The pet food industry has been steadily growing in the last few decades owing to Americans’ increasing acceptance of pets as being part of the family. Small business owners are some of the trade’s drivers, as it generates profit margins as high as 40% and revenues of $30-40 billion annually.

Pet Food Labeling

The government enforces strict pet food marketing regulations to ensure the health of our animal friends. Recalls are made not only for unacceptable adverse reaction occurrences but also for misleading claims. Here, we share this pet food labeling guide to help small businesses stay compliant and do their part in protecting American pets. 

Why Is Pet Food Labeling Important?

We pointed out in our previous articles that product labels protect both the customers and business owners. This applies to items meant for human and animal consumption.

For customers. labels let them easily identify the products they want to buy. They give important information about proper usage and first aid measures for side effects to help ensure safety. By supplying the manufacturers’ contact information, customers can reach out and report adverse events or give feedback that can improve the merchandise.

For business owners, product labels let them stay compliant with the law. For example, the FDA does not require premarketing approval for animal food unless it has a component that can be classified as a drug. However, before marketing pet food, it must first be registered in the states where it is intended to be sold, and part of the approval process is labeling compliance. 

Additionally, well-designed labels spice up product packages to enhance their shelf appeal. The creative application of brand colors creates customer loyalty, which is the fuel that enables mom and pop businesses to grow and remain resilient.

Small business owners who want to invest in the pet food industry must keep in mind these important roles of product labels.

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What Government Agencies Regulate Pet Food Labels?

According to the FDA, pet food labeling has two regulatory controls.

The first comes from the FDA itself, through the Center for Veterinary Medicine (CVM). The agency oversees pet food labels, making sure they adhere to the part of the Code of Federal Regulations concerning animal food labeling (21 CFR 501).

The second comes from each state, which has local branches of the US Department of Agriculture (USDA). Many territories implement the model pet food standards set forth by the Association of American Feed Control Officials (AAFCO).

US pet food labels bear information specified by these government units.

dog food label

What Information Is Required on a Pet Food Label?

According to AAFCO, pet food label information can be classified according to its location on the packaging. Details concerned with brand and product identification are found on the principal display panel (PDP). The PDP is the package’s most prominent area and is usually in front. Other product data may be placed on the sides and rear, which comprise the information panel.

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Both the FDA and local government check for completeness and accuracy of information. However, the state is more involved with some because they appear on AAFCO’s model regulations.

What-Information-Must-Be-on-a-Pet-Food-Label

Information Appearing on the PDP

1. Brand name

The brand name is the name used for marketing the product, e. g. “Purina.”

2. Name of the species for which the pet food is intended

The label must state this conspicuously after the brand name, e. g. “Purina Dog Chow.”

3. Product name

The product name identifies the contents, and it may be stated before or after the species name. From the FDA’s rules, the product name must correlate with its composition.

    • The 95% rule

If at least 95% of the product is made of only one ingredient, it is named after that ingredient.

Examples:

“Beef for Dogs”—this means that beef makes up at least 95% of the product.

“Chicken ‘n Liver Dog Food”—this means that at least 95% is composed of chicken and liver, but chicken predominates by weight.

    • The 25% rule

This is also called “the dinner rule.” For products following this rule, the named ingredients comprise 25-95%. Words other than “dinner” may be used, such as “platter,” “nuggets,” “formula,” “entrée,” etc.

When this rule is used, the named ingredient is not always the primary one. For example, “Chicken Formula Cat Food” may have 25% chicken but with the fish component making up 30% or more. A feline pet allergic to fish may not be able to tolerate the product.

    • The 3% rule

This is otherwise known as “the with rule.” Here, the ingredient’s presence is emphasized on the PDP though it is not included in the brand name. For example, “Chicken Formula Cat Food with Cheese” contains at least 25% chicken and at least 3% cheese.

    • The “flavor” rule

Here, the ingredient is detectable, but a percentage is not required. An example is “Beef-Flavored Dog Food.” Note that artificial flavors are rarely used in pet foods. Smoke and bacon flavors, however, may come from artificial sources.

4. Net quantity statement

This must appear conspicuously on the PDP below the brand name, species and product name. It must be in the format specified in the 21 CFR 501.

5. Other claims

The term “human-grade” appears a lot on pet food labels these days, signifying the rising importance of pets in American households. To authorize its use, the product must pass the FDA’s manufacturing and distribution standards for human food.

The label may be classified as misleading if these standards are not met, and the business owner can get sanctioned for the deceptive act.

Other claims that may appear on the PDP for marketing purposes may have no CFR definition.

  • In some cases, other government agencies, like the USDA, may authorize their use after specific requirements are met. For example, business owners may use the term “organic” to denote the conditions under which the pet food’s plant or animal source is raised. But first, they must obtain National Organic Program (NOP) accreditation.

On the other hand, authorization for the term “Made in the USA” falls under the jurisdiction of the Federal Trade Commission (FTC). It can only be used on products with all or practically all of their parts and processing originating from America. Just obtaining the product from a US broker is not enough to merit the term’s use on labels.

