Organic Pet Food Regulations to be Cut Due to Deregulation Initiative

The USDA Agricultural Marketing Service has posted an announcement on Regulations.gov its plan to withdraw all existing rules for organic pet food. “AMS is proposing to rescind the rule and regulations issued on December 23, 2024, titled, ‘National Organic Program; Market Development for Mushrooms and Pet Food.’”

These important organic regulations for pet food were in place for less than six months, and now – due to the “Eliminating 10 Regulations for each new Regulation Executive Order” – the agency plans to delete them.

TruthaboutPetFood.com asked the USDA why they are wanting to rescind the organic pet food rules they recently finalized, the agency responded with:

“Hi Susan, the Department published a proposed rule to withdraw the Market Development Rule. There is an executive order that requires that whenever an agency promulgates a new rule, regulation, or guidance, it must identify at least 10 existing rules, regulations, or guidance documents to be repealed. Stakeholders can submit public comments on the proposed withdrawal until June 11, 2025 at midnight.”

Were the organic pet food rules USDA plans to delete necessary?

Per the USDA, absolutely yes. When the organic pet food rules were published in December 2024, the USDA explained why the rules were so necessary.

“This rule regulates what organic pet food can contain and how organic claims may be used on pet food.”

“The lack of specific standards for organic pet food has created inconsistency and uncertainty around labeling and composition requirements for organic pet food. Certifiers have used various combinations of the standards for livestock feed and processed products, neither of which are entirely sufficient. The handling standards are appropriate for verifying the processing, handling, product composition, and labeling requirements for multi-ingredient processed agricultural products, but they lack specific allowances for nutrients that are necessary for pets. Conversely, the livestock feed standards include allowances for many of the nutrients that are necessary for pets, but they prohibit common pet food ingredients, such as slaughter by-products.”

“In conclusion, this rule addresses inconsistencies in how certifying agents are applying the current organic regulations to pet food. It also resolves regulatory uncertainties that artificially increase risk in the organic pet food market.”

Significantly, the December 2024 organic pet food rule assured pet owners that slaughter by-products (used in organic pet foods) were sourced from inspected and passed animals. Quoting USDA:

“The term organic slaughter by-products refers to the parts of organic animals that humans do not typically eat, such as offal, gristle, and bone. It does not refer to substandard animal products from diseased animals, uninspected animals, condemned animals, or animals deemed unfit for human consumption.”

“AMS agrees with the commenters that organic pet food must not contain condemned, diseased, or otherwise unsanitary animal products, and the final rule should in no way be misconstrued to permit them.”

The USDA itself admitted that the rules approved in December 2024 resolved “problems by, first, establishing that organic pet food is regulated as a processed product rather than as livestock feed.”

But, if these regulations are cut – organic pet food will again be faced with problems. Organic pet food will return to being regulated as livestock feed.

If these regulations are cut, there would be nothing in place to prevent an organic feed grade pet food from sourcing “substandard animal products from diseased animals, uninspected animals, condemned animals, or animals deemed unfit for human consumption.”

The deletion of these rules results in “inconsistencies” in the regulation of most pet foods that make organic claims. The exception would be the (very) few pet food and treat brands whose manufacturing facilities are certified organic.

Please speak up.

The USDA is accepting comments on the proposed withdrawal of organic pet food regulations up until June 11, 2025. We urge all pet owners to submit a comment telling the USDA to keep organic pet food regulations in place, please find another rule to meet their requirement of deleting 10 rules. Organic pet food should be regulated as pet food, not livestock feed.

To comment, go to: https://www.regulations.gov/document/AMS-NOP-22-0063-3399 and click on the blue “Comment” button.

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