dwisner@petfoodcompliance.com, Author at Pet Food Compliance https://petfoodcompliance.com/author/dwisnerpetfoodcompliance-com/ Pet Food Compliance streamlines registration, renewals and reporting for the pet food industry. Mon, 20 Jul 2026 15:50:49 +0000 en-US hourly 1 https://wordpress.org/?v=7.0.3 //ffscdn.s3.us-east-1.amazonaws.com/petfoodcompliance.com/2024/04/cropped-pfc-favicon-2-32x32.png dwisner@petfoodcompliance.com, Author at Pet Food Compliance https://petfoodcompliance.com/author/dwisnerpetfoodcompliance-com/ 32 32 The AAFCO Name Game: 5 Ingredient-Naming Mistakes That Trip Up Pet Food Brands https://petfoodcompliance.com/2026/07/20/the-aafco-name-game-5-ingredient-naming-mistakes-that-trip-up-pet-food-brands/ Mon, 20 Jul 2026 15:45:34 +0000 https://petfoodcompliance.com/?p=1024 The space between what an ingredient feels like and what AAFCO requires you to call it, is where a lot of pet food brands get tripped up. AAFCO doesn't let brands describe ingredients however they like, however evocative or accurate the language might feel.

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Picture the rendering room on the day your pet food formula finally comes together. There’s a low simmer going, and the smell is rich, warm, almost buttery. It makes you think of a Sunday roast rather than an ingredient spec sheet. 

What’s rendering down into that glossy, pale-gold liquid is tallow, and everyone on your team knows it by that name. It’s the word your supplier used on the phone and what your co-packer wrote on the batch ticket. It’s the word your packaging designer wants on the front of the bag, because “tallow-enriched" sounds like something out of a farmhouse kitchen, not a factory.

Then your label copy lands on someone’s desk for review, and the word “tallow" is gone. In its place: “Animal Fat." No warmth, no farmhouse, no Sunday roast, just two flat, clinical words sitting in the ingredient statement where the golden, fragrant thing from the rendering room used to be.

The space between what an ingredient feels like and what AAFCO requires you to call it, is where a lot of pet food brands get tripped up. AAFCO doesn’t let brands describe ingredients however they like, however evocative or accurate the language might feel.

Every ingredient in a pet food formula needs to match a specific, approved name from AAFCO’s Official Publication (OP), the reference most states use to decide what’s allowed on a label. Tallow becomes “animal fat,” organs become “meat by-products,” “chicken meal" can’t just mean whatever a supplier happens to call it that week. These are compliance requirements, and getting them wrong is one of the more common (and avoidable) reasons labels get flagged.

Here are five AAFOC naming mistakes we see often, and how to steer clear of them

1. Using a Common Name Instead of the AAFCO-Defined Name

Suppliers, ingredient houses, and even internal R&D teams often talk about ingredients using industry shorthand or marketing-friendly language. But that shorthand rarely matches AAFCO’s official ingredient definition, and the label has to reflect the defined name, not the version that sounds nicer or more familiar to shoppers.

If an ingredient doesn’t have a matching AAFCO definition at all, that’s a bigger issue. It may need to go through a formal ingredient review before it can appear on a label anywhere. AAFCO recently approved a new scientific review pathway through Kansas State University’s Olathe Innovation Campus specifically to speed up that process for new ingredient submissions, which tells you how often this comes up industry-wide.

Quick check: cross-reference every ingredient against the current AAFCO Official Publication before finalizing your label. 

Here’s how that translates in practice. You’ll find the everyday, kitchen-table term on the left, the AAFCO-defined name that has to appear on the label on the right:

Common / Colloquial TermAAFCO-Defined Name
Organs (liver, lungs,
kidney, spleen)
Meat By-Products
Beaks, feet,
undeveloped eggs
Poultry By-Products
FeathersHydrolyzed Poultry Feather Meal
Ground boneMeat and Bone Meal
BloodBlood Meal / Dried Blood
Rendered fat, tallowAnimal Fat
Corn glutenCorn Gluten Meal
Fish scraps, trimmingsFish Meal
Yeast productBrewers Dried Yeast

A few of these look interchangeable at a glance, but each defined name corresponds to a specific processing method and composition standard in the Official Publication. Swapping in the plain-language version, even with good intentions, creates a different (and non-compliant) ingredient statement.

2. Assuming An Older Official Publication Still Applies Everywhere

Ingredient names can also become outdated through no fault of your own. In October 2024, FDA’s long-standing agreement with AAFCO for reviewing ingredient definitions expired, putting hundreds of AAFCO-defined ingredients in legal limbo.

The FDA stepped in with guidance that same month, saying it wouldn’t take enforcement action against manufacturers using ingredients from the 2024 Official Publication, as long as they stayed within approved safety limits and used the OP’s official names. It was a stopgap, not a new rule, and it’s easy to miss if you assume your ingredient names are set for good. 

States don’t always adopt updates on the same timeline either, so a name that’s compliant in one state might lag behind in another. Building a habit of checking your ingredient statement against the current OP each renewal cycle saves a lot of headaches later.

3. Overcorrecting For The “Clean Label" Trend

The clean label movement has pushed brands toward shorter ingredient lists and more familiar-sounding names, and consumer demand for that is real. Research on food labeling consistently shows people gravitate toward products with recognizable, minimally processed-sounding ingredients.

A willingness-to-pay study on clean label yogurt formulations found consumers paid a real premium for shorter, more familiar ingredient lists. But “clean label" marketing and AAFCO-compliant naming are two different systems, and brands sometimes blur them by softening or renaming an ingredient to sound cleaner than its regulatory name allows.

You can absolutely market around ingredient quality and sourcing! What you can’t do is swap out the required AAFCO name for something friendlier. The name on your ingredient statement stays fixed; the story you tell around it in your marketing copy is where you have room to work, provided that copy doesn’t drift into unsupported claims (more on that below).

4. Letting Marketing Copy Contradict the Ingredient Statement

This is where naming compliance bleeds into FTC territory. If your label lists an ingredient by its correct AAFCO name but your website, packaging callouts, or influencer partnerships describe it differently, you’ve created a mismatch regulators and retailers both notice. 

Consumer confusion around ingredient lists is already common; one recent industry survey found ingredient lists were a top source of confusion for pet owners, right alongside nutritional claims and packaging imagery. Contradictory language between your label and your marketing only adds to that confusion, and it’s the kind of thing that draws scrutiny fast.

This isn’t a theoretical risk! A 2024 class action against Rachael Ray Nutrish alleged that products marketed as “natural" contained synthetic ingredients like citric acid and zinc sulfate listed right on the ingredient statement, arguing the “natural" claim couldn’t square with what the label itself disclosed.

The underlying ingredients were disclosed correctly. The problem was that the marketing language on the front of the package, or in ads and social content, told a different story than the ingredient statement did. That gap is exactly what plaintiffs’ attorneys look for, and it’s a preventable one if label copy and marketing copy get reviewed side by side before launch.

We put together a quick two-minute labeling quiz that catches a lot of these mismatches before they become a problem.

5. Missing Updates to Ingredient Statement Formatting Rules

Naming isn’t just about which word you use, it’s also about how the ingredient statement is structured. AAFCO’s membership recently approved updated Pet Food and Specialty Pet Food Model Regulations, which included changes to ingredient statement formatting, clarifying how terminology should be used consistently and allowing parentheticals and common names for vitamins. 

Brands that built their labels under the older model regulations need to check whether their formatting still holds up, since AAFCO was clear that hybrid labels mixing old and new formatting aren’t acceptable.

