With a history spanning more than a century, the industry organization Association of American Feed Control Officials (AAFCO) has been leading the charge on setting ingredient definitions, labeling standards, and laboratory standards for animal feed and feed ingredients. This includes pet food and ingredients. And for the better part of a decade, AAFCO has been engaged in the Pet Food Label Modernization (PFLM) project aimed at updating AAFCO's model regulations setting forth the requirements for pet food labeling.

That's likely why when AAFCO launched its revised Model Regulations for Pet Food and Specialty Pet Food (2023 Model Pet Food Regulations) in July 2023, there was no surprise and not much of an uproar from the industry or regulators. Instead, the 2023 Model Pet Food Regulations have received unanimous support from heads of state departments of agriculture and generally have industry support. This is important because it's the individual states that must now adopt and implement the 2023 Model Pet Food Regulations to give them the force and effect of law. And that won't happen without industry and regulator buy-in. 

Pet Food Labels

What are the major updates to pet food labels AAFCO suggests? Well, it looks a lot more like human food packaging than current pet food packaging. Notable changes include the following:

• A Pet Nutrition Facts Box, that looks similar to the Nutrition Facts Panel for human food.
• Calorie content is now broken down into calories from protein, fat, and carbohydrates to "achieve or maintain a healthy body weight for your pet."
• Nutrient information is in common household measurements, like cups, instead of only a guaranteed analysis percentage.
• New symbols were designed for packaging to be used for handling and storage recommendations.

Advertising Standards

There are a number of important labeling rules that address common false advertising claims in pet food labeling, including:

• Vignettes or graphics must not misrepresent the contents of the package.
• Use of "Proven" is not allowed unless the claim is substantiated by scientific or other empirical evidence.
• Product comparisons must not be false or misleading.
• Endorsements must not be false or misleading.
• "Improved," "New," or similar statements must be substantiated and limited to six (6) months production.
• Preference or comparative label claims must be substantiated and limited to one (1) year production, after which the claim must be removed or re-substantiated.
• There are also a number of rules on whether ingredients or other terms may be used in the name of the product. Review the model rules for more details. 

Looking Ahead

Note that these model rules don't have the force and effect of law yet, but given their widespread acceptance by regulators, they are likely to be adopted by states in the near future. Even so, AAFCO recommends states provide a generous six-year transition period for pet food companies. Meaning that, under AAFCO's proposal, pet food packaging with labeling in line with the 2023 Model Pet Food Regulations would not be on the shelves until at least 2030, depending on when they are adopted by each state.