While pet food trends tend to follow trends in human food, policy changes regarding human food shouldn’t necessarily be reflected in pet food, according to Dana Brooks, former president and CEO of the Pet Food Institute (PFI).
Brooks spoke April 28 during the 2026 Petfood Forum in Kansas City, Missouri, U.S.
The Make America Healthy Again movement championed by Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. focuses on food ingredients to address chronic diseases.
The key policy directives HHS is targeting that are particularly relevant for pet food manufacturers or ingredient suppliers is the limit on petroleum-based food dyes, or FD&C colors, to prioritize natural color alternatives to evaluate risks from microplastics exposure; developing a definition for ultra-processed foods (UPF); and reforming the generally recognized as safe (GRAS) designation, Brooks said. Self-GRAS, which is a largely voluntary process allowing food manufacturers to determine that a substance is safe without notifying the U.S. Food and Drug Administration (FDA), is considered by Kennedy not to be transparent.
“What’s going on in human food certainly will impact us in pet food,” Brooks said. However, she added, “pet food differs fundamentally from human food … because we have complete and balanced nutrition, sole-sourced diets, as well as requirements of 40 essential nutrients. That’s different from human food.”
HHS is already phasing out dyes, advancing the definition of “ultra-processed” and preparing for GRAS changes.
“Any policy decisions that come about from the definition of UPF need to be strongly considered for reasons and purpose of ingredients in the final product and not just an arbitrary number,” Brooks said.
HHS considers a long list of ingredients as negative, however, pet food tends to have long lists of ingredients that are necessary for the health and well-being of the pets that consume it. Additionally, pet food processing is part of ensuring food safety as well as nutrient stability, Brooks said.
“PFI argues that ingredient count alone is not an appropriate measure for processing in pet food and policies must reflect nutritional function and safety,” Brooks said. “For pet food manufacturing, ingredients are not just added for convenience or variety.”
Removing ingredients from pet food could result in nutritional deficiencies and toxicities, leading to chronic diseases for pets, she added.
Potential changes to ingredient review process
In addition to the previously mentioned changes, FDA is evaluating changes to the ingredient review process, and the industry is awaiting FDA’s proposed GRAS rule this year.
“This could be the greatest shift in ingredient oversight in decades,” Brooks said.
The GRAS rule shapes innovation and regulatory structure, she said, so “any new system must recognize a long history of safe use for many ingredients essential for complete and balanced nutrition.”
Several changes are likely in the GRAS reform process including elimination of self-GRAS, an FDA “database” or website for notifications, and triggers for regulatory review of an approved product.
Brooks said the industry should expect increased transparency with clear milestones.
“Together, these changes will shape not just how ingredients are reviewed, but how quickly companies can innovate and bring new products to market,” she said.
Because these changes have the potential to shape the pet food industry, the industry must be involved. The pet food industry needs a risk-based regulatory approach, federal pre-emption to codify ingredients that have already been in use in the marketplace, transparency in regulatory decision-making, and timeliness and predictability of FDA reviews.
“This is a significant period of regulatory change and requires industry engagement,” Brooks said.