Why This Keeps Coming Up

None of this is about AAFCO trying to make life difficult. Ingredient names carry real regulatory weight because they connect directly to safety data, ingredient definitions, and how states enforce labeling law. And because AAFCO isn’t a regulatory agency itself, most of the actual enforcement happens at the state level, using AAFCO’s names and definitions as the backbone. A mismatch that seems small in your files can turn into a registration delay or a retailer’s compliance team sending your label back for revisions.

The brands that avoid this friction usually build a simple habit: check every ingredient name against the current AAFCO Official Publication before the label goes final, and check it again at each renewal cycle. It’s a small step that prevents a lot of downstream cost.

If you want a second set of eyes on your ingredient statement before it ships, or you’re not sure whether your current label matches the latest Official Publication, our labeling and compliance services are built exactly for this. We’ll help you catch naming issues before a retailer or a state regulator does!

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“Chicken for Dogs” Requires 95% Chicken. “With Chicken” Requires 3%. Here’s What Every Pet Food Brand Needs to Know. https://petfoodcompliance.com/2026/06/15/chicken-for-dogs-requires-95-chicken-with-chicken-requires-3-heres-what-every-pet-food-brand-needs-to-know/ Mon, 15 Jun 2026 22:50:33 +0000 https://petfoodcompliance.com/?p=1002 There are four AAFCO naming standards — the 95%, 25%, 3%, and Flavor rules — that govern exactly how much of a named ingredient must be present in a pet food product based on how that ingredient appears in the product name. And these rules are enforceable.

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A few months ago, a friend and I ducked into a cozy, vibey, high-ish end restaurant for lunch. We settle into the corner booth and look over the menu.

Now, something you should know about me is that if there are crab cakes on the menu, I will be ordering them; same goes for Bloody Marys. And because this is a nice place, the crab cakes are priced accordingly. They arrive golden, gorgeous, perfectly plated, and smelling appropriately seafood-y. I eat them happily while my friend and I catch up on each other’s lives.

Later, I flip over the menu in search of dessert and notice an asterisk: “made with natural crab flavor." The main protein: Alaska pollock. There’s enough crab-adjacent something in there to call it crab-flavored, but the star of the dish is decidedly not crab and I very much paid crab prices for my lunch. Not exactly the experience or the meal I was looking for. 

Now imagine you’re the pet owner who just paid a premium for “Chicken for Dogs" and eventually realizes the bag contains 3% chicken.

That’s the gap the AAFCO naming rules exist to close. These four standards — the 95%, 25%, 3%, and Flavor rules — govern exactly how much of a named ingredient must be present in a pet food product based on how that ingredient appears in the product name. And these rules are enforceable.

States that have adopted AAFCO’s model regulations (which is most of them) can and do cite products for naming violations, and those citations can delay registrations, trigger label changes, and create costly headaches right before a launch.

The AAFCO naming rules are also among the most commonly misunderstood standards in the industry. Here’s what you need to know.

Why The AAFCO Naming Rules Matter

Pet owners are reading labels more carefully than ever before. A December 2025 industry statement from Zenapet noted that consumers are now “examining product labels more carefully than ever before, asking detailed questions about ingredient sources." A 2024 Merck Animal Health study found that two-thirds of U.S. consumers believe more transparency around animal protein is necessary, and that sentiment applies directly to how pet food products are named.

When a shopper picks up “Chicken Dinner for Dogs," they’re making an assumption about what’s inside. The naming rules exist to ensure that assumption isn’t misleading. When brands get them wrong, whether intentionally or not, it erodes the trust that the entire industry depends on.

The Four AAFCO Naming Rules, Explained

The 95% Rule: When the Name Is the Ingredient

Under the 95% rule, the named ingredient must make up at least 95% of the product by weight, excluding water for processing. If water is included in the calculation, the named ingredient must still comprise at least 70%.

Classic examples: “Beef for Dogs," “Chicken Cat Food," “Salmon Dog Food."

This rule typically applies to products consisting primarily of meat, poultry, or fish, and most often applies to canned products. When you name a product this way, you’re making an extremely high-content promise, and you need your formula to back it up.

When more than one ingredient appears in the name, no single ingredient can be less than 3% of the total product by weight. Because the first-listed ingredient appears first in the name, there must be more of it than the second. A product named “Chicken and Rice Cat Food" must contain more chicken than rice, and both combined must hit the 95% threshold.

Worth noting: there’s also a 100% rule that applies to certain treat products. “All-beef jerky dog treats" must be all-beef meat with the exception of water added for processing, decharacterizing agents, and trace amounts of preservatives and condiments. It’s unlikely anything other than a treat product will meet that threshold.

The 25% Rule: The “Dinner" Zone

The 25% rule covers products with names like “Chicken Dinner for Dogs," “Lamb and Rice Formula," or “Chicken, Rice, and Pumpkin Platter for Puppies." These names include an additional descriptor such as “dinner," “entrée," “platter," “formula," or “recipe."  The named ingredient must make up at least 25% of the product, not including added water, and at least 10% including it.

Here’s where brands frequently run into trouble: A product labeled “Chicken Dinner for Dogs" only needs to contain 25% chicken, which means up to 75% of the product could be something else entirely: grains, vegetables, other proteins. If two ingredients are named under the 25% rule, for example “Chicken and Turkey Dinner for Dogs," both chicken and turkey combined must make up 25% of the total, but neither can account for less than 3% of the total. 

The 25% rule is where well-intentioned brands often end up in naming mismatches. They choose a product name that sounds high-content, but they’re technically in “dinner" territory. The fix usually requires label changes, and those are far less expensive before the bags are printed.

Not sure if your labels are compliant? Take this 2-minute quiz to find out!

The 3% Rule: “With" Is a Specific Promise

The “with" rule indicates that the named ingredient comprises at least 3% of the food by weight, excluding water.

“Dog Food with Chicken" tells a consumer there’s at least 3% chicken. This rule exists so brands can call out a featured-but-minor ingredient without misrepresenting the formula, but it’s frequently misapplied in both directions. We’ve seen brands use “with" language when their product contains 30% of the named ingredient, which creates a different problem: consumers may assume the product is lower-content than it is and potentially choose a competitor’s product instead.

The word “with" is doing regulatory heavy lifting in a product name. It should be chosen deliberately, not by default.

The Flavor Rule: The Most Minimal Claim of All

A “Beef Flavor Dog Food" only needs to have a detectable amount of beef, often provided by stock or broth. There’s no minimum percentage threshold, only that the flavor be detectable, typically verified through an animal feeding preference test or some form of analytical detection.

This rule gives brands maximum formulation flexibility while still allowing a named ingredient to appear in the product name or elsewhere on the product label. It also comes with real consumer perception risk. If your packaging emphasizes beef and the actual beef content is negligible, you may be technically compliant while still drawing scrutiny from retailers, consumers, and state regulators who evaluate whether labeling is misleading in context.

Why the Co-Manufacturer Situation Complicates Everything

If you’re working with private label or co-manufacturing partners, you’re responsible for your label, even if someone else makes the product.

If the guarantor is not the actual manufacturer, the name and address on the label must be preceded by words such as “manufactured for" or “distributed by." The party listed on the label is the responsible party. It’s a signal of where compliance accountability lives. 

If your co-manufacturer uses an ingredient formulation that puts your named ingredient below the threshold required by your product name, the enforcement action lands on you. This is especially important as AAFCO’s new model regulations continue rolling out

To allow state regulatory programs time to incorporate the guidelines, AAFCO recommended a six-year enforcement discretion period, and both AAFCO and NASDA encourage state authorities to allow distribution of products that comply with either existing regulations or the new model regulations. That discretion period won’t last forever, and it doesn’t eliminate your responsibility to get the naming right now.

What Happens If You Get This Wrong

Naming violations can trigger:

Registration rejections

State departments of agriculture review product names as part of the registration process. A name that doesn’t match your formula’s actual ingredient percentages can result in a rejected application, which means delays before you can legally sell in that state.

