2025 Pet Food Compliance Changes: The No-Stress, Plain-English Rundown

If you make or sell pet food for a living, you already know this work isn’t for the faint of heart. The rules shift constantly, states don’t talk to each other, and somehow everything always comes due in December, when you’d rather be drinking eggnog with your family. 

So we were excited when our friends at the Norton Rose Fulbright law firm offered to share their legal expertise with our audience and invited us to join them for a virtual panel discussion about 2025’s hottest topics in pet products. If you didn’t have a chance to join us live, we wanted to share what we learned from this super informative conversation: what’s changing, what’s coming, and why brands can’t afford to “wait and see.”

Think of this as your friendly, plain-English rundown of the big updates (with zero legalese). And if you want to stay ahead of these changes without tracking 30+ state portals on your own, make sure you’re on our newsletter list; you’ll automatically get our free Tonnage & Renewal Dates download!

The regulatory landscape is getting more complicated, not less

Even though AAFCO isn’t a regulatory agency, states continue to rely heavily on its model regulations – typically adopting them in part if not entirely. And this creates a tricky three-layer system for every brand:

• FDA oversight (safety, ingredients, labeling truthfulness)
• AAFCO recommendations that states often adopt
• State-by-state licensing, tonnage reporting, and packaging rules
  

The biggest takeaway: state-level variation is widening. Some states require multiple license types; others are changing how they classify treats vs. supplements; still others are tightening packaging expectations.

What this means for your brand

If your compliance strategy is still based on habits or assumptions from a few years ago, this is the moment to pause and re-evaluate. State-level variation is only increasing, and small misclassifications or outdated labels can now ripple into bigger problems. 

It’s worth taking time to review whether your licenses match the actual products you’re selling, whether your classifications align with how states interpret treats vs. supplements, and whether your packaging is compliant in every state where you have a presence.

If any of that feels unclear, that’s normal and also a sign it’s time to update your approach before renewal and reporting season fully hits.

PFLM is slowly rolling out, but states are moving at different speeds

AAFCO’s Pet Food Label Modernization (PFLM) continues to be one of the biggest shifts in the industry. 

• Updated definitions and nutritional requirements are now standard
• Label formatting rules have changed (names, GA, ingredients, adequacy statements)
• AAFCO recommends full adoption by 2030
• Some states are even treating PFLM versions as “replacement products”

What this means for your brand

If your labels haven’t had a serious refresh in a few years, this is the perfect moment to take stock. The modernization effort is moving slowly but steadily, and states are adopting pieces of it at their own pace. 

That means you may start seeing states requiring PFLM-style formatting even before 2030. Expect reviewers to pay closer attention to guaranteed analysis formatting, ingredient statements, and how your product name aligns with AAFCO definitions. Getting ahead of this now will make future transitions much smoother — especially if you sell nationwide.

You can take this 2-minute quiz about your labels to see if you’re missing anything!

The PURR Act could reshape national standards

The PURR Act is still moving slowly through Congress, and while revisions have been made, it has not passed. If it eventually advances, it would create more uniform federal requirements for pet food. The proposed changes include:

• More consistent labeling requirements
• Tighter safety and quality control
• Increased transparency around ingredients
• Higher nutritional expectations
• Stronger recall procedures

Revised language (not yet law):

• A proposed 90-day FDA review period for ingredient submissions
• AAFCO-approved ingredients presumed GRAS

What this means for your brand

Because the bill is stalled and because added FDA oversight seems unlikely given current staffing and the administration’s priorities, none of these updates are guaranteed. But if your formulas rely on innovative ingredients, it’s still smart to prepare.

Revisit your documentation, update ingredient evidence, and flag any formulas that could be impacted by stricter federal review. Even if nothing moves soon, having strong records in place puts you ahead of the curve and ready for regulatory shifts whenever they come.

The end of the FDA–AAFCO partnership is already impacting ingredients

The 17-year Memorandum of Understanding between FDA and AAFCO expired in October 2024 and was not renewed.

AAFCO responded by launching the SRIS (Scientific Review of Ingredient Submissions) program for novel ingredients. Norton Rose Fulbright  made it clear that this transition period is… messy.

Expect:

• To follow AAFCO recommendations and FDA right now, but be aware that states do have some differences of interpretations.
• No differences in interpretations thus far; previously approved ingredients are grandfathered in
• More steps in the approval process
• Slower movement for innovation-forward products due to federal downsizing. We’re not sure how they’ll even begin to review product labels and handle approvals. 

What this means for your brand

If you’re working on anything innovative, factor in extra lead time. And make sure you understand how states treat SRIS-reviewed ingredients — acceptance won’t be universal.

Guaranteed analysis is under renewed scrutiny

The Texas State Chemist examined analytical variation and found several thresholds were outdated, recommending:

• Revalidating GA
• Auditing labels
• Retesting formulas regularly
• Testing whenever ingredients or suppliers change

AAFCO committees are now digging deeper here, which means more changes may follow.

What this means for your brand

Formula drift is real and states take it seriously. A stale GA can lead to misbranding, registration delays, or required reformulation.

If it’s been a while since you revisited your GA, now’s the time.

Claims litigation is rising and brands are in the spotlight

Norton Rose Fulbright shared several cases showing exactly where regulators and lawyers are focusing: Attias v. Mars Petcare (Vitamin D levels > AAFCO limits) and Krikorian v. Post Consumer Brands (“preservative free” challenge).

There are ongoing cases around “all natural,” “grain free,” “free from” claims, and prescription pet food. There are also salmonella contamination cases and facility odor and nuisance claims. All good things to be aware of!

What this means for your brand

If you’re making claims of almost any kind, it’s time to make sure every statement is fully backed by documentation. 

Litigation around claims has increased sharply. Norton Rose Fullbright has seen clients’ brands can be challenged on even subtle wording. This is a good moment to assess whether your marketing, packaging, and substantiation files tell the same story. If they don’t, tightening them up now can help you avoid costly challenges later.

Get ahead now so 2026 doesn’t run you over

Between PFLM, PURR Act changes, state-by-state variation, and increased litigation, this is one of the most dynamic periods pet food has seen in years.

If you want a simple way to stay ahead, start here. You’ll get our Tonnage & Renewal Dates PDF (free), plus seasonal reminders so you don’t find yourself drowning in December paperwork again.

And if you want to make your workday exponentially easier, you can use our system for a couple dollars a day. It’s a centralized system with automated reminders, designed by people that handle this stuff!