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Supplement vs. Feed vs. Treat

Feed: AAFCO recognizes a specific number of product categories of nutritional adequacy that qualify as a feed. This includes gestation/lactation, growth, maintenance, and all life stages. Products that target general wellness may also fall under this category.

Feed Product Examples (not limited too): Probiotic, Skin & Coat, Vitamins/Mineral and Vitality.

Supplement: Supplements are targeted towards specific performance or nutritive balances. They are intended to be used in conjunction with a complete food.

Supplement Examples: Hip and Joint, Omega, Immune Support, Antioxidant, UTI, or any supplements specific to an organ or anatomical section of the animal (hip/joint).

Treat: The Principal display panel should state that the product is a, “snack” or a “treat” and must not be intended as a daily source of calories, nutrients and must not contain any supplemental label indicators. Principal display panel is the part of a label that is most likely to be displayed, presented, shown, or examined while being displayed for retail or online sale.

Labeling a Feed Product

Along with the standard list of label requirements (see below), products identified as a feed are required to further supply on their label an ingredient deck from highest to lowest inclusion, a Guaranteed Analysis and a statement of nutritional adequacy or purpose.

a. Ingredient Deck: Ingredients must be listed by weight of inclusion from highest inclusion to lowest.

No brand or tradenames are to be used in this section, only AAFCO approved naming conventions.

b. Guaranteed Analysis must include, but is not limited to:

a. Minimum percentage of Crude Protein

b. Minimum percentage of Crude Fat

c. Maximum percentage of Crude Fat

d. Maximum percentage of Crude Fiber

e. Maximum percentage of Moisture

Nutritional purpose statement: A statement of nutritional purpose of the product is required unless it is clearly identified on the principal display panel as a snack, treat or supplement. If this is not clear, you must include a statement such as the following, “This product does not meet the complete and balanced AAFCO food requirements. It is intended for intermittent or supplemental feeding only.”

Labeling a Supplement

Along with the standard list of label requirements (see below) products identified as a supplement have other labeling requirements.

a. Ingredient Statements: Ingredient statements may be listed alphabetically, or by inclusion

based off percent inclusion from highest to lowest.

b. Nutritional purpose statement: A statement of nutritional purpose of the product is required unless it is clearly identified on the principal display panel as a snack, treat or supplement. If this is not clear, you must include a statement such as the following, “This product does not meet the complete and balanced AAFCO food requirements. It is intended for intermittent or supplemental feeding only.”

Navigating Product Claims

The DSHEA (Dietary Supplement Health and Education Act) that applies to human products does NOT apply to pet products. This is important to understand in the pet space because all “health claims” that show an article is intended to cure, mitigate, treat or prevent a disease is a drug claim and not allowed. Further anything claiming to affect the structure or function of the body is also considered a drug claim. Please refer to the below phase listings to help navigate these claims.

Claims/Phrases to Avoid

Relief, Boosts, Increase, Stops, Reduce, Prevents, Enhances, Arthritis, Inflammation, Improves, Pain, Builds, Repair, A safe alternative to drugs.

Acceptable Phrases

Helps Maintain or Maintains (i.e. Maintains a healthy circulatory system), Supports (i.e. Supports healthy urinary tract), Aids in, Helps Improve

Label Requirements:

The following is a list of required items that must appear on your label.

1. Product name – Must be clearly stated and easily interpreted by the consumer for its intended use.

2. Species intended for – Must be clear to the consumer and it may be included in the product name.

3. Net quantity statement (both lbs. and metric) – Net weight must be in the lower third of the principal panel of the product.

4. Distributor Name and Address – This names your company as guarantor of the product and gives you or your company's location. The street address may be omitted if the named entity is listed in the local telephone directory, but the city, state and zip code must be shown.

5. Product must say ‘Manufactured for” or “Distributed by”

6. Feeding/dosage directions

7. Ingredient statement (see above)

8. Nutritional purpose statement (see above)

9. Guaranteed analysis if it is a feed product (see above)

25% Rule

Per AAFCO, the 25% Rule lets pet food/treat companies include the protein in their product name. The 25% Rule states that if a pet food/treat is to be called “Dinner” “Entree” “Formula” or “Recipe” then the protein needs to be at least 25% of the total ingredients. For example, “Hip and Joint Chicken Formula” or “Chicken Recipe” must contain at least 25% chicken.

Pet Industry Agencies and Links:

The below listed agencies are the most active and influential agencies in the pet industry today. For more information on labeling, ingredients and GRAS ingredients follow the links below.

AAFCO: Association of American feed Control Officials:

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https://talkspetfood.aafco.org/supplements⁠

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https://talkspetfood.aafco.org/readinglabels#adequacy⁠

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https://talkspetfood.aafco.org/treatsandchews⁠

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FDA: Federal Drug Administration:

https://www.fda.gov/animal-veterinary/animal-food-feeds/pet-food⁠

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