By: Casey L. Bradley, Ph.D. - October 1st, 2024; President and Founder of Animistic
As a consultant in the animal and pet nutrition industry, one of the most common questions I get is, “Can I make this pet food labeling claim on my product?” It’s a question that reflects how complex pet food labeling claims can be — and if you’ve ever asked it, chances are you’ve been met with a flat “No” from your regulatory team.
But here’s the thing — I don’t believe in starting with a hard stop. Instead, I like to begin with, “It depends.” I understand how frustrating it can be for sales and marketing teams to feel like they’re running into brick walls when it comes to compliant product messaging. So rather than focusing on why you can’t make certain claims, let’s explore how to make pet food labeling claims that are compliant, effective, and backed by science.
Regarding product labeling, the FDA defines a claim as any statement about the relationship between a substance—typically a nutrient or food component—and a health-related condition, disease, or physiological effect. These claims must comply with AAFCO model guidelines. For a deeper dive into recent AAFCO and FDA changes, see our full breakdown of AAFCO pet food regulations.
In the animal and pet nutrition world, we have our own set of regulatory guidelines to navigate. While we don’t have to notify the FDA within 30 days of marketing a structure/function claim like 'supports digestive health,' as required for human dietary supplements, our claims must still comply with the Federal Food, Drug, and Cosmetic Act and various animal feed regulations. But it doesn't stop there. Organizations like AAFCO (Association of American Feed Control Officials) and individual state regulatory agencies also play a key role in monitoring our labels and claims. And with ongoing regulatory changes, such as the FDA’s recent decision to end its Memorandum of Understanding (MOU) with AAFCO, the industry constantly presents challenges and opportunities.
Another common question I encounter is, what exactly constitutes a label when making a claim? The FDA defines a label as any written, printed, or graphic matter that is directly affixed to a product’s container or packaging. This includes everything physically attached to the packaging, such as stickers, tags, or printed labels. Beyond the label itself, the FDA also considers labeling to include any written, printed, or graphic materials accompanying the product—this could be brochures, flyers, websites, or other promotional content used at the point of sale.
Whether for human or animal products, the FDA requires that all labels are accurate and not misleading. This means that every label must include essential information such as the product’s name, ingredients, intended use, manufacturer’s details, and any claims made about the product’s benefits. The goal is simple: to ensure consumers and regulators can easily understand the product’s purpose and nutritional value.
Claims in the Real World
Example 1: "Enzyme A increases ADG by 4.0% when fed to weaned pigs through slaughter."
What’s Wrong with This Claim?
The use of the word "increases" suggests a drug-like effect, which can only be legally claimed for products registered as drugs with the FDA. For example, Paylean™ can legally state "increases weight gain" because it is registered as a drug with the FDA and has undergone the necessary approval process. However, enzymes, such as Enzyme A, are generally not classified or registered as drugs, meaning they cannot legally make such specific claims about increasing growth.
How to Fix It:
To stay compliant and avoid suggesting a drug-like effect, you can use more general language. A compliant and scientifically accurate way to phrase this would be:
This statement is broad enough to avoid any regulatory issues while still conveying the benefit of the product.
Presenting Data Effectively:
If you want to highlight the specific results, you can refer to published research rather than making an outright claim. For instance:
This approach allows you to present the scientific evidence without directly making a non-compliant claim on the product label or in marketing materials.
Example 2: Doggie Biz’s Movement Supplement “reduces osteoarthritis in dogs.”
Why This Claim is Incorrect:
"Reduces osteoarthritis" implies a therapeutic or drug-like effect, which is only permitted for FDA-approved drugs. Even though there may be scientific support for glucosamine and chondroitin benefiting dogs with joint issues, the claim should not suggest it can cure or treat a specific disease without regulatory approval.
How to Fix It:
These claims focus on supporting overall joint health rather than implying a treatment or cure, making them compliant for dietary supplements and consistent with regulatory guidelines.
Example 3: Poultry Layer 17% with Super Phytase.
How to Fix the Issue:
To prevent future labeling issues and ensure compliance, the following steps should be taken:
Concluding Remarks
Navigating the complexities of product labeling and regulatory compliance in the animal and pet nutrition industry can be challenging. As we've seen in these examples, even small missteps—whether in phosphorus content, enzyme usage, or product claims—can lead to costly setbacks like stop-sale orders or loss of consumer trust.
Want more insights? Browse all our blogs on animal nutrition and labeling to stay informed.
At Animistic , we bring years of experience working with both state and federal regulators, as well as a deep knowledge of animal nutrition. Whether you need help writing pet food labeling claims, formulating compliant products, or designing a clear and trustworthy label, Animistic brings the experience and regulatory insight to get it right.
Is your business ready to take the next step in regulatory compliance and optimized animal nutrition? Book a call with Animistic today to discover how we can help you avoid costly mistakes and ensure your products meet the highest standards of quality and compliance. Let’s work together to build a future where your business thrives through science and heart.
