Regulatory Guidance for Pet Products
AAFCO: A Century of Pet Food Ingredient Standards
For over a century, the Association of American Feed Control Officials (AAFCO) has been the go-to source for regulatory guidance in the pet food space. AAFCO’s annually released Official Publication includes a comprehensive list of animal food ingredients. Among other things it includes FDA-approved color additives, substances that are generally recognized as safe (GRAS) by the FDA for an intended use in animal food, and ingredients reviewed through the AAFCO ingredient definition request process.
FDA-AAFCO Split: What It Means for Pet Food
Since 2007, the FDA has empowered AAFCO to assess ingredients for use in animal food and treats and served as a scientific and technical reviewer for the AAFCO ingredient definition request process. However, this shifted in late 2024 when the FDA-AAFCO Memorandum of Understanding (MOU) expired.
The alphabet soup of acronyms and the ongoing evolution of the relationship between the FDA and AAFCO makes it easy to get confused, so let’s break down how it impacts the industry, pet food color, and pet food brands and manufacturers.
What should we expect?
FDA is in the process of reevaluating its pre-market animal food review programs. Through public comment periods, stakeholder sessions, and draft guidance documents, the industry will have an opportunity to provide feedback on what’s working and what’s not.
The goal is to improve efficient development and review of new animal food ingredients.
AAFCO is not going away, but it will no longer be the sole voice in animal food ingredient review.
How will animal food ingredients get approved?
Without the FDA serving as the scientific and technical reviewer for the AAFCO Ingredient Definition Request process, AAFCO has approved a new pathway for ingredient approval. The approved proposal from Kansas State University’s Olathe Innovation Campus includes a scientific review panel of subject matter experts which will evaluate potential new ingredients and provide recommendations to AAFCO for final approval. Approved ingredients will then be added to AAFCO’s Official Publication.
In parallel, the FDA announced a new process for ingredient review, the Animal Food Ingredient Consultation (AFIC) process. This process will enable companies to consult with the FDA directly and provide a venue for the FDA to review the safety of animal feed ingredients independent of the AAFCO ingredient definition process.
How does recent news around synthetic colors impact the pet food industry?
The FDA’s decision to revoke color additive approval for FD&C Red 3 means that it will no longer certify the dye, making it unavailable for use by pet food manufacturers. Any products using the dye will be considered adulterated after January 15, 2027.
State legislation around synthetic colors broadly as well as titanium dioxide focuses almost entirely on human food and beverages, leaving pet out of the conversation. While synthetic colors remain largely permitted in pet food, consumers are wary and interest in naturally colored pet products continues to rise.
In the US, 41% of consumers are influenced by “all natural” claims when purchasing pet food, with consistent year-over-year increases since 2020.
Mintel 2025
What’s next for pet food?
Brands and developers can continue to future-proof pet products by working with natural colors to create bright, appealing food and treats.