Label reprints

Fixing a non-compliant product name after packaging is already printed is expensive. The earlier you catch it in the development cycle, the less it costs.

Retailer friction

Retailers are increasingly asking for compliance documentation before onboarding new brands. A labeling issue flagged during their review process can stall or kill a listing opportunity. Here’s what retailers are looking for when they partner with pet food brands.

Consumer complaints

When a shopper buys “Chicken Dinner for Dogs" expecting a high-chicken product, finds out it’s primarily grain, and leaves a review about it, that’s a trust problem that naming compliance could have prevented.

How to Check Your Own Product Names

Before you finalize any product name, run through these questions:

What percentage of the named ingredient does my formula actually contain?

Get this number from your co-manufacturer or formulation records, and confirm whether it’s calculated with or without water for processing.

Does my product name match that percentage?

Map it against the four rules above. If you’re at 40% chicken, “Chicken for Dogs" doesn’t work, but “Chicken Entrée for Dogs" or “Chicken Recipe for Dogs" does.

Are there multiple named ingredients?

The minimum threshold for all categories except flavor is 3% per named ingredient—make sure each one clears that bar. Then confirm they’re listed in descending order of quantity and that their combined percentage qualifies under the applicable rule. 

Am I using qualifying descriptors correctly?

Words like “dinner," “entrée," and “formula" aren’t just marketing language, they’re regulatory signals that tell the state (and the consumer) which rule your product falls under.

Have I reviewed my label for all required elements?

Product naming is just one piece. If you haven’t run a full label review recently, our free 2-minute quiz to avoid expensive labeling mistakes is a good starting point.

Fix Problems Before You Print The Bags

The AAFCO naming rules reward brands that understand them and create risk for those that don’t. The gap between “Chicken for Dogs" (95% chicken) and “With Chicken" (3% chicken) is the difference between a compliant product and one exposed to enforcement, retailer rejection, or consumer backlash.

If you’re working on a new launch, reformulating an existing product, or inheriting a label that you’re not sure about, this is the right moment to get clarity. Our team works with brands at every stage, from first formula to national distribution, to make sure naming, labeling, and state registrations are all aligned before anything goes to print.

Reach out to us here and let’s take a look at what you’ve got!

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The Plain-Language Guide to Current Good Manufacturing Practices for Pet Food https://petfoodcompliance.com/2026/05/17/the-plain-language-guide-to-current-good-manufacturing-practices-for-pet-food/ Sun, 17 May 2026 22:04:24 +0000 https://petfoodcompliance.com/?p=962 Imagine seeing your company’s name showing up all over social media, in trade magazines, on government websites, and even earning its own Reddit thread - seems great, right? But what if all that free publicity is due to … salmonella and listeria? 😬

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Imagine seeing your company’s name showing up all over social media, in trade magazines, on government websites, and even earning its own Reddit thread – seems great, right?

But what if all that free publicity is due to … salmonella and listeria? 😬

Regrettably, that’s exactly what happened to Answers Pet Food in 2024. 

Lab analysis of four sampled product lots confirms the presence of Salmonella and/or Listeria. The FDA concluded that the company failed to identify and implement the preventive controls that could have caught this before it became a public safety issue.

By June 2025, a formal warning letter had been issued, and the brand’s reputation was in a very different place than it had been twelve months earlier.

Stories like this obviously don’t start with bad intentions. They start with gaps in documentation, sanitation procedures, or the foundational food safety infrastructure that holds everything else together.

That infrastructure has a name: Current Good Manufacturing Practices, or CGMPs.

If you’re manufacturing pet food in the U.S. — or planning to — this is your plain-language guide to what CGMPs require, why they matter, and how to build a program that keeps you on the right side of the FDA.

Related: A few months ago, we sponsored a great workshop with Pet Food Forum’s “Ask A Petfood Pro” series Ramparts Of A Strong Food Safety System. Super helpful and applicable to this topic!

What Are Current Good Manufacturing Practices (CGMPs)?

CGMPs are the FDA’s minimum standards for how animal food — including pet food — must be manufactured, processed, packed, and held. They’re codified in 21 CFR Part 507, Subpart B, which was finalized as part of the Food Safety Modernization Act (FSMA) in 2015.

Think of CGMPs as the foundation of your food safety program. They don’t address every possible hazard your product might face — that’s what preventive controls are for — but without a solid CGMP foundation, even the best hazard analysis won’t hold up. As the FDA puts it in its guidance for industry, CGMPs serve as a prerequisite: the baseline that makes everything else work.

If you’re already familiar with the broader regulatory landscape (the FDA, AAFCO, and state-level requirements) you can think of CGMPs as the “how you run your facility" piece of the puzzle. 

Who Has to Follow CGMPs?

If your facility is required to register with the FDA because you manufacture, process, pack, or hold animal food for consumption in the U.S., CGMP requirements apply to you.

That covers:

  • Pet food manufacturers (dry, wet, raw, freeze-dried, and more)
  • Co-manufacturers and private label producers
  • Brands manufacturing in-house, even at small scale
  • Facilities handling ingredients that will go into finished animal food

There are limited exemptions and those are primarily for certain on-farm activities and very small qualified facilities. But for the vast majority of pet food brands, CGMPs aren’t optional. 

The Six Core Areas CGMPs Cover

1. Personnel

Everyone working in direct contact with animal food, food-contact surfaces, or food packaging has to follow hygienic practices that protect against contamination. We’re talking hand washing, appropriate clothing and protective gear, keeping employees who are ill away from food-contact areas, and making sure your team understands why these practices matter, not just that they’re required.

Training is a documented requirement, and inspectors will ask to see proof of it.

2. Plant and Grounds

Your facility’s physical environment matters. The grounds around your plant need to be maintained to eliminate pest attractants, and the building itself has to be designed and maintained to prevent contamination. You need proper drainage, no entry points for pests, adequate lighting, sufficient ventilation.

A 2024 FDA warning letter to Reconserve Inc. cited ingredients stored outside on bare gravel, uncovered and exposed to birds, rodents, insects, and rainfall. They’d been stored that way since a facility fire in February 2023. What began as a temporary fix became a significant enforcement action. A good reminder to us all that “we’ll deal with it later" is rarely a safe plan when it comes to your facility.

3. Sanitation

Your facility needs documented sanitation procedures and those procedures need to be  followed. That means cleaning schedules, approved sanitizers used correctly and for the right contact time, and verification that sanitation is working.

The 2024 FDA warning letter to Mid America Pet Food is one of the more sobering examples of what can happen when sanitation gaps go unaddressed. Their brands — Victor, Eagle Mountain, Wayne Feeds — were linked to a Salmonella outbreak that sickened seven people across seven states, six of them children under one year of age. 

Even after a voluntary recall and a facility-wide deep clean, inspectors returned and found the sanitation deficiencies hadn’t been resolved. The warning letter came nearly a year after the original recall. Inspectors do come back.

4. Equipment

Manufacturing equipment has to be designed to be cleanable, properly maintained, and used in a way that doesn’t create contamination risk. No dead zones where product can accumulate, no rust or corrosion on food-contact surfaces, calibrated instruments wherever measurements matter to safety. 

5. Plant Operations

This is the actual day-to-day manufacturing piece: how raw materials are inspected when they arrive, how they’re stored and handled, how the finished product is protected before it ships. Ingredients that arrive damaged, contaminated, or outside spec need to be identified and controlled. 

6. Recordkeeping

Say it with us: if it isn’t documented, it didn’t happen! CGMPs require records that show your practices are being followed consistently; you should have training logs, sanitation records, supplier documentation, ingredient receiving logs. Those records become your best defense if you ever face an inspection, a consumer complaint, or a recall situation.

