From Petfood Industry:
In August 2013, Petfood Industry featured a column that discussed what is required for pet food products to claim they are “made in the USA.”
In that column, author David A. Dzanis said 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).
At the time, the need for pet food labels to meet the criteria set forth by the FTC had only recently become more than an academic exercise.
Regarding country of origin labeling of imported food (including pet food) items, FDA works cooperatively with US Customs and Border Protection (CBP) in enforcement of the latter’s regulations. However, the product must be of “negligible foreign content” to be worthy of the claim. Also, in determining percentage of US vs. foreign content, not only must the relative amounts by weight be considered, but also the relative costs. So, even if only a small proportion of a product consists of foreign-sourced ingredients, if they constitute a major fraction of the expense of manufacturing that factor needs to be considered, as well.
Recently, lawsuits filed against Tyson and Big Heart Pet Brands claim those companies’ pet treats do not accurately include “made in the USA” on their labels. The lawsuits say certain pet treat products are labeled as made in the US, should not because some of the product components are sourced from outside the country.
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.