Human-Grade Compliance for Pet and Specialty Pet Food

Human-grade claims have increased rapidly throughout the pet and specialty pet food world. While the American Association of Feed Control Officials (AAFCO) does allow for human-grade claims, they must be truthful and not misleading. To substantiate a human-grade claim, all pet food products should be manufactured in accordance with the human food regulations for ready–to–eat human food (21 CFR part 117 for “Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventative Controls for Human Food”). It is essential to remember that all animal food products are subject to inspection under 21 CFR 507 for “Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals.” So, while AAFCO does permit human-grade claims, they must meet stringent manufacturing standards.

AAFCO's recognition of human-grade claims is comprehensive; it applies to the entire product, meaning all ingredients used in the diet must be made in a facility that adheres to 21 CFR part 117. Moreover, the manufacturing facility responsible for the whole product and/or packaging must be licensed/registered with the FDA (Food and Drug Administration) as a food facility operating under both General Product Categories (Food for Human Consumption and Food for Animal Consumption). These registrations must be up-to-date, readily available for subsequent requests from federal authorities, and require submission through the FDA Industry Systems. Then followed by an inspection by an authorized agency for human food production.

In addition to keeping all licenses up to date and accessible, documentation sufficient to show that ingredients supplied to the manufacturer of the human-grade pet food are fit for human consumption while also being stored, handled, processed, and transported in a manner that is consistent and compliant with 21 CFR part 117 must also be provided. This process can become extremely convoluted and requires a multitude of documents from suppliers.

The regulatory authority responsible for U.S. animal and plant health inspections is APHIS (Animal and Plant Health Inspection Service), an agency of the USDA (United States Department of Agriculture). APHIS is the branch that both FDA and USDA use to inspect manufacturing facilities and ensure they meet their regulations. There are some instances, however, where final processing and/or packaging can occur in a food facility under USDA regulations rather than FDA regulations. For example, any meat processing plant is subject to USDA regulations. As mentioned above, all documentation must be made available upon request to verify that the ingredients used, and the product made are ready to eat. 

Human-grade claims may also be made regarding ingredients and/or whole product processing/packaging coming from other countries. Depending on the country of origin, an agreed-upon government entity will inspect a facility in accordance with U.S. food regulations. These inspections are then sent to the appropriate authority (FDA or USDA) for final licensing.

BSM Assurance, specializes in helping pet food companies meet the stringent requirements for human-grade claims. Our team can guide you through the entire process, from initial planning to final documentation. Ensuring products comply with all regulations and that label claims are accurate and substantiated. While human-grade pet food offers a premium image, it's essential to understand the complexities involved. By aligning with the appropriate resources, brands can confidently make human-grade claims and provide your customers with the highest quality products.

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About the Author

Dr. Emily Taylor is a Senior Analyst part of the BSM-FSQAR Team. Dr. Taylor is a nutritionist with over 14 years in the animal industry. She resides in Lafayette, Indiana, with her family, showing dressage horses.