September 24, 2021

Volume XI, Number 267

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Upcoming AAFCO Meeting to Discuss Guidelines for “Human Grade” Claim on Animal Food

  • The Association of American Feed Control Officials (AAFCO) is a voluntary membership association of local, state, and federal agencies that works together with FDA to regulate animal food, including by establishing definitions to describe new feed ingredients. The definitions, along with a model feed bill, are published annually in the AAFCO Official Publication.

  • AAFCO typically holds a mid-year and annual meeting in mid-January and early August, and considers a variety of issues, including changes to the model feed bill and new ingredient definitions. This year’s August meeting is scheduled for August 2-4 and will include a discussion of AAFCO’s recommendations for the use of “human grade” in the labeling of pet foods and specialty pet foods. According to the proposed guidelines, the claim may only be used to refer to the product as a whole, but every ingredient and the resulting product must be compliant with federal human food laws, including the cGMP requirements in 21 CFR Part 117.  Additionally, all facilities that process or package a final “human grade” pet food product that is considered ready-to-eat must be registered both as an FDA food facility and an FDA feed facility. The guidelines also include significant documentation requirements and labeling requirements, which, among other things, require the claim “human grade” to be juxtaposed with the statement of intended use (e.g., human grade dog food). The full proposed guidelines can be found here.

  • The AAFCO Ingredient Definitions Committee (IDC) will discuss publication of a tentative definition of Barley Protein Concentrate, withdraw of a Barley Distillers Protein Concentrate definition, and a modification to a tentative definition for a Black Solider Fly Larvae Oil.

© 2021 Keller and Heckman LLPNational Law Review, Volume XI, Number 208
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About this Author

Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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