AAFCO issued enforcement discretion guidance allowing state feed programs to delay enforcement of revised feline calcium and phosphorus nutritional profiles during an implementation period aligned with the Pet Food Label Modernization effort, supporting manufacturers through reformulation and compliance without requiring separate product registration.
- AAFCO approved revised feline calcium and phosphorus nutritional profiles based on expert panel findings presented in January 2025 and approved in August 2026.
- State programs are encouraged to refrain from enforcement action during the implementation period while manufacturers reformulate, validate, and analytically verify products.
- Manufacturers do not need separate registration or fees when reformulating solely to meet the revised profiles.
- The revised profiles apply to both legacy and PFLM-labeled products, and manufacturers can maintain their planned label conversion timeline.
- AAFCO will periodically review implementation progress, including analytical methods, ingredient availability, manufacturing considerations, and registration issues.
The Association of American Feed Control Officials (AAFCO) issued a final position on enforcement discretion related to feline calcium and phosphorus nutritional profile updates, outlining how state feed regulatory programs are encouraged to approach implementation of the revised profiles.
The revisions stem from an expert panel convened in 2023 by AAFCO’s Pet Food Committee (PFC) to review research on calcium and phosphorus in feline nutrition. The panel’s findings were presented to the PFC at AAFCO’s January 2025 midyear meeting, and membership approved the revisions at the August 2026 annual meeting. According to AAFCO, the revised profiles are intended to reflect current scientific understanding of feline nutritional needs and health outcomes.
“Implementing these changes will take real work, including formulation review, validation of nutritional adequacy, analytical verification, quality system updates and manufacturing changes across many product lines,” said Austin Therrell, executive director of AAFCO, in an email to members and partners.
Therrell noted that the work is occurring alongside implementation of the revised Model Regulations for Pet Food and Specialty Pet Food under the Pet Food Label Modernization (PFLM) effort.
“As the industry navigates these changes, AAFCO recommends a single, aligned approach rather than a separate timeline,” Therrell said.
Enforcement aligned with PFLM timeline
Under the position, AAFCO recommended that state programs refrain from enforcement action against products that do not yet comply with the revised feline calcium and phosphorus profiles during the implementation period established under AAFCO’s PFLM enforcement discretion position.
During that period, AAFCO encouraged states to work cooperatively with manufacturers and distributors as products are evaluated, reformulated where necessary, analytically verified, manufactured and introduced into commerce.
The revised profiles apply to products using either legacy or PFLM labels, according to AAFCO. Manufacturers do not need to convert to the PFLM label format ahead of their planned schedule in order to comply.
Registration and ongoing review
For products reformulated solely to meet the revised profiles, AAFCO recommended that participating states not treat the change, on its own, as a new product or formula requiring separate registration or an additional registration fee. AAFCO stated that each state retains authority to determine when a product is new or requires registration under its own statutes or regulations.
The PFC will periodically review the recommendation and may recommend changes to support nationally consistent implementation, according to AAFCO. Issues under review will include progress toward implementation, analytical methods and laboratory capacity, ingredient availability and reformulation challenges, manufacturing and supply chain considerations, and registration and marketplace issues.
AAFCO stated that the recommendation should not be interpreted as delaying implementation of the revised nutritional science.
“This recommendation supports orderly, practical and harmonized implementation across jurisdictions while maintaining confidence in the safety, nutritional adequacy and quality of commercial cat foods,” Therrell said.
