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Pet Food Regulations
on October 5, 2016

‘Human grade’ pet food labels tricky for manufacturers

With the new definition and guidelines for use locked in, some pet food manufacturers are eager to use the label. But implementation is proving challenging.

As mentioned in the September 2016 issue of Petfood Industry magazine, the Association of American Feed Control Officials (AAFCO) recently adopted a new definition and guidelines for use of the term "human grade" on pet food labels. While many in the industry are eager to incorporate the term in their labeling, its implementation is proving difficult for some.

The definition appears clear and succinct. It reads:

“Human Grade: Every ingredient and the resulting product are stored, handled, processed and transported in a manner that is consistent and compliant with regulations for current good manufacturing practices (CGMPs) for human edible foods as specified in 21 CFR Part 117.”

The accompanying guidance further explains that this use is solely applicable to the product as a whole; i.e., that even "made with human grade ingredients" is false and misleading unless the product itself fully conforms to the rules. Further, because the product is ultimately intended for animals, that fact must be made crystal clear, so the words "human grade" on the label and labeling cannot exceed the size of the species designation statement; e.g., "dog food" or "for cats." 

Part 117 of the Code of Federal Regulations is a newly promulgated section of the regulations under the US Food and Drug Administration (FDA), necessary to implement aspects of the Food Safety Modernization Act (FSMA) as it pertains to food for human consumption. In fact, it is so new that for some smaller firms the need for compliance with the rules…

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