CGMPs and FSMA Preventive Controls: How They Fit Together

CGMPs and Preventive Controls work together, but they’re not the same thing. CGMPs are your baseline — sanitation, personnel hygiene, facility maintenance.

Preventive Controls (also under 21 CFR Part 507) are the risk-based layer on top: a formal hazard analysis, identification of hazards that require control, and documented measures to prevent or minimize those hazards.

A helpful way to think about it: CGMPs reduce the likelihood that hazards occur in the first place. Preventive Controls address the hazards that could still show up even with strong CGMPs in place.

Most pet food facilities that aren’t very small businesses are subject to both and increasingly, what retailers expect from your compliance documentation reflects both layers of this framework. If you’re eyeing wholesale or national distribution, your compliance posture matters to buyers before you ever get to contract negotiations.

Practical Steps for Getting Your CGMP Program in Order

Whether you’re preparing for a launch or taking stock of an existing operation, here’s where to put your energy:

Write your SOPs and make sure your team actually uses them.

Standard operating procedures for sanitation, receiving, pest control, and personnel hygiene are your roadmap for consistent execution and your defense if something goes wrong.

Train your team and document it.

“We covered this during onboarding" won’t hold up in an inspection. You need records: who was trained, on what, and when.

Walk your facility like an FDA investigator would.

Look at pest entry points, equipment condition, sanitation logs, and how incoming ingredients are being stored and inspected. If something would be hard to explain to an outsider, that’s worth fixing before someone with a badge asks about it.

Get your supplier documentation current.

CGMP compliance doesn’t stop at your receiving dock. Certificates of analysis, supplier specs, and traceability records are all part of demonstrating that your inputs are safe. We’ve written about how analytical variation and documentation gaps can create real problems even when your formulation intent is solid.

Build your food safety plan if you’re subject to Preventive Controls.

A qualified individual needs to lead that process and it’s not a one-and-done document. It needs to be revisited as your products, ingredients, and processes change.

You Don’t Have to Figure This Out Alone

CGMPs are genuinely manageable, but they do require intention, consistency, and follow-through. The brands that find themselves in trouble are usually the ones who meant to get around to this  … and didn’t.

If you’re not sure where your facility stands, or you’re building this from scratch and want to get it right from the start, we’d love to be part of that process. We work with brands at every stage, from startups mapping out their first facility requirements to established manufacturers who need a clear-eyed compliance review before a retailer audit.

Reach out and let’s talk through where you are and what you need!

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What Is the NASC? It’s Not a Regulatory Agency (Even Though It Feels Like One) https://petfoodcompliance.com/2026/04/17/what-is-the-nasc-its-not-a-regulatory-agency-even-though-it-feels-like-one/ Fri, 17 Apr 2026 14:06:45 +0000 https://petfoodcompliance.com/?p=919 The NASC is genuinely valuable and worth understanding but one of the most common misconceptions we hear from pet food and supplement brands at every stage is that NASC is some kind of government or regulatory body overseeing the industry. It isn't and understanding the difference could save you from a costly compliance gap down the road.

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If you’ve spent any time in the pet food or supplement space, you’ve almost certainly come across the acronym NASC. It shows up on product packaging, in retailer conversations, and in industry discussions about quality and compliance. 

And if you’re a brand owner trying to figure out what the National Animal Supplement Council actually means for your business, the whole thing can feel a little murky.

So let’s clear it up!

The NASC is genuinely valuable and worth understanding but one of the most common misconceptions we hear from pet food and supplement brands at every stage is that NASC is some kind of government or regulatory body overseeing the industry. It isn’t and understanding the difference could save you from a costly compliance gap down the road.

So, What Is the NASC?

The National Animal Supplement Council (NASC) is a nonprofit trade association. It was founded in 2001 at a moment when the animal supplement industry was in a bit of a regulatory storm. Products were being pulled from shelves, enforcement was inconsistent across states, and consumers had no reliable way to evaluate quality from one brand to the next.

NASC stepped in to create voluntary standards where few existed. They developed what’s become the gold standard of the supplement space: the NASC Quality Seal, a yellow badge you’ve probably seen on supplement packaging for dogs, cats, and horses.

To earn that seal, companies have to go through a rigorous process. It’s not something you buy or simply apply for and receive. 

To display the NASC Quality Seal, brands must:

  • Pass a comprehensive independent third-party quality audit (repeated every two years)
  • Maintain a quality control manual with documented standard operating procedures
  • Run an active adverse event reporting system tied to the NASC’s national tracking database
  • Follow NASC pet supplement labeling requirements, including specific caution statements required by the FDA’s Center for Veterinary Medicine
  • Submit to random independent product testing to verify label claims

That’s a real commitment, and it means something. The NASC Quality Seal is a credible, recognized signal of quality in the marketplace. Retailers increasingly look for it, consumers trust it, and earning it takes genuine work.

NASC Is Not a Government Agency

This is where the confusion tends to set in and it’s totally understandable. The National Animal Supplement Council works closely with the FDA. It collaborates with AAFCO. It has active relationships with state regulators. Its standards mirror many regulatory requirements. It even has a “Regulator" membership tier specifically for government employees who oversee animal supplements.

So it looks like it’s part of the regulatory system, but it isn’t.

NASC has no legal enforcement authority. It cannot fine your company, issue a stop-sale order, mandate a product recall, or compel any state or federal agency to treat your products differently. It’s a trade association — a highly influential and respected one — but a private nonprofit organization, not a government body.

A helpful comparison: AAFCO operates similarly.  AAFCO isn’t a regulatory agency either but its model regulations are adopted by most states, giving it enormous real-world influence on your compliance requirements. NASC works the same way. It works with the regulatory system, and it has shaped that system for the better, but it isn’t part of it.

Here are the agencies that have legal authority over your pet supplement products:

The FDA

It regulates animal food (including supplements) under the Federal Food, Drug, and Cosmetic Act. Depending on your facility size and production activity, you may need to register your facility and comply with FSMA Preventive Controls for Animal Food. Critically, DSHEA — the Dietary Supplement Health and Education Act that governs human supplements — does not apply to animal products. Pet supplements are regulated as food or drugs depending on their intended use.

State Departments of Agriculture

This is where most day-to-day pet supplement compliance happens. Most states require product registration, manufacturer or distributor licensing, and annual renewals, often with per-SKU fees. This is separate from, and not replaced by, NASC membership.

The FTC

This group governs the claims you make — not just on your label, but on your website, in your social posts, and in influencer content. “Calming," “supports immune health," and “helps with anxiety" are all phrases that can draw scrutiny regardless of your NASC status.

Photo credit: NOW Pets

NASC Membership Is a Quality Credential Not a Compliance Shortcut

This is the most important takeaway: NASC membership does not exempt your products from state registration requirements.

It doesn’t replace your manufacturer or distributor license. It doesn’t satisfy FDA facility registration. It doesn’t handle your tonnage reporting. It doesn’t make your label automatically compliant in every state.

Even products that follow NASC’s labeling templates may still be required to register in certain states. Some states recognize those templates; others require brands to follow their own state feed regulations entirely. The only way to know which applies to your products is to check  product by product, state by state.

We know that sounds like a lot. And it is! This is why our registration and licensing services exist. Missing a single state registration can create retailer delays, or worse, enforcement letters. Selling across all 50 states means managing 50 different sets of expectations, and that’s before you factor in how individual states classify supplement products versus animal feed.

