Pet Food and Feed Exporters: What FDA Requires vs What AAFCO Controls

AAFCO is a model-setter, not an approval body

Animal food market entry in the United States has two legal layers. FDA’s Center for Veterinary Medicine regulates pet food, livestock feed, ingredients, facilities, and imports at the federal level. State feed-control programs administer their own product registration and labeling laws. AAFCO develops model regulations, ingredient definitions, and nutritional standards for states to use, but AAFCO does not approve, register, certify, test, or enforce pet food products. FDA’s regulation of pet food explains this federal and state structure.

This distinction matters to foreign pet food, treat, livestock feed, aquaculture feed, and animal-food ingredient manufacturers. An overseas facility can satisfy FDA registration requirements and still lack required state product registrations or label elements. Conversely, following an AAFCO model does not replace FDA facility registration, a confirmed U.S. Agent, preventive controls, federal labeling, or Prior Notice for imported shipments.

Animal food compliance obligation map

Primary authorities include the FDA animal food registration guidance, 21 CFR Part 507, FDA animal food labeling guidance, Prior Notice regulations, food facility registration regulations, AAFCO state-market guidance, and AAFCO pet food label requirements.
Exporter obligation	Legal source or model	Who enforces it
Food facility registration and biennial renewal	FD&C Act section 415 and 21 CFR Part 1, Subpart H	FDA
Current good manufacturing practices, hazard analysis, and preventive controls	21 CFR Part 507	FDA, working with state regulatory partners where applicable
Federal animal food labeling	21 CFR Part 501	FDA’s Center for Veterinary Medicine
Prior Notice for each imported commercial shipment	21 CFR Part 1, Subpart I	FDA, with U.S. Customs and Border Protection at entry
U.S. Agent designation for a foreign registered facility	21 CFR 1.227 and 1.232	FDA
State product or label registration before sale	Individual state feed laws, often modeled on AAFCO provisions	The destination state’s feed-control program
Guaranteed analysis or required nutrition panel	AAFCO pet food models as adopted by each state	State feed-control officials
Ingredient names and definitions used on the state-market label	AAFCO ingredient definitions as adopted or referenced under state feed law	State feed-control officials; FDA retains federal ingredient-safety authority
Feeding directions for applicable pet foods	AAFCO Model Pet Food Regulations as adopted by each state	State feed-control officials
Nutritional adequacy or purpose statement for pet food	AAFCO nutrient profiles, feeding protocols, and model labeling rules as adopted	State feed-control officials

A useful operating distinction is that FDA determines whether the facility, manufacturing system, label, and shipment comply with federal law. States determine whether the product can be offered for sale within their jurisdictions under state feed laws. Neither layer replaces the other.

What an overseas animal food facility must handle federally

Facility registration follows the human-food cycle

A foreign facility that manufactures, processes, packs, or holds animal food for consumption in the United States must register with FDA unless it falls within a regulatory exemption. Pet food does not use a separate or lighter registration cycle. The registration must be renewed from October 1 through December 31 of every even-numbered year, just like registration for human food facilities. As of October 2, 2026, the 2026 renewal window is open and closes on December 31, 2026. FDA’s animal food facility registration FAQ confirms the scope and renewal dates.

The foreign facility needs a confirmed U.S. Agent

The U.S. Agent is part of the foreign facility registration, not an AAFCO role or a product approval. The agent must reside or maintain a place of business in the United States and serves as the communications link for routine and emergency FDA contacts. A mailbox or answering service cannot serve as the agent. FDA verifies that the named agent accepted the designation before confirming a new registration, and it verifies a changed agent during an update or renewal. 21 CFR Part 1, Subpart H defines the role and confirmation process.

Registration is only one part of the federal workload

Commercial animal food facilities subject to registration must also account for the manufacturing and food-safety requirements in 21 CFR Part 507. Part 507 covers current good manufacturing practices, hazard analysis, preventive controls, monitoring, corrective actions, verification, and written food-safety plans. Imported pet food and feed also require Prior Notice before arrival, and FDA checks facility registration, labeling, and other applicable requirements during import review. FDA’s animal and veterinary import guidance addresses pet food, feed, and animal-food ingredients.

