Processing Pet Food for Sale

This page was developed with input from experienced producers, processors, and regulators.

Consumer interest in raw, local and/or organic diets for their pets has increased greatly in recent years. With Americans spending over $60 billion on their pets annually, many meat processors are looking for ways to access the growing pet food market.

While customers buying scraps and bones for their dogs from their local butcher is nothing new, if you are going to label and sell a product as “pet food,” “dog food,” “dog treats,” and so forth, you need to follow the appropriate regulations — and stay current as they evolve.

Who Has Jurisdiction?

The U.S. Food and Drug Administration (FDA) has primary regulatory jurisdiction over pet food, but the U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA FSIS) also has a say, because it regulates inspected facilities. Many processors are familiar with USDA regulations but less familiar with FDA. FDA will regulate directly when the product is shipped interstate. An overview of FDA’s role in regulating pet food can be found here.

Otherwise, FDA’s rules about inspections, labeling, and licensing are typically implemented by states, through a state-level commercial feed/livestock/pet food regulatory agency, usually within the state agriculture department. The Association of American Feed Control Officials (AAFCO) website provides a list of each state’s regulatory agency.

The AAFCO website provides comprehensive, user-friendly information about starting a pet food business, registration and licensing, ingredients, product handling, labeling… everything you need to know. Here, we provide some initial information to get you going.

What Counts as Pet Food?

FDA includes the following in its definition:

Dog and cat food, aquarium fish food, raw meat and raw poultry formulations for pets.
Pet treats or chews (e.g., dog biscuits, rawhide, pig ears)
Vitamins, minerals, and other nutritional supplements intended for dogs, cats, and other pets.
Pet food ingredients such as animal products, plant protein products, grain products, vitamin and mineral products.

What Are the Rules?

FDA requires that all animal foods, like human foods, be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled. What that means in practice is spelled out on the AAFCO website.

However, keep in mind that USDA-FSIS has its own requirements for inspected processors who want to make pet food. A good first step is to talk to your current inspector about what you want to do. You may need to declare when during the day or week you will be making pet food to ensure it is separate from human food in time or space.

USDA-FSIS has the following requirements for pet foods produced in a USDA inspected facility:

Complete segregation from inspected product through the whole process;
Handled in the same manner as edible product (sanitary conditions, temperature, employee hygiene, etc.);
Produced from product that could be used for human food. (No inedible products, no products that deviated from HACCP plan, etc.);
Labeled according to poultry or red meat regulations (but without the inspection legend or “bug”);
Produced during inspection hours.

The full regulations are spelled out in 9 CFR 318.12 and 9 CFR 381.152. This notice is also helpful: USDA/FSIS Notice 26-13 – Manufacture of Animal Food or Uninspected Articles at Official Establishments. Additional requirements, spelled out in 9 CFR 355, apply if you want to certify that the pet food you are making meets certain specific nutritional standards.

A tip about labeling and marketing: If you make a product that is labeled for human consumption but you know your customers buy it for their pets, do not have any point of purchase information (posters, brochures, etc.) that indicates it could be fed to animals.

More questions about FSIS regulations? Go to AskFSIS, where FSIS posts answers to regulatory questions, and type in “pet.” If your question isn’t answered, you can post it yourself, and FSIS will answer. More about using AskFSIS.

Issues to Watch

Salmonella

FDA’s regulations on pet food are changing. Salmonella contamination is a particular concern, especially for dogs: it can make dogs really sick or even kill them. Humans who handle contaminated pet food can also get salmonella if the product is not treated properly. In July 2013, FDA published Guidance for FDA Staff: Compliance Policy Guide for Sec.690.800 Salmonella in Food for Animals and a notice in the Federal Register.

Food Safety Modernization Act

In addition to current FDA regulations and guidance, the Food Safety Modernization Act (FSMA) will also affect pet food processing. In October 2013, FDA released a draft proposed rule regarding pet food: FSMA Proposed Rule to Establish Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals. The New York Times covered the proposed ruling in a recent article entitled FDA Bids to Regulate Animal Food, Acting After Recall and Deaths. The link to that article is here (may require subscription). The rule is currently open for public comment.

FDA maintains a website on FSMA and animal feed: check here for updates. We’ll also update this page as new FSMA regulations roll out.