While the Food and Drug Administration provides guidelines for pet treats manufacturing, it has not formally provided a definition for "natural" ingredients. However, the Federal Food, Drug and Cosmetic Act "requires that pet foods, like human foods, be pure and wholesome, safe to eat, produced under sanitary conditions, contain no harmful substances and be truthfully labelled," according to the FDA.
Federal and State Requirements
Regulations vary, depending on whether you are making treats in your home or in a commercial operation. However, pet treat regulations are similar to laws guiding other animal feeds both at the federal and state level.
The Association of American Feed Control Officials
The Association of American Feed Control Officials (AAFCO) published an official manual of laws to promote uniformity in the industry. In the manual, "Model Regulations for Pet Food and Specialty Pet Food," the AAFCO cites 11 regulations that are consistent between federal and state governments.
Properly Name Your Product
According to the AAFCO manual, you must not mislead consumers; your product's name must represent what the product is. Don't call your pet treat Beef Marrow Biscuit if it does not contain beef marrow, for example.
Write "For Dogs" on the label if your treat is intended for dogs. The AAFCO discourages using only a picture of a dog on the label, since an image does not clearly indicate the "species of intended use," according to the AAFCO.
List all of the ingredients used in the dog treats, rather than putting the recipe on the label. Federal law requires that all ingredients listed on the label should be represented by "their common or usual name" and written in "descending order of predominance by their weight in the product," the AAFCO states.
Statement of Nutritional Adequacy
If you claim that your product meets the nutritional requirements for one or more stages of a dog's life, regulations require you to provide a statement of nutritional adequacy. The statement should inform the customer how the treat meets the dog's daily nutrient requirement for its stage of life. If your treat does not make this claim, your label must state, "Intended for intermittent or supplement feeding only," according to regulations.
A dog treat label presenting a nutritional adequacy statement must also include feeding instructions that "are consistent with meeting the animal's daily nutrient requirements from the product," according to the AAFCO. Provide practical directions that the average user will understand.
The law requires that your label present the name and location of the manufacturer and distributor of the pet treat product, including the street address, city, state and Postcode. If you make the product but use an independent distributor, your address as well as the distributor's address must be listed, according to federal regulation.
Business Registration and License
Most states require that you register and license your business with your state's feed control office. The AAFCO manual provides a list of feed control offices in each of the 50 states. If you sell dog treats online or through mail order and ship to various states, the product also needs to be registered with the recipient's state, according to state regulations. The AAFCO manual provides a table of registration and licensing fees by state.
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