Where Pet Supplement Brands Misstep

Beyond the government agency misconception, here are two other areas where NASC membership is sometimes (incorrectly) assumed to provide a compliance free pass:

Product claims

NASC has labeling guidelines and following them is a smart baseline. But those guidelines don’t insulate you from FDA or FTC scrutiny if your language crosses into drug-claim territory. Structure/function language like “supports joint health" or “promotes calmness" can shift your product’s regulatory classification, and that shift can happen whether you’re NASC-audited or not. 

Product classification is one of the first things we encourage every brand to lock down. If you’re unsure whether your label language is creating unintended regulatory exposure, this free two-minute quiz is a fast first checkpoint.

Retailer onboarding

Retailers are asking harder questions at compliance review than they were a few years ago. A quality seal and a current state registration record tell two different stories. Buyers increasingly want documentation of both and assuming one covers the other is a gap that tends to surface at the worst possible moment.

So Where Does NASC Fit In?

Think of NASC membership and regulatory compliance as two parallel tracks. Both matter, but neither is a substitute for the other.

NASC membership demonstrates that your brand is committed to quality standards, responsible labeling, and continuous improvement. That carries weight with retailers, consumers, and regulators alike. The NASC has done meaningful work to create a more stable, more favorable regulatory environment for the supplement industry and brands that participate in that effort benefit from it.

But the state registrations, the FDA obligations, the licensing and annual renewals still have to happen regardless of your membership status.

The good news is that brands who run both tracks tend to scale much more cleanly. They don’t hit surprise roadblocks at retailer onboarding. and they’re not caught off guard when a state department of agriculture comes knocking.

Not Sure Where Your Compliance Gaps Are?

Whether you’re pre-launch, mid-growth, or cleaning up an existing product lineup, our team at Pet Food Compliance works with pet supplement and food brands every day to make sure both tracks are running smoothly. We know which states are going to ask the hardest questions about your products and we know how to get you ready before they do.

The post What Is the NASC? It’s Not a Regulatory Agency (Even Though It Feels Like One) appeared first on Pet Food Compliance.

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Why We Upgraded The Pet Food Compliance Hub + How The New Features Save You Time & Stress https://petfoodcompliance.com/2026/02/09/why-we-upgraded-the-pet-food-compliance-hub-how-the-new-features-save-you-time-stress/ Mon, 09 Feb 2026 21:59:53 +0000 https://petfoodcompliance.com/?p=802 As our clients’ teams grew and product lines became more complex, we saw ways we could make our already-good online portal even better.

The post Why We Upgraded The Pet Food Compliance Hub + How The New Features Save You Time & Stress appeared first on Pet Food Compliance.

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If you’ve ever tried to manage pet food compliance through a combination of spreadsheets, email threads, shared drives, and crossed fingers, you’re already painfully familiar with the problem our Compliance Hub was built to solve.

At its core, the Compliance Hub is a centralized system that helps pet food companies manage licenses, products, formulations, and retailer-facing compliance requirements in one place. It’s how we keep registrations organized, documentation accurate, and retailers confident that what they’re receiving is complete and current.

Over the past year, as our clients’ teams grew and product lines became more complex, we  saw ways we could make this already-good online portal even better. 

Below is a walkthrough of what the Compliance Hub does today, why retailers love it, and how the newest features make compliance easier for real-world teams, not just nerdy compliance managers like us!

What The Compliance Hub does + Why It Exists

The Compliance Hub exists to answer one question: “Is everything we’ve submitted accurate, complete, and up to date—right now?”

Inside the hub, clients can:

  • Manage state licenses and renewals
  • Maintain product data, formulations, and documentation
  • Track retailer-specific compliance requirements
  • Upload and store supporting materials in one system
  • Get alerts when something needs attention

Instead of chasing files across departments or wondering which version is the “real one,” the hub becomes the single source of truth. That clarity saves time internally and significantly reduces friction with retailers.

Why Retailers Love It When Brands Use The Compliance Hub

Retailers don’t want more emails. They want clean data, submitted correctly, on time.

When brands use the Compliance Hub, retailers benefit from consistent product and license information, fewer back-and-forth corrections, and faster onboarding and approval timelines. The Compliance Hub also reduced the risk of expired or missing documentation. 

In other words, using a centralized compliance system makes your brand easier to work with. And in a competitive retail environment, that matters.

Update 1: Multi-user access

One of the most requested updates we’ve ever received was “Can we set it up so more than one person log in?”

And now the answer is yes! The Compliance Hub now supports multiple users with role-based permissions, making it far easier for teams to collaborate without stepping on each other’s work. 

We also expanded access for registration companies and consultants who manage multiple brands; this reduces duplicated effort across client portfolios. Partners using RetailComply can now manage multiple company accounts within the system. To set this up, they’ll need to contact our team at rc@petfoodcompliance.com for access.

This update You can assign users as:

  • View Only – can see everything, but can’t upload or edit
  • Editor Access – can upload files and add or edit data
  • Admin Access – can do everything an editor can, plus add, edit, or remove users

This makes it easy to loop in QA, operations, finance, or marketing—without giving everyone the same level of access.


Notification preferences by role

Each user can also choose which notifications they receive:

  • License updates
  • Tonnage reminders
  • Billing alerts

So the right people get the right information, without inbox overload.

Update 2: Product updates

Product data is rarely simple, especially as brands scale. The Compliance Hub now includes several powerful tools designed specifically for modern pet food product lines.

PFLM uploads—single or bulk

Pet Food Labeling Model (PFLM) submissions can now be uploaded individually or in bulk using a spreadsheet

This is a major time-saver for teams managing multiple SKUs or rolling out product updates at scale.

Variety Pack builder

If you sell variety packs—where multiple finished products with their own SKUs are packaged together—the new Variety Pack Builder simplifies the process.

Each product is entered individually (if sold separately), then assembled into a variety pack within the tool. This keeps data clean and prevents duplication or mismatched documentation.

Multi-Item builder

For products with one SKU but multiple recipes or Guaranteed Analyses, the Multi-Item Builder allows you to add multiple “items” under a single product.

Each item has its own GA fields, ensuring accuracy while keeping everything tied to the same SKU.

Important note: Variety Packs and Multi-Item products cannot mix GA and PFLM products—this separation helps maintain regulatory clarity and avoid submission errors.

Update 3: The Action Center

Missed an email? It happens. That’s why we built the Action Center.

The Action Center flags:

  • Licenses that need attention
  • Outstanding renewals or missing items
  • Tasks that haven’t been resolved yet

While the system sends automated emails and weekly reminders while items remain outstanding, the Action Center gives clients a habit-forming place to check in and stay ahead of issues before they become problems.

Update 4: Clearer, faster customer communication

As we’ve grown, we realized that mixing customer questions with state-facing paperwork wasn’t working as well as it should.

Many clients have historically emailed processing@petfoodcompliance.com, since that address appears on license applications and state documents, but that inbox is built for regulator communication, not day-to-day client support.

So we’re officially separating the two. Our new inbox for Managed Services client support is clientcare@petfoodcompliance.com

Use this inbox to reach our Managed Services team with questions about your account, submission status, the Compliance Hub, or anything else you need help sorting out.

The processing@petfoodcompliance.com email will remain dedicated to communication with state agencies and regulators, helping ensure submissions and correspondence stay on track.

This means you’ll get faster responses, clearer routing, and fewer delays. 

Why Centralized Systems Reduce Compliance Risk

These updates dramatically reduce your risk. Research from Deloitte and PwC consistently shows that organizations with centralized data systems experience fewer compliance failures and faster response times when issues arise. Fragmented systems, on the other hand, increase the likelihood of missed deadlines, inconsistent submissions, and audit exposure.

In regulated industries like pet food, process clarity is a competitive advantage.

If your compliance process still lives in email threads, shared drives, or just one person’s head, we created these updates for you. The upgraded Compliance Hub supports cross-functional collaboration, cleaner product data, and fewer retailer rejections.

