Regulatory Developments in the Pet Food Sector for 2025

1. The Association of American Feed Control Officials (AAFCO) and its collaboration with the Food and Drug Administration (FDA). Notably, the AAFCO/FDA Memorandum of Understanding (MOU) is set to expire, impacting the pet food labeling modernization efforts.

2. Introduction of H.R. 597, known as the Pet Food Uniform Regulatory Reform Act of 2025 (PURR Act), which was proposed in January 2025. This legislation aims to replace the current state-based regulatory framework with federal oversight under the FDA.

3. The U.S. Department of Agriculture (USDA) Agricultural Marketing Service's proposal to rescind its 2024 rule on organic pet food standards.

4. Initiatives by the U.S. Department of Health and Human Services (HHS) and the FDA to eliminate synthetic food dyes in pet foods.

5. A new FDA requirement for dog and cat food manufacturers to incorporate H5N1 considerations into their food safety plans.

As part of this ongoing regulatory landscape, the following developments are key:

On August 2, 2024, the FDA announced the upcoming expiration of its MOU with AAFCO, effective October 24, 2024. This MOU had been in place for 17 years, governing the collaboration in the animal feed ingredient definition review process. The FDA indicated that these changes would facilitate a thorough evaluation of its pre-market review programs aimed at enhancing public health.

Additionally, on October 23, 2024, the FDA issued final guidance regarding AAFCO-defined animal food ingredients, allowing manufacturers to use ingredients found in AAFCO’s 2024 Official Publication for their products sold across state lines.