Feed Bites

The Best Path to Regulatory Harmonization is One We Take Together

Written by: Constance Cullman   |   May 11, 2023

Pets, Federal agencies

The year was 1909. In a Chicago meeting room, owners of businesses growing an animal food industry discussed the increasing body of regulations governing the sector at both the federal and state levels. They understood the need to coordinate and stay informed of how these regulations were developing and formed an organization, which today is the American Feed Industry Association. Simultaneously, state agencies realized that together, they could develop standards, definitions and policies for the enforcement of feed laws that promoted uniformity. Thus, they created the Association of American Feed Control Officials (AAFCO).

The two organizations have been working together ever since.

It isn’t always harmonious. Sometimes, there is tension between the regulated industry and the regulators, however, common ground has been found in a commitment to scientific principles, system-based regulations and efforts to harmonize state regulations. We know that despite 114 years of effort, regulations change, new challenges emerge, and much work remains.

Recently, an organization representing the pet food segment of the animal food industry, Pet Food Institute (PFI), announced a proposal to overhaul the way cat and dog food and treats are regulated. While we have not seen the final proposal, we know it calls for federal preemption on regulating sales and assessing fees and in doing so, eliminates one of the three pathways companies can now use to register new ingredients for use in pet food.

The proposal also calls for a new center to be developed at the Food and Drug Administration to focus solely on regulating cat and dog food and treats. Unfortunately, as part of the plan to fund the center, PFI’s proposal calls for the assessment of user fees on new ingredient submissions – an approach that has been met with industry confusion, frustration and continually escalating costs when used to fund the regulatory review of pesticides, animal drugs and other products from business sectors unfortunate enough to have to pay them.

The animal food system is…well…a system. When one part of that system is carved out in regulation, it creates an avalanche of impacts for the rest of the system.

One of the more obvious impacts is on the ingredient suppliers that provide healthy, safe and innovative products for both livestock and pets. If this proposal proceeds as outlined, those companies would be forced to comply with a duplicative, dual registration process at the state and federal levels, doubling their costs and potentially facing differing data requirements. Impacts are not limited to the industry but will also be felt by both state and federal regulators and their association, AAFCO – some of those impacts may be warranted and long overdue – others may have implications for those of us, whom they regulate.

We are currently reviewing the proposal with our members, our leadership, other organizations within the animal food industry and regulatory agencies to gauge their positions and find common ground to solve these issues. For now, we have preliminary questions about how this proposal could impact federal and state resources and our feed, pet food and animal food ingredient manufacturing facilities. 

The AFIA has been committed to maintaining a united and harmonious animal food industry for over a century. We work to build consensus when and where needed and leverage the power of collaboration to affect the change we need to continue to provide safe and nutritious food so that animals stay healthy throughout their lives. We know there are challenges, and we are eager to continue our efforts to resolve them. Tackling those challenges together just makes sense.

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