FDA faces renewed pressure on pet food labeling and GRAS

FDA’s pet food oversight is under renewed scrutiny from two directions: a delayed but potentially sweeping GRAS reform proposal, and a fresh challenge to the agency’s refusal to require “feed grade” disclosure on pet food labels. The immediate trigger for the latest dispute is a Petition for Reconsideration filed by the Association for Truth in Pet Food after FDA denied its earlier citizen petition on March 16, 2026. At the same time, FDA’s broader proposed rule to require GRAS notices for certain uses in human and animal food has slipped to December 2026, extending uncertainty for ingredient suppliers and manufacturers. (truthaboutpetfood.com)

The background here matters. Since FDA finalized the GRAS rule in 2016, companies have been able to conclude on their own that a substance is GRAS under its intended conditions of use and, if they choose, notify FDA through a voluntary process. FDA has said that under the current framework, a company may introduce a human or animal food substance purported to be GRAS without FDA notice or review. The agency’s 2026 Human Foods Program priorities now frame GRAS reform as a major oversight initiative, and the regulatory agenda states that the coming proposal would require GRAS notices for certain uses of food substances in both human and animal food. (fda.gov)

The label-disclosure fight has a separate history. Truth about Pet Food has been pressing FDA since July 21, 2022 to require pet food labels to disclose when ingredients are “feed grade.” After waiting what Susan Thixton said was 1,333 days for a response, FDA denied the petition in March 2026. In that denial, the agency said there is no standard of identity established under section 401 of the FD&C Act for animal food ingredients, rejected the claim that “feed grade” ingredients are “optional ingredients,” and said the petition did not provide evidence that consumers are misled when pet food ingredients are labeled simply as “chicken” or other common names. (truthaboutpetfood.com)

In the reconsideration petition filed in April 2026, Thixton argues FDA is overlooking misleading representations on labels, especially when products use imagery like roasted meat or claims such as “Made with Real Chicken” while the underlying ingredients may not match what pet parents assume. The petition contends that some animal foods use USDA-inspected and passed meats while others do not, yet labels do not distinguish between them, and it asks FDA to require disclosure of feed grade ingredients for transparency. The filing asks FDA to respond within 45 days. (truthaboutpetfood.com)

Industry and regulatory context suggests this debate won’t stay confined to one petition. FDA’s animal food labeling page says federal rules require ingredients to be listed by common or usual name in descending order by weight, and notes that many states rely on AAFCO model regulations and ingredient definitions. FDA also continues to point industry toward AAFCO ingredient definitions, GRAS notices, food additive petitions, and the newer animal food ingredient consultation pathway. In practice, that means ingredient oversight in pet food remains a patchwork of federal law, FDA enforcement policy, AAFCO definitions, and state feed control adoption, which helps explain why labeling disputes can be hard to resolve through a single petition. (fda.gov)

Why it matters: For veterinarians, technicians, and nutrition-focused practices, these developments are less about political process than about how confidently they can interpret pet food labels and ingredient safety claims for clients. If FDA ultimately moves toward mandatory GRAS notifications for new substances claimed to be GRAS, clinicians may gain a more transparent regulatory backstop for at least some ingredients entering the animal food market. If the agency continues to reject feed-grade disclosure, however, the gap between what labels legally say and what pet parents believe they mean will remain a live issue in exam-room conversations, especially in cases involving adverse food reactions, elimination diets, or clients seeking higher-transparency products. That does not necessarily mean current products are unsafe, but it does mean regulatory status and consumer understanding are not always aligned. That last point is an inference based on FDA’s denial, current labeling rules, and the petitioner’s arguments. (reginfo.gov)

There’s also a business and compliance angle for the veterinary sector. Pet food companies, ingredient suppliers, and veterinary diet manufacturers are watching the GRAS proposal because mandatory notification could add procedural burden, alter timelines for ingredient commercialization, and increase public visibility into safety determinations. PetfoodIndustry reported that AFIA said the broader U.S. food and animal food regulatory review system is already rigorous, signaling that any move away from self-affirmed GRAS will likely draw close industry scrutiny. (reginfo.gov)

What to watch: The next concrete milestone is December 2026, when FDA is scheduled to publish the proposed GRAS rule. On the labeling side, the near-term question is whether FDA answers the reconsideration petition, and the longer-term question is whether pressure for clearer pet food ingredient disclosure shifts from petitions into formal rulemaking, guidance, or state-level AAFCO action. (reginfo.gov)