FDA denies petition to require ‘feed grade’ pet food labels

The FDA has denied a long-running citizen petition that sought a major change in pet food labeling. In a March 16, 2026 letter responding to Docket No. FDA-2022-P-1643, the agency rejected requests to require pet food makers to disclose “feed grade” ingredients on labels, websites, and advertising, and to reserve claims such as “Made with Real Chicken” for ingredients that meet federal meat or poultry inspection standards for human food. The petition was filed on July 21, 2022 by Susan Thixton on behalf of the Association for Truth in Pet Food, making the FDA’s answer a decision that arrived after 1,333 days. (truthaboutpetfood.com)

The dispute sits inside a long-running tension in pet food regulation: ingredients and finished products are regulated as animal food, but marketing often borrows language and imagery that pet parents associate with human food. FDA says pet food must be safe, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled, while much of the practical ingredient and labeling framework is shaped through collaboration with the Association of American Feed Control Officials, or AAFCO. AAFCO itself has no regulatory authority, but its ingredient definitions and model rules are widely used by states and referenced by FDA. (fda.gov)

Thixton’s petition argued that ingredients commonly called “chicken” or “beef” in pet food can differ materially from products that meet the Poultry Products Inspection Act or Federal Meat Inspection Act for human food, and therefore should be distinguished as “feed grade.” In its response, FDA disagreed on both legal and evidentiary grounds. The agency said animal food ingredients are not “permitted optional ingredients,” are not necessarily “imitation” foods under 21 CFR 501.3, and do already have common or usual names through regulation or common usage. FDA also said the petition did not provide evidence that consumers are misled by current naming conventions or that adding “feed grade” would remedy any confusion. (truthaboutpetfood.com)

One of the sharpest points in the exchange concerns nutritional inferiority. Truth about Pet Food highlighted FDA’s statement that it had “no reason to think” poultry ingredients outside human-food inspection standards are nutritionally inferior for pets. In the formal response, FDA wrote that the petition had not submitted evidence showing such ingredients are nutritionally inferior for pets, which is a required element for an “imitation” theory under the regulation cited by the petitioner. FDA further said it does not think ingredients that conform to definitions applying only to animal food are an imitation of ingredients defined under the PPIA. (truthaboutpetfood.com)

The decision also lands against a broader backdrop of shifting federal policy on animal-food ingredients. In October 2024, FDA issued Guidance for Industry #293, stating it generally does not intend to initiate enforcement action regarding food additive approval requirements for ingredients listed in the AAFCO 2024 Official Publication, and it outlined a similar enforcement approach for certain ingredient names on animal food labels. That guidance followed the end of the older FDA-AAFCO memorandum framework and signaled a more explicit reliance on enforcement policy while the agency works through its own ingredient review processes. (fda.gov)

On “human grade” specifically, FDA’s denial does not weaken the existing AAFCO standard for companies that want to make that claim. AAFCO’s guidelines say the term “human grade” is only acceptable for the product as a whole, and only when every ingredient and the finished product are stored, handled, processed, and transported in compliance with human-food current good manufacturing practice requirements. AAFCO announced updated standards for human-grade pet food several years ago, reinforcing that this is a high-threshold claim rather than a general descriptor for premium ingredients. Recent advertising scrutiny shows the issue remains active: on March 17, 2026, BBB National Programs’ National Advertising Division recommended that certain Freshpet claims suggesting its dog food is “human grade” be discontinued. (aafco.org)

Why it matters: For veterinarians and practice teams, the FDA decision preserves a status quo that can be hard to explain in the exam room. “Human grade” has a defined, relatively strict meaning in the AAFCO framework, but the absence of a required “feed grade” disclosure means many pet parents may continue to assume ingredient names on pet food labels map directly to human-food standards when they do not. That doesn’t automatically speak to safety or nutritional adequacy, which are separate questions, but it does leave room for confusion around sourcing, processing, and marketing claims. Clinicians counseling pet parents on diet choice may need to keep separating three issues that often get blurred together: legal labeling standards, ingredient sourcing standards, and whether a food is complete, balanced, and appropriate for the individual animal. (truthaboutpetfood.com)

What to watch: Thixton has said she does not accept the FDA response and is considering next steps. Beyond any follow-on advocacy or legal challenge, the bigger issue to watch is whether pressure grows for clearer federal standards on pet food marketing language, especially as FDA continues using enforcement discretion for AAFCO-defined ingredients and outside bodies scrutinize “human grade” advertising more aggressively. (truthaboutpetfood.com)