good time to double-check that your ingredients are compliant.

Ingredients must be:

• GRAS (Generally Recognized As Safe) per FDA regulations
• Approved via a Food Additive Petition
• Defined by AAFCO
• On the Animal Food GRAS Notice Inventory
• Acceptable seafood from the FDA list (must be listed by market/common name)
• "Common foods" per AAFCO's definition
• USDA-recognized foundational mushrooms (only above-ground parts allowed)

Pro tip: Some color additives are only permitted for certain uses. All are considered "artificial" under current guidance.

Make one smart update, not five stressful ones

AAFCO’s PFLM updates are required—but they don’t have to be overwhelming. Just remember: if you update even one part of your label before 2029, you have to update everything. That means now is the perfect time to get help, streamline the process, and make sure you’re not back at square one six months from now.

If this is something you’d like help with, we’d love to chat!