On July 21, 2022, Susan Thixton of the Association for Truth in Pet Food filed a Citizen Petition with the Food and Drug Administration, urging the agency to comply with federal law in its regulation of petfood.
The petition called for the removal of misleading references that equate petfood ingredients with human-grade ingredients.
Thixton argued that if a petfood or treat product is composed entirely of feed-grade ingredients, the label should clearly state this. “Should a pet food/treat product consist of 100% feed grade ingredients, we ask FDA to require the label to prominently display the words ‘Feed Grade’ directly below the name of the product on the principal display panel and in the ingredient panel,” she wrote.
The petition also requested that claims such as “Made with Real Chicken” or “Made with Real Beef” only be permitted if the ingredient meets standards established under the Meat Inspection or Poultry Products Inspection Acts by the United States Department of Agriculture.
For the reasons discussed, the agency denied the petition. It stated that animal food ingredients are not permitted optional ingredients and are not an imitation of other foods. It further noted that such ingredients have common or usual names, and that the use of “feed” terminology does not make an ingredient optional or non-standardised, nor does it create a new class or subclass of food under FDA regulations.
The agency also concluded that using the common or usual name for petfood ingredients does not misbrand the product. In accordance with 21 CFR 10.30(e)(3), the FDA therefore denied the petition.