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CPG Sec. 690.200 Pet Food Labeling October 1980

Issued by:
Guidance Issuing Office
Office of Foods and Veterinary Medicine, Center for Veterinary Medicine
Office of Global Regulatory Operations and Policy, Office of Regulatory Affairs


We have recently responded to a question concerning the proper way to label a frozen cat food product manufactured from headed and gutted ocean fish with bone and skin removed. The manufacturer characterized the product as "minced fish" made from ground fish such as pollock, haddock, or cod.

We advised that we could not permit an ingredient to be represented as containing "pollock or haddock or cod" as the inquirer requested, since, in our opinion, this would cause the product to be misbranded as discussed in 21 CFRa and b. In order to conform with the common or usual name requirement of 21 U.S.C. 343(i)(1) and (2), the label should reference only the specific species of fish physically a part of the product contents.

We advised, however, that we would not object to the labeling of such a product being represented as containing merely "fish," or "ocean fish," or some such similar designation with no species designation.


Pet food does not qualify under 21 CFRc for the use of collective names for animal feed ingredients. Where a manufacturer may be using various species of fish in a pet food as dictated by a day-to-day supply situation, the manufacturers may not reference all of the species alternatives on the label. The fish ingredient may be designated as "fish" or "ocean fish" or some such factual statement.
a 21 CFR 501.4
b 21 CFR 501.18
c 21 CFR 501.110

Issued: 10/1/80

Submit Comments

Submit comments on this guidance document electronically via docket ID: FDA-2013-S-0610 - Specific Electronic Submissions Intended For FDA's Dockets Management Staff (i.e., Citizen Petitions, Draft Proposed Guidance Documents, Variances, and other administrative record submissions)

If unable to submit comments online, please mail written comments to:

Dockets Management
Food and Drug Administration
5630 Fishers Lane, Rm 1061
Rockville, MD 20852

All comments should be identified with the title of the guidance.


Contact Point
Center for Veterinary Medicine
Food and Drug Administration
7500 Standish Pl, HFV-1
Rockville, MD 20855
(240) 402-7002