Regulatory Shifts in Pet & Animal Feed: Navigating AAFCO, FDA, and USDA Changes 

By: Casey L. Bradley, Ph.D. - March 3rd, 2025; Founder of Animistic 

The AAFCO Pet Food Regulations landscape is evolving rapidly. Recent developments, including AAFCO’s new ingredient approval process, the USDA’s conditional approval of an avian flu vaccine, and Amazon’s stricter enforcement of pet supplement regulations, are reshaping the industry. 

These changes are not just bureaucratic updates. They have significant implications for companies seeking to bring new feed ingredients, supplements, and health solutions to market. At Animistic, we are actively engaged in these discussions, ensuring our clients stay ahead of the curve. 

Changes in AAFCO Pet Food Regulations and Ingredient Approval

In a recent conversation with Austin Therrell, Executive Director of AAFCO, it became clear that the dissolution of the long-standing Memorandum of Understanding (MOU) between AAFCO and the FDA has created a new regulatory reality. The previous system relied on FDA’s voluntary GRAS notification program, but many states only recognized ingredients listed in AAFCO’s Official Publication. The result was regulatory uncertainty, particularly for companies using self-GRAS ingredients that had not gone through FDA’s formal review. 
Quote from Austin Therrell about the AAFCO Kansas State ingredient approval process, highlighting its role in AAFCO Pet Food Regulations.

Kansas State Partnership and Industry Impact

To address this, AAFCO has partnered with Kansas State University to establish a new ingredient definition pathway. Therrell described this as a self-GRAS model that will provide a structured review process without requiring additional FDA oversight. “We feel like it kind of solves that self-GRAS dilemma,” Therrell said. “If it goes through the new AAFCO Kansas State process, it is legally considered GRAS from FDA’s viewpoint” (Therrell, 2025). 

 

For industry stakeholders, this means faster approval timelines, with AAFCO targeting an approval process of approximately nine months—significantly shorter than FDA’s traditional food additive or GRAS notification pathways. However, FDA has yet to formally acknowledge the process, leaving questions about how state regulators and international markets will respond. 

USDA’s Avian Flu Vaccine and Its Impact on Pet Food Regulations

The USDA recently granted conditional approval for a vaccine targeting highly pathogenic avian influenza (HPAI). This decision comes in response to devastating outbreaks that have impacted poultry producers and contributed to rising egg and meat prices. While this is a step forward for disease prevention, the regulatory framework surrounding animal vaccines remains complex. 

Regulatory Conflicts Between USDA and FDA

The FDA generally oversees animal drugs, while the USDA’s Center for Veterinary Biologics manages veterinary vaccines. The conditional approval raises concerns about potential conflicts between these agencies, particularly regarding trade regulations. Several major poultry importers, including the European Union and China, have expressed concerns about vaccinated poultry, which could create export barriers for U.S. producers. 

For companies involved in feed additives and nutritional solutions, this shift in disease management strategies could impact the demand for immune-supporting feed ingredients. Producers will need to weigh the benefits of vaccination against potential market restrictions, and those developing alternative health solutions should prepare for increased regulatory scrutiny. 

Amazon’s Compliance Crackdown on Pet Supplements

Amazon has significantly tightened its compliance requirements for pet supplements, creating confusion for many manufacturers. Unlike human dietary supplements, which fall under FDA’s 21 CFR 111 regulations, pet supplements are regulated under 21 CFR 507, which focuses on animal food safety. Despite this distinction, Amazon is now requiring pet supplement brands to provide GMP certification and ingredient approval documentation that aligns more closely with human supplement regulations. 

Impact of the PURR Act on Compliance

This change has left many companies scrambling to meet new documentation requirements, particularly those using ingredients that have not gone through FDA’s GRAS or food additive petition processes. The newly introduced PURR Act, which seeks to establish national uniformity in pet food and supplement regulations, may help clarify these requirements in the future. Until then, manufacturers must navigate a complex and evolving regulatory framework to maintain their product listings on e-commerce platforms. 

Regulatory Strategy Moving Forward

The shifting regulatory environment presents both challenges and opportunities for companies in the pet and animal nutrition space. Businesses must carefully evaluate the best approval pathway for their ingredients, whether through AAFCO’s new process, FDA’s existing GRAS notification system, or the traditional food additive petition route. 

International trade considerations are also becoming more critical, particularly for companies involved in poultry production and feed additives. The regulatory divergence between the USDA, FDA, and global trade partners highlights the need for a proactive approach to compliance. 

Preparing for Future Shifts in AAFCO Pet Food Regulations

At Animistic, we work closely with clients to navigate these complexities, providing strategic guidance on ingredient approvals, vaccine compliance, and e-commerce regulatory requirements. As industry regulations continue to evolve, staying informed and proactive will be essential for long-term success in the regulatory AAFCO animal and pet food landscape.

For more information on how these changes may impact your business, or to develop a tailored regulatory strategy, contact Animistic today. 

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