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Pet Food Regulations / Pet Food Labeling
On August 5, 2013

‘Made in USA’ claims: What’s required for petfood products?

Many factors must be considered by petfood manufacturers before product labels can be placed.

To appeal to the concerns of many petfood purchasers in the US, the claim "Made in USA" or similar verbiage, often accompanied by a depiction of the American flag, is not uncommon on petfood labels these days. Neither the US Food and Drug Administration (FDA) nor the Association of American Feed Control Officials (AAFCO) has any regulations or expressed policies regarding use of the claim. Rather, the only written guidance offered on the matter is that by the Federal Trade Commission (FTC) (see business.ftc.gov/documents/bus03-complying-made-usa-standard). While this guidance has been available for a number of years now, the need for petfood labels to meet the criteria set forth by FTC has only recently become more than an academic exercise. In the past few months, at least one state feed control official has begun asking petfood registrants for documentation of compliance with FTC guidance. Thus, for those petfood companies wishing to make the claim, it is prudent to obtain and keep adequate documentation on hand before some regulator asks for it.Regarding country of origin  labeling of imported food (including petfood) items, FDA works cooperatively with US Customs and Border Protection (CBP) in enforcement of the latter's regulations (Title 19 of the Code of Federal Regulations Part 134, see www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074567.htm).The CBP regulations require that labels identify the country of origin unless there is a "substantial transformation" of the food in the US before distribution to the public. The example used is with shrimp. If the shrimp is imported from another country, and once ...

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