We have waited 1,132 days for FDA’s response

1,132 days ago we submitted a Citizen Petition to FDA Center for Veterinary Medicine (CVM), asking the agency to provide pet food consumers with transparency to what they are purchasing for their cats and dogs.

Federal law requires FDA CVM to respond within 180 days. However, the only response we have received from the agency is (dated January 11, 2023): “FDA is currently considering the issues raised by your citizen petition; however, the Agency will require additional time to issue a final response.”

We have asked FDA CVM multiple times over the years when we can expect to receive their response, the Agency ignores these questions. The most recent requests we have sent to the agency for an estimated date of response to our Citizen Petition were July 7, 2025, July 14, 2025, July 28, 2025 and August 7, 2025. FDA CVM did not respond to any of these requests.

Currently (because FDA CVM does NOT enforce federal law in pet food), pet owners are not informed if they are purchasing a pet food that could contain highly inferior (feed grade) ingredients. As an example, ‘chicken’ listed in the ingredient panel of one pet food could be the type of chicken you are familiar with; USDA inspected and passed chicken. But, ‘chicken’ listed in the ingredient panel of another pet food could be condemned, diseased, decomposing chicken. Even pet foods that claim ‘Made with Real Chicken’ could be sourcing condemned, diseased, decomposing chicken without disclosure on the pet food label. 

Further, it is not just chicken. Every single ingredient in pet foods has a unique definition that can be VERY different from the same ingredient in human food.

Federal law prohibits this type of consumer deception. 

Title 21, Chapter 9 Federal Food, Drug and Cosmetic Act, Subchapter IV Food, Section 341 Definitions and standards for food states:

“In prescribing a definition and standard of identity for any food or class of food in which optional ingredients are permitted, the Secretary shall, for the purpose of promoting honesty and fair dealing in the interest of consumers, designate the optional ingredients which shall be named on the label.”

Specific to animal food, federal law states:

“The common or usual name of a food, which may be a coined term, shall accurately identify or describe, in as simple and direct terms as possible, the basic nature of the food or its characterizing properties or ingredients. The name shall be uniform among all identical or similar products and may not be confusingly similar to the name of any other food that is not reasonably encompassed within the same name. Each class or subclass of food shall be given its own common or usual name that states, in clear terms, what it is in a way that distinguishes it from different foods.”

These laws mean that condemned, diseased, decomposing chicken CANNOT be named ‘chicken’ (on a pet food label) because it is “confusingly similar” to USDA inspected and passed chicken. Condemned, diseased, decomposing chicken is a “subclass” of USDA inspected and passed chicken and law requires it to be “given its own common or usual name…that distinguishes it…” for pet food consumers.

Our Citizen Petition suggested to FDA to require pet food manufacturers to label pet food ingredients as either ‘chicken’ (if the ingredient meets the legal requirements of the Poultry Products Inspection Act/USDA inspected and passed) or the subclass ‘feed grade chicken’ (if the ingredient does not meet the legal requirements of chicken). This would be a simple, easy to understand way for pet food consumers to know what they are purchasing. 

Regardless, federal law requires disclosure to consumers…and FDA CVM needs to promptly facilitate the pet food label disclosures.

But…the agency has delayed responding to our legal request for 1,132 days.

We are asking for your help to nudge FDA CVM into responding. Please send the agency the following (or similar) email:

Email: AskCVM@fda.hhs.gov

Subject: Docket ID FDA-2022-P-1643

I am requesting CVM provide a full response to Docket ID FDA-2022-P-1643. Law requires label disclosure of subclass (feed grade) ingredients, and pet owners across the US deserve to know what they are purchasing. Pet owners have waited more than 1,130 days for CVM’s response, that is long enough. Provide pet food consumers with transparency to what we are purchasing as this Citizen Petition suggested.

[your name]

Thank you in advance for your help!

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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