  • In other instances, AAFCO may provide a definition, but the term must be used carefully because the said organization is not a regulatory body.

One example is the word “natural,” which can mean that the product lacks artificial flavors, colors or preservatives. Note that, although artificial flavors are rarely included in pet food, artificial colors and preservatives are sometimes used if they are necessary for processing and presentation.

To drop the term “veterinarian-recommended” on your label, you may need to get hundreds of veterinarians to endorse your product to substantiate the claim. Meanwhile, a “veterinarian-formulated” product needs only one animal doctor to enable its use on a pet food label.

“Veterinarian-approved” should never be used because only government regulatory agencies have the authority to approve pet food marketing and consumption.

  • Pet food retailers sometimes use vaguely defined terms to boost their products’ reputation. Such terms must also be used cautiously because they can be misleading without any set usage standards.

Examples are “premium” and “gourmet,” which suggest high quality. However, using these words does not guarantee that a product has quality ingredients or good nutrient profiles.

Pedigree Chopped Gound Dinner front label
Pedigree Chopped Gound Dinner back label

Information Appearing on the Information Panel

1. Ingredients list

The FDA requires that ingredients are listed by their common or usual names in decreasing predominance by weight. Components with chemical-sounding names, such as vitamins and colors, may be listed under their recognized chemical names. For ingredients with confusing designations, you may check out AAFCO’s official publications, which define a number of pet food ingredient names.

CVM can prohibit or modify the use of an ingredient in pet food if it shows potential for harming animals. For example, melamine-containing products were recalled in 2007 when many cats and dogs were reported to have died from its ingestion.

2. Guaranteed analysis

This is part of AAFCO’s labeling standards. It requires that pet food manufacturers guarantee the following about their products, declared on an “as fed” or “as is” basis:

  • Minimum percentages of crude protein and crude fat
  • Maximum percentages of crude fiber and moisture

The maximum percentage moisture content for pet food is 78% except if it is liquid, e. g. sauces and stews.

Guarantees for other ingredients, e. g. vitamins or minerals, may be added as long as they are substantiated by lab analysis.

3. Nutritional adequacy statement

Any claims that a type of pet food is “complete,” “balanced” or “100% nutritious” must be supported in either of two ways:

  • The products are formulated such that they meet AAFCO nutrient profiles. For these pet foods, the label will say, “(Name of the product) is formulated to meet the nutritional levels established by the AAFCO (Dog/Cat) Food Nutrient Profiles.”
  • The products are tested using AAFCO Feeding Trial Protocols. For these pet foods, the label will state, “Animal feeding tests using AAFCO procedures substantiate that (name of the product) provides complete and balanced nutrition.”

The product label should also indicate the life stage for which the product is suitable, e. g. “for growth,” ”for all life stages,” etc.

If a product does not satisfy the nutritional adequacy criteria, you may state in the label if you’re marketing it as a supplement, snack or treat.

4. Feeding directions

They include the daily amount per unit bodyweight of the pet. Feeding recommendations vary with the species and life stage. For example, young pets and nursing mothers may need more servings than animals in other life stages.

5. Calorie statement

This is expressed in kilocalories per kilogram of pet food and made on an “as fed” basis.

6. Manufacturer’s contact details

These are included for reporting side effects or giving feedback about the product. If manufacturer information is not available, the distributor’s information may appear instead.

More detailed explanations of these labeling information bits are available on the web pages of the FDA and AAFCO.

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What Else Should You Keep in Mind When Marketing Pet Food?

The FDA defines “small businesses” as those establishments with fewer than 500 full-time employees. Meanwhile, “very small businesses” generate sales of less than $2.5 million yearly. Farms and establishments (pet shelters, kennels, etc.) selling pet food directly to consumers for immediate consumption are exempt from FDA registration. However, they may need to show proof of compliance with USDA regulations before they operate.

Remember these definitions when you are applying for FDA approval for any product. Unlike when selling human food, small pet food businesses do not get labeling exemptions. However, exemptions for other aspects, particularly those involving preventive controls like hazard analysis, may be given upon request.

Another topic of concern is whether or not pet foods are covered by the Dietary Supplement Health and Education Act of 1994 (DSHEA). DSHEA is a set of laws that health supplement manufacturers and distributors must satisfy to market their products. Many pet foods are vitamin-enriched, but they are not classifiable as health supplements. Therefore, they are not covered by this act.

cats and dogs

Conclusion

The pet food business is a rapidly expanding trade because of American society’s increasing affection for pets. The government tightly regulates all aspects of manufacturing, including labeling, to keep the animals safe.

Both federal and state agencies are tasked to ensure pet food safety and marketing truthfulness. A pet food label must include the brand name, species for which it is formulated, product name and net quantity statement on the PDP. Its information panel must have the ingredients list, guaranteed analysis, nutritional adequacy statement, feeding directions, calorie statement and manufacturer or distributor information.

Any claims should be proven by means acceptable to the relevant government agencies or satisfy specific legal requirements for their inclusion on labels. Business owners must comply with the labeling rules to protect their brand as well as their customers.

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