Even better, it scales with you as your team and product line grow.

Want Access To The Compliance Hub?

The Pet Food Compliance Hub is available to clients using our managed compliance services. If you want a centralized system that keeps licenses, products, and retailer requirements organized and support from a team that lives and breathes pet food compliance—we’d love to help. Click here to get in touch!

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Extended Producer Responsibility for Pet Brands: Costs, Packaging Changes & How to Get Ahead https://petfoodcompliance.com/2025/12/17/extended-producer-responsibility-for-pet-brands-costs-packaging-changes-how-to-get-ahead/ Wed, 17 Dec 2025 23:13:37 +0000 https://petfoodcompliance.com/?p=779 As extended producer responsibility laws expand, brands are realizing they need to understand what EPR actually requires and how it will impact packaging, costs, and retailer expectations.

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Last month, a mid-sized pet treat company called us in a mild panic.

A retailer emailed asking for something brand-new on their radar: “Can you send your packaging recyclability data and confirm whether your products will meet upcoming extended producer responsibility requirements in Colorado and Oregon?”

Their operations director groaned: “We just finished renewals. Now EPR compliance? What even counts as recyclable under these new packaging regulations?”

This is becoming a common moment across the pet food industry. As extended producer responsibility laws expand, brands are realizing they need to understand what EPR actually requires and how it will impact packaging, costs, and retailer expectations.

So here’s a clear, concise breakdown of extended producer responsibility, how it affects the pet food industry, and what you can do right now to stay compliant and competitive.

What extended producer responsibility means for pet food brands

Extended producer responsibility (EPR) shifts end-of-life packaging costs from cities to companies. If you sell any packaged pet food product—kibble, treats, toppers, supplements—you’re included.

Most EPR programs require brands to:

  • Report packaging data (material type, weight, recyclability)
  • Pay EPR fees based on material impact
  • Meet PCR and recyclability targets over time

Seven U.S. states now have EPR laws for packaging (CA, CO, OR, ME, MN, MD, WA), and more are coming. The EU’s updated Packaging & Packaging Waste Regulation adds even tighter rules.

Retailers are also turning this into a requirement. If you read our trend breakdown,

How EPR will impact your packaging, operations, and costs

Pet food packaging relies heavily on flexible plastics and multi-layer laminates—materials that EPR laws specifically target.

Here’s what pet food brands should expect:

1. Packaging choices now directly affect EPR fees
Eco-modulated EPR fees reward recyclable packaging and penalize complex, hard-to-recycle materials.

2. Multi-layer bags become increasingly expensive
Traditional kibble bags and laminated treat pouches may carry higher compliance costs unless redesigned with more recyclable materials. (If you need help redesigning your packaging, we can point you towards a packaging/logistics partner for the physical packaging and our team can facilitate the design and labeling.) 

3. Detailed EPR reporting becomes mandatory
Brands will need to track material type, weight, and recyclability by SKU.

Bottom line: EPR is a cost-of-goods issue.

Step one: Map your EPR responsibilities and build your packaging data foundation

Think of extended producer responsibility the same way you think of licensing, tonnage, or label compliance: consistent, organized, and predictable.

1. Map where EPR laws apply to your products

Create a simple EPR compliance spreadsheet listing:

  • States and countries where you sell
  • Which regions already have EPR laws
  • Which packaging formats appear in each market

2. Start collecting packaging data now

Capture the basics:

  • Material type
  • Material weight
  • Recyclability under EPR laws
  • PCR content, if applicable

This is the core of your EPR reporting requirements. Adding a packaging tab to your spec sheets makes future reporting far easier.

3. Assign someone to manage EPR compliance

This could sit under Regulatory, Ops, Sustainability, or Finance—but someone needs ownership of:

  • Monitoring EPR regulations
  • Coordinating packaging data
  • Modeling EPR fees over time

If your internal team is stretched thin, folding EPR into your existing compliance partnership can reduce the workload dramatically.

Step two: Redesign packaging with EPR compliance in mind

You don’t need a full rebrand to make meaningful improvements to your EPR footprint. Most brands can make progress with a few strategic changes.

High-impact moves for EPR-friendly packaging

Simplify materials
Shift toward mono-material films where possible. These perform better under EPR packaging regulations.

Right-size your packaging
Reducing excess material lowers both costs and EPR fees.

Choose “widely recyclable” formats first
Paper, certain plastics, and metals with strong recycling markets perform better under extended producer responsibility models.

Integrate PCR content early
States like CA and CO already require minimum PCR levels. Early adoption improves compliance and reduces sourcing friction later.

Consumer research consistently shows demand for sustainable pet packaging. EPR simply adds a regulatory push to a market-driven trend.

Step three: Turn EPR readiness into a competitive advantage

EPR compliance makes you more attractive to retailers and consumers. Given the option, wouldn’t you rather buy dog food in a fully recyclable container? 

Stronger retailer partnerships

Retailers increasingly expect:

  • Recyclability data
  • Packaging specs
  • A 2–3 year packaging roadmap

Brands that come prepared stand out as low-risk, high-reliability partners.

What pet food companies should do next

Extended producer responsibility is growing quickly, and the best-prepared brands will adapt early.

Here’s your simplified roadmap:

  1. Build your EPR map — know exactly where packaging obligations apply.
  2. Organize packaging data — even rough numbers help you prepare.
  3. Update packaging roadmaps — integrate recyclability and PCR targets.
  4. Make EPR part of your compliance system — like licensing or tonnage.
  5. Use EPR for trust-building — with retailers and sustainability-minded consumers.

If you want support integrating EPR compliance into your licensing, labeling, and regulatory workflow, our team can help streamline the entire process! Learn more here.

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2025 Pet Food Compliance Changes: The No-Stress, Plain-English Rundown https://petfoodcompliance.com/2025/12/04/2025-pet-food-compliance-changes-the-no-stress-plain-english-rundown/ Thu, 04 Dec 2025 22:19:48 +0000 https://petfoodcompliance.com/?p=774 Our friends at the Norton Rose Fulbright law firm are sharing their legal expertise: 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).

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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:

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!

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Your Complete Guide To Florida’s Pet Food Sampling & Testing Requirements https://petfoodcompliance.com/2025/10/21/your-complete-guide-to-floridas-pet-food-sampling-testing-requirements/ Tue, 21 Oct 2025 19:12:49 +0000 https://petfoodcompliance.com/?p=758 Let's break down what Florida’s sample requirements really mean, the most common mistakes we see, and what you can do to stay compliant — without losing an entire week to the LIMS portal.

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Every September, inboxes across the pet food industry light up with the same subject line: “REMINDER: Florida Feed Sample Deadline.”

It’s the state’s gentle way of saying: “If you sell feed or pet food in Florida, your compliance samples are due.”

But year after year, brand owners are caught off guard. They think they’re in the clear after renewing their license and reporting tonnage — until they realize sample submission is a separate requirement tied to that same registration period.

If you’ve ever been confused about what Florida expects (and when), you’re not alone. Between quarterly tonnage reports, sample submissions, and certified lab testing, it can feel like alphabet soup.

Today, we’ll break down what Florida’s sample requirements really mean, the most common mistakes we see, and what you can do to stay compliant — without losing an entire week to the LIMS portal.

Florida’s Sampling Period + Key Deadlines

You probably received an email in which FDACS reminded companies that the sampling period runs concurrently with the registration period. This means your sampling requirements reset each year along with your feed registration.

“Samples of commercial feed and feedstuffs shall be submitted quarterly, to laboratories certified by the Department, corresponding to the tonnage reported… Section 5E-3.003(4), F.A.C., requires a minimum of one sample to be submitted by the end of the first quarter of each year—September 30, 2025.”