What AAFCO requirements mean in practice

There is no application for national “AAFCO approval.” AAFCO creates models that individual states can adopt, revise, or reference in their own feed laws. State regulators, not AAFCO, decide whether a product must be registered, whether a company needs a license, whether a submitted label is acceptable, and whether enforcement action is warranted. AAFCO’s pet food business guidance states that requirements, forms, and fees vary by state.

For pet food, the state layer commonly addresses the guaranteed analysis, ingredient nomenclature, nutritional adequacy statement, feeding directions, calorie information, claims, and the manufacturer or distributor identified as guarantor. A product can meet an AAFCO nutrient profile or feeding protocol, but that does not make the product “AAFCO approved.” AAFCO’s label guide explains the principal pet food label elements.

State adoption is also changing over time. AAFCO approved modernized model pet food labels and recommended a six-year transition while states complete their own rulemaking. Exporters should therefore review the actual requirements of each destination state rather than treating one label template as an automatic nationwide clearance. AAFCO’s Pet Food Label Modernization guidance outlines the transition.

Where the federal and state layers commonly collide

Facility registration is not product approval

An FDA registration number identifies a registered facility. It does not mean FDA approved the finished bag, can, formulation, claims, or website language. FDA generally does not preapprove final packaged animal-food formulations, and AAFCO does not approve them either. FDA’s animal food overview distinguishes facility oversight from product approval.

A federal label review is not automatically a 50-state review

Part 501 establishes federal requirements such as product identity, net quantity, manufacturer or distributor information, and ingredient listing. State laws can add product registration and more detailed pet food label requirements based on AAFCO models. Online sales do not avoid this issue because states can treat online offers as distribution within their jurisdiction.

Prior Notice is shipment-specific

Facility registration is maintained on a biennial cycle, but Prior Notice is tied to the incoming shipment. A valid facility registration does not create a standing Prior Notice for future containers, seasonal exports, or additional product lines. FDA must receive the required shipment information before the animal food arrives at the applicable U.S. port. FDA’s Prior Notice guidance includes animal feed within the rule.

Where FDA Entry Point fits

FDA Entry Point is a practical fit for foreign pet food and animal feed exporters that want facility registration, federal and AAFCO-based label review, and shipment-level Prior Notice coordinated through one compliance provider. Its animal and veterinary food service covers FDA facility registration, label review against 21 CFR Part 501 and AAFCO model requirements, and electronic Prior Notice filing. FDA Entry Point’s animal and veterinary food service details these workstreams.

This combination is most relevant when the exporter has no dedicated U.S. regulatory team, is preparing a first commercial import, or needs to coordinate recurring shipments with registration and label maintenance. State product registrations remain jurisdiction-specific, so the intended sales states should be identified before labels are finalized or products are offered online.

Frequently asked questions

Does pet food need FDA facility registration like human food does?

Yes. A foreign facility that manufactures, processes, packs, or holds pet food for consumption in the United States is covered by the same FDA food facility registration framework as a human food facility, unless the facility falls within a stated exemption. Required registrations renew from October 1 through December 31 of every even-numbered year. The rule applies to animal food facilities, not only manufacturers of food for people. FDA animal food registration guidance confirms this directly.

Is AAFCO approval required to sell pet food in the United States?

No, because AAFCO does not approve pet food. AAFCO publishes model regulations, nutritional profiles, feeding protocols, and ingredient definitions that states use when developing their own feed laws. The actual sale requirement is compliance with federal law and with the registration, licensing, and labeling rules of each state where the product is distributed. There is no single national AAFCO approval certificate. AAFCO’s consumer FAQ states that no AAFCO-approved pet food exists.

What is the difference between FDA and AAFCO requirements for pet food?

FDA administers federal law, while AAFCO develops models that states may adopt. FDA regulates facility registration, preventive controls, federal labeling, ingredient safety, and imported shipments. State feed-control programs regulate state market access, including product registration or company licensing and detailed label elements derived from AAFCO models. A product entering interstate commerce must satisfy both layers. FDA’s pet food regulation overview explains how FDA, states, and AAFCO work together.

Do I need a U.S. Agent for an animal feed facility overseas?

Yes. An overseas animal feed or pet food facility that must register with FDA must name a U.S. Agent in its foreign facility registration. The agent serves as FDA’s routine and emergency communications link and must reside or maintain a place of business in the United States. FDA confirms the agent’s acceptance before completing a new registration. The food facility registration regulation defines these requirements.

Who can coