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Animal Food Labeling and Pet Food Claims

Section 201(m) of the FD&C Act defines "labeling" as all labels and other written, printed, or graphic matter upon any article or any of its containers or wrappers, or accompanying such articles including promotional brochures, promotional pamphlets, testimonials, product information sheets, books, etc., (21 U.S.C. 321(m)).  An animal food label should contain information describing the product and any details necessary for the safe and effective use of the food. The federal regulations concerning the labeling of animal foods and all exemptions are published in 21 Code of Federal Regulations (CFR) part 501. These requirements include:

  • proper identification of the product
  • net quantity statement
  • name and place of the manufacturer or distributor, and
  • listing of all ingredients

In addition to meeting the federal labeling requirements, animal food products are also subject to individual state laws. Additional information concerning state registration and labeling requirements may be obtained from the individual states where the products will be distributed. Alternately, the Official Publication of the Association of American Feed Controls Officials (AAFCO) contains Model Regulations for labeling animal food, which many states utilize in development of their state specific regulations. Copies of this publication, which is updated yearly, can be obtained from AAFCO Publications.

Common or Usual Name

Federal regulations require ingredients be listed on the product label by their common or usual name in descending order of predominance according to weight (21 CFR 501.4(a)). A common or usual name is one that accurately identifies or describes the basic nature of the food, or its characterizing properties or ingredients (21 CFR 502.5(a)). The names of ingredients defined by AAFCO and listed in its Official Publication may be common usage names (Guidance for Industry #293). An animal food ingredient is exempt from the requirement to list the common or usual name if the ingredient is a collective name (i.e., animal protein products, forage products, grain products, plant protein products, processed grain by-products, and roughage products) and meets the other requirements in 21 CFR 501.110.

Drug Claims on Labels

Expressed or implied claims that establish the intended use of a product is to cure, treat, prevent, or mitigate disease, or affect the structure or function of the body in a manner other than for food purposes (nutritive value, aroma, or taste) can indicate an intent to offer the product as a "new animal drug." These claims would need to be approved through the new animal drug process in order to appear on the label.

Specific Claims on Labels

FDA reviews specific claims on pet food, such as “maintains urinary tract health,” “low magnesium,” and “hairball control.” Guidance for collecting data to make a urinary tract health claim for cat food is available in CVM Guidance for Industry (GFI) #55 and GFI #284.

CVM does not recommend one product over another or offer guidance on individual pet health issues that are normally provided by the pet’s veterinarian. Questions regarding your pet's health or the specific use of any veterinary drug, pet food, or other product should always be referred to your veterinarian.

Guidance Documents



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