Here’s what that means in practice:

  • If you’re registered in Florida, you must submit at least one compliance sample by September 30 each year.
  • The total number of samples required corresponds to your reported tonnage of mixed feed or feed ingredients.
  • All samples for the 2025–2026 registration year must be received by June 30, 2026.

Failure to submit the required samples is a violation of Florida law. Missing one quarter puts you out of compliance. Missing two consecutive years triggers a $250 administrative fine under Rule 5E-3.018(3)(a)(1), F.A.C. And ongoing failure to comply can lead to suspension of your Feed Master Registration under Section 580.112 (3) & (13), F.S.

The state also clarified that samples must be logged online through the Feed Regulatory website (lims.flaes.org) before being shipped to a certified lab. Samples not entered in the system will no longer be accepted.

What You’re Required To Test

FDACS outlines specific laboratory analyses that must be performed each year, depending on your product type.

For mixed feed products, testing must include:

  • Protein, fat, and fiber
  • Minerals, if guaranteed on the label
  • Aflatoxin and vomitoxin
  • Fumonisin (for horse feeds)

For unmixed feed ingredients, analysis must include mycotoxin testing appropriate to the ingredient type and level of distribution.

These tests ensure your label guarantees are accurate and your products are free of contaminants that could harm animals or lead to product recalls.

If you’re not sure which category your product falls under or what analytes are required, we can help review your products and determine exactly what testing is necessary. Learn more about our compliance services here.

How To Log + Submit Samples The Right Way

Submitting samples through FDACS’s online system (the LIMS portal) can feel intimidating, but once you know the steps, it’s straightforward.

Here’s what you’ll do:

  1. Log in to lims.flaes.org.
    First-time users will need to reset their password and create a security question.
  2. Click “Compliance Sample Login.”
    You’ll see two tables: one for mixed feeds and one for feed ingredients, showing how many samples you owe based on tonnage.
  3. Enter your sample information.
    Include the:
    • Lab name and number (auto-fills when you select a certified lab)
    • Tons represented by the batch
    • Collection and submission dates
    • Product name (exactly as it appears on your registration)
    • Sampling method and location (e.g., “plant” or “warehouse”)
    • Analytes and contaminants to test (protein, fat, fiber, mycotoxins, etc.)
  4. Certify and submit.
    Click “I Certify,” then “Submit Compliance Sample.” Wait for the confirmation number before closing the page.
  5. Print and ship your form and sample.
    Print your submission report and include it with your physical sample. Then send it to one of the FDACS-certified laboratories listed below.

💡 Tip: You can use the “Compliance Sample Calculator” inside the LIMS portal to estimate how many samples you owe based on your tonnage reports for the year (July 1, 2025 – June 30, 2026).

Where To Send Your Samples

Florida only accepts testing from FDACS-certified laboratories. As of 2025, the following labs are approved:

  • Eurofins Central Analytical Laboratories – New Orleans, LA
    Certified for: Drugs and Mycotoxins
    eurofinsus.com
  • Eurofins Food Chemistry Testing Des Moines, Inc. – Des Moines, IA
    Certified for: Nutrients and Mycotoxins
  • Midwest Laboratories – Omaha, NE
    Certified for: Nutrients and Mycotoxins
    midwestlabs.com
  • NP Analytical Laboratories – St. Louis, MO
    Certified for: Nutrients and Mycotoxins
    npal.com
  • Trilogy Analytical Laboratory – Washington, MO
    Certified for: Nutrients and Mycotoxins
    trilogylab.com

Be sure to list the correct lab on your online submission form. Samples sent to unlisted or uncertified labs won’t count toward compliance. And if you need an intro to a lab, just message us!

Common Questions (and Missteps) About Florida Samples

1. I sell mostly treats. Do I need to send samples?

Maybe not. FDACS has confirmed that treats and milk products are exempt from sample requirements. But if your product has feed-like claims or nutritional guarantees, it might still qualify.

2. Can I skip a quarter if I’m a low-volume seller?

No. Sampling is required for every registrant with reported tonnage, regardless of volume.

3. Can FDACS staff enter my samples for me?

No. Only registered users can submit samples. FDACS cannot enter them on your behalf.

4. Can I use my own lab?

No. Only department-certified labs may test regulatory feed samples.

5. What happens if I miss the deadline?

Failure to submit a sample by September 30 may result in fines or delayed registration renewals. Two consecutive years of noncompliance trigger a $250 fine and possible registration suspension.

If you’re unsure whether your product is exempt or how many samples you owe, we can help you figure it out before the deadline. Book a free 15-minute consultation here.

How To Make Compliance Less Complicated

Florida’s feed regulations are clear but complex, and staying compliant takes organization. The good news? A few simple habits can make the process feel a lot more manageable.

Start early—don’t wait until the end of the first quarter to begin collecting and submitting your samples. Labs and regulators are at their busiest in September, and early submissions are processed faster and with fewer errors. Before you log in to the LIMS portal, double-check your product categories. Misclassifying a product in your tonnage reports can change how many samples you owe, which is an easy but costly mistake.

It’s also smart to track everything in one place. A simple compliance calendar can help you stay on top of sample deadlines, tonnage reports, and renewal dates so nothing slips through the cracks. Inside the LIMS portal, you’ll find Florida’s built-in sample calculator—a quick way to estimate how many samples you need based on your tonnage for the year.

And finally, remember that you don’t have to do it all yourself. For many pet food companies, outsourcing compliance is the simplest way to save time and avoid errors. We can manage your renewals, tonnage reports, and sample submissions across all 50 states—so you can stay focused on your products, your customers, and your growth.

The post Your Complete Guide To Florida’s Pet Food Sampling & Testing Requirements appeared first on Pet Food Compliance.

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Navigating Pet Food Licenses in the US vs. UK/EU https://petfoodcompliance.com/2025/09/16/navigating-pet-food-licenses-in-the-us-vs-uk-eu/ Tue, 16 Sep 2025 18:55:36 +0000 https://petfoodcompliance.com/?p=751 In the U.S., it’s usually the manufacturer or brand owner who holds the responsibility.
In the UK/EU, it’s the importer, but your reputation is still at stake if things go wrong.

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When headlines broke last year about H5N1 avian flu being detected in raw cat food in San Francisco, the story spread as quickly as the virus itself. Shelves were cleared, worried pet parents flooded Facebook groups, and regulators stepped in. For many in the industry, it was a jarring reminder: one contaminated shipment can set off alarms not just in your own backyard, but across borders.

Here’s what’s interesting: if that same product had been headed for the UK or EU, the response would have looked completely different. In the U.S., recalls and FDA/FSVP enforcement are the main tools. 

In Europe, the conversation would have started much earlier. In fact, it would have started at the border. Importers there must file pre-notifications in TRACES NT or IPAFFS, provide detailed Export Health Certificates, and prove that animal by-products meet strict rules before the food ever hits store shelves.

That contrast—reactive oversight in the U.S. versus preventative control in the UK/EU—says everything about how licensing and compliance differ depending on which side of the Atlantic you’re on.

How pet food licensing works in the U.S.

In the States, licensing often feels like juggling. Every state has its own rules, which means a brand launching nationwide has to navigate dozens of applications, fees, and tonnage reports. On top of that, the FDA expects facilities to be registered, and importers must run a documented Foreign Supplier Verification Program (FSVP).

Think of it as a patchwork quilt: each square (state) has its own pattern, and the FDA stitches them together with broader food safety oversight. Most companies end up tracking multiple state licenses, managing product registrations for each SKU, submitting annual tonnage reports, and making sure their FDA facility registration is up to date. If they import, the FSVP program adds another layer, requiring documentation that proves suppliers are vetted and hazards have been analyzed.

