On July 21, 2022 we submitted an official request to FDA Center for Veterinary Medicine asking the agency to require disclosure on pet food labels of feed grade ingredients. Two and a half years later, the FDA has not responded to our request.
Law Requires Disclosure
In US federal law (Code of Federal Regulations, Subchapter E Animal Drugs, Feeds, and Related Products), it clearly states the name of an animal food (ingredient) cannot be “confusingly similar to the name of any other food“. The same federal laws also state “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.”
Such as…
Using the example of “chicken”:
The ingredient ‘chicken’ in human food is required to be USDA inspected and passed as edible; abiding by requirements of The Poultry Products Inspection Act.
But the ingredient of the exact same name in pet food – ‘chicken’ – is NOT required to be USDA inspected and passed, not required to abide by the requirements of The Poultry Products Inspection Act. Chicken in pet food is allowed to be sourced from condemned chicken and/or chicken classified as inedible.
Two food ingredients of the same name but with very different qualities.
As we exampled to FDA, law requires these ingredients to have their own common name. We suggested to FDA that pet food ingredients be given the subclass common name of “feed grade“, such as ‘feed grade chicken’ – to clearly distinguish it for pet food consumers.
Click Here to read our Citizen Petition to FDA Center for Veterinary Medicine (document can be also be downloaded from the Regulations.gov website).
No response from FDA.
Pet food consumers deserve to know what they are buying – chicken or feed grade chicken. We have federal law behind us, federal law requiring pet food ingredient names that distinguish them from food ingredients.
The FDA has only told us on January 11, 2023: “Pursuant to the administrative regulations at 21 CFR 10.30, FDA is required to respond to your petition within 180 days. FDA is currently considering the issues raised by your citizen petition; however, the Agency will require additional time to issue a final response.”
How much “additional time” does the FDA need to require pet food to abide by federal law?
We continue to wait.
Pet owners can email FDA Center for Veterinary Medicine asking them when they intend to respond to our request – make certain to include the reference of Docket FDA-2022-P-1643 – at AskCVM@fda.hhs.gov.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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