Pet food labeling requirements keep dog and cat food suppliers on a short leash. Rules come from three main directions at once: Both federal and state regulators decide what a label must say, and each retailer has its own compliance requirements. A pet food label can satisfy one layer while failing another, and one labeling mistake can bring both a regulatory risk and a retailer penalty at the same time. Making matters more complex, these three layers are subject to change.
In this article, you will learn:
How federal, state, and retailer labeling requirements layer together
Changes the Association of American Feed Control Officials (AAFCO) made to pet food labeling requirements
What the PURR Act is proposing
How retailer-ready item data and electronic data interchange (EDI) help prevent revenue loss
What Are the Pet Food Labeling Requirements Suppliers Have To Meet?
Pet food suppliers must adhere to three different sets of rules, each enforced by a different party.
Federal Regulations
The U.S. Food and Drug Administration (FDA) requires animal food labels to contain “information describing the product and any details necessary for the safe and effective use of the food,” including:
Proper product identification
Net quantity statement
Name and place of the manufacturer or distributor
Full ingredient list, using the ingredient’s common or usual name, in descending order of predominance according to weight
All federal regulations concerning labeling, as well as their exemptions, are outlined in the 21 Code of Federal Regulations (CFR) Part 150.
State Regulations
The FDA also notes that animal food is subject to state laws as well, and many states build theirs from the Association of American Feed Control Officials (AAFCO) model regulations. AAFCO is a nonprofit made up of state, federal, and international regulators who oversee animal feed and pet food. It doesn’t make laws or enforce anything itself. Rather, it writes model regulations (i.e., template set of rules for labeling and marketing pet food), including ones for pet food labels, and each state decides whether to adopt them.
According to the Pet Food Institute, AAFCO’s model pet food labeling regulations includes requirements like clearly identifying that the product is a dog or cat food and using a brand name that isn’t misleading.
Because states adopt AAFCO regulations according to their own schedule, the same label can meet one state’s rules but not another’s.
Retailer Compliance
Retailers can add a third layer of labeling requirements. For example, PetSmart’s Master Vendor Agreement folds applicable laws into its own vendor requirements and subjects vendors to deductions for noncompliance. Other large pet-food-carrying retailers like Walmart, Target, Chewy, and Pet Supplies Plus all have their own vendor requirements.
Moreover, if a product’s item data (e.g., ingredient order, nutrient analysis, and intended-use wording) in the retailer’s system differs from what is on the package itself, suppliers may face rejected setups or deductions, even if the label meets all necessary regulations.
Related Reading: EDI for First-Time Suppliers: A Plain-English Guide to the Documents You'll Send
What Changed in the AAFCO Pet Food Label Requirements?
On July 31, 2023, AAFCO announced that its members had approved a revised version of the Model Regulations for Pet Food and Specialty Pet Food, calling it the first major update in more than 40 years. Published in 2024, AAFCO made changes to four key areas:
Nutrition facts box: Updated to look more like human-food labeling.
Intended use statement: Updated to a new location — the lower third of the font display panel.
Ingredient statement: Updated to clarify the use of consistent terminology and to allow parentheticals and common or usual names for vitamins.
Handling and storage instructions: Updated and standardized with optional icons for greater consistency.
AAFCO notes that the revised Model Regulations for Pet Food and Specialty Pet Food “are for all pet and specialty pet foods, including daily pet foods (i.e., complete foods), treats, toppers, mixers, supplements, and veterinary diets.” AAFCO recommended six years of enforcement discretion after 2024, but that is only a recommendation. The state of Washington, for example, adopted the rules and delayed enforcement until July 1, 2030. A supplier that ships nationally must track each state it sells to.
How Could the PURR Act Affect Suppliers?
Pet food suppliers should also have the Pet Food Uniform Regulatory Reform (PURR) Act, H.R. 597, on their radar, which would make the FDA’s Center for Veterinary Medicine (CVM) the sole regulator of dog and cat food. According to the bill summary, “no state or local government [would be able to] establish, implement, or enforce any authority or requirement relating to pet food marketing or labeling."
The PURR Act also specifies that AAFCO-recognized ingredients are generally recognized as safe (GRAS) and “allows manufacturers to state, without prior approval, that their products (1) sometimes, but not always, have certain ingredients (e.g., flavors); (2) have certain health benefits (e.g., tartar control); or (3) are human grade or natural, if certain conditions are met.”
Congress.gov lists no action since the House referred it to committee on Jan. 21, 2025.
Get Retailer-Ready Item Data With SPS Fulfillment
SPS Fulfillment connects suppliers to retailers such as PetSmart, Chewy.com, and Pet Supplies Plus through EDI. Accurate, retailer-ready item data keeps a compliant label from still costing you a deduction. See how SPS Fulfillment and EDI work.
Not ready yet? See how pet food company Jinx scaled from $0 to $100 million with SPS Fulfillment and Revenue Recovery.
Frequently Asked Questions
Do the new AAFCO label rules apply today?
AAFCO’s model regulations are not law until a state adopts them, and each state sets its own enforcement timing.
Is the PURR Act law?
No. The PURR Act (H.R. 597) has sat in committee since January 2025.
Who enforces pet food labeling requirements?
The FDA enforces federal rules, state regulators enforce state law, and retailers enforce their own standards through vendor agreements and deductions.
Does SPS handle regulatory label compliance?
No. Label compliance stays with a supplier’s counsel and quality team. SPS Fulfillment helps keep item data retailer-ready through EDI.
This article is general information, not legal advice. Labeling rules and state adoption dates change, so double-check current requirements with your legal counsel and quality team.