And let’s not forget animal-based ingredients. Chews, treats, or raw formulas can trigger APHIS permits or special declarations. In short, the U.S. system gives you room to get products on shelves quickly but relies heavily on enforcement after the fact—recalls, warning letters, and inspections are the pressure points.

How licensing works in the UK/EU

Across the pond, the focus isn’t on state-by-state approvals. Instead, the burden falls on the importer or distributor, and the whole system is designed to catch issues before products reach the consumer.

Before a shipment even leaves port, importers must:

  • Register with the national feed authority (APHA in the UK, or the competent authority in an EU Member State)
  • Prove compliance with feed hygiene rules (Regulation 183/2005), including HACCP documentation and facility registration
  • File pre-notifications through TRACES NT (EU) or IPAFFS (UK)
  • Provide detailed animal by-product (ABP) paperwork if raw or high-risk ingredients are used
  • Ensure labels comply with Regulation 767/2009, often in multiple languages

The philosophy is simple: the U.S. says “get licensed and we’ll deal with problems later,” while the UK/EU says “prove safety and traceability before we even let you in.”

Timelines, costs, and paperwork you can’t ignore

The UK/EU Pet Food Regulatory Guide lays out a week-by-week roadmap, and it shows just how front-loaded the process is. Instead of trickling in requirements, most of the heavy lifting happens before your product ever ships. Here’s what a typical first-time exporter timeline looks like:

WeekAction
1–2Appoint a responsible importer or distributor in the UK/EU
2–3Register with the competent authority (APHA in the UK or national feed authority in an EU Member State)
3–5Prepare HACCP documentation, facility registration, and supplier agreements
4–6Submit Export Health Certificate (UK) or CHED-P via TRACES NT (EU)
5–7Develop compliant labeling (multilingual for EU)
7–9Book customs broker and align logistics
9–10First shipments cleared at Border Control Posts

Costs aren’t negligible either. Facility registration runs around £1,000 in the UK or €1,200 in the EU, and every shipment requires an EHC or CHED-P certificate that costs about £150/€150. Add in translations, certificate preparation, and customs broker fees, and it’s easy to see why brands underestimate the financial and time investment of expanding overseas.

Common pitfalls that stop shipments cold

Plenty of U.S. brands have learned the hard way that what worked at home doesn’t always fly in Europe. The most common mistakes include:

  • Leaving the importer’s address off the label
  • Using a U.S.-style “Guaranteed Analysis” instead of the EU-required “Analytical Constituents”
  • Shipping English-only labels into non-English markets like France or Germany
  • Overstating claims such as “100% natural,” which face tighter scrutiny abroad
  • Forgetting durability dates or lot numbers required for traceability

Each of these errors has led to shipments being stopped at customs. They’re small details, but they carry big consequences. If you want help with this, we’d love to chat!

A shared lesson from H5N1

Back to that San Francisco story: the contamination triggered recalls and FDA oversight, but not before the product reached consumers. In the UK/EU, the shipment likely wouldn’t have cleared customs without the right paperwork on sourcing, processing, and disease status.

Neither system is perfect, but both highlight what matters most for brands: knowing where you’re selling, who carries the compliance burden, and how risk is managed. 

In the U.S., it’s usually the manufacturer or brand owner who holds the responsibility.

In the UK/EU, it’s the importer, but your reputation is still at stake if things go wrong.

What to do next

So what should a growing brand do? Start by mapping out where you plan to sell. If you’re U.S.-only, get familiar with each state’s licensing requirements, track your renewal dates, and make tonnage reporting part of your rhythm. If you’re importing, don’t just file an FSVP binder and call it good—build a real program that documents supplier audits, hazard analyses, and verification steps.

For the UK and EU, plan ahead for longer lead times. Appoint your importer early, build HACCP and traceability into your production process, and don’t underestimate the time it takes to apply for EHCs or access TRACES NT. 

Most importantly, get your labels right before you print thousands of bags. A multilingual, Regulation 767/2009-compliant label is a lot cheaper to produce at the start than to redo after customs seizes your first shipment.

If you want your brand to grow globally, you’ll need to play by both sets of rules. The good news? You don’t have to do it alone. Whether it’s a state regulator in Montana asking for tonnage reports or a customs officer in Rotterdam asking for an EHC you didn’t know you needed, we can help you prepare before those headaches hit.

The post Navigating Pet Food Licenses in the US vs. UK/EU appeared first on Pet Food Compliance.

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Take This 2-Minute Quiz To Avoid Expensive Labeling Mistakes https://petfoodcompliance.com/2025/08/28/take-this-2-minute-quiz-to-avoid-expensive-labeling-mistakes/ Thu, 28 Aug 2025 07:16:00 +0000 https://petfoodcompliance.com/?p=742 2 minutes could save you thousands of dollars and weeks of stress.

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Picture this: you’re getting ready to launch a new line of high-protein freeze-dried cat treats.  You’ve got the recipe locked in, the branding is colorful and enticing, and you’re proud of the ingredients you’ve sourced. But before you start shipping products or sending out samples, there’s one more box to check: Is your label compliant?

You might assume the answer is yes. After all, you modeled it after a product that’s already in stores. But, regrettably, pet food labels are a regulatory minefield and just because something looks right doesn’t mean it is.

That’s why we created this free label audit quiz – a fast, free tool that helps you determine whether your label might need a closer look.

Why pet food labels are more complicated than you think

Most pet food founders are surprised to learn just how complex label requirements can be. It’s not just about ingredient lists and brand names. Your label needs to meet AAFCO guidelines, follow FDA regulations, and stay within the rules set by each state where your product will be sold.

And when your label makes certain claims—like “supports joint health" or “calming formula"—you’re entering a whole new level of scrutiny. Functional treats and health supplements are regulated differently, and mislabeling them could mean expensive reformulations, product delays, or even legal action.

We’ve worked with clients who thought they were just a few weeks away from launch… until their label hit a regulatory snag that set them back by months.

The good news? Our quick quiz can help you catch those problems before they cost you.

How the label audit quiz works

We built this quiz for busy people who want a fast, reliable gut-check on where they stand. It takes just 2 minutes to complete, and it walks you through questions like:

  • Does your label include feeding directions or a guaranteed analysis?
  • Are you making any functional or therapeutic claims (e.g., “calms anxiety," “relieves joint pain")?
  • Does your product blur the line between food and supplement?
  • Are you using novel ingredients like slippery elm bark or MSM?

At the end, you can upload a photo of your label and get a recommendation on whether your label is good to go or should be submitted for a full audit.

A full label audit typically ranges from $300 to $550—a fraction of what you might spend if a regulatory agency flags your label after launch.

Common issues the quiz helps uncover

One of the biggest risks in the pet food world is labeling something as a treat when it’s really a supplement—or listing ingredients that have pharmacological effects without the right disclaimers or approvals. We’ve seen:

  • Products with dosage instructions instead of feeding guidelines
  • Labels that use medical language like “treats arthritis"
  • Claims like “human grade" without the substantiation to back it up
  • Gaps in required elements (like listing a calorie count but skipping guaranteed analysis)

These things don’t just raise red flags—they can derail your entire go-to-market timeline.

A 2-minute quiz that could save you months of cleanup

Running a pet food company is already hard enough without getting bogged down in regulations you didn’t know existed. Our goal with this quiz is simple: give you peace of mind, fast.

If you pass the quiz? Great. You’ve got confidence moving forward.

If the quiz flags a potential issue? Even better. You caught it early, and now you can fix it before it causes problems.

We built this quiz to save you:

  • Time (no back-and-forth with regulators for 3 months)
  • Money (no surprise reformulations or relabeling)
  • Reputation (no product pulled from shelves)

Take the quiz now and get clarity in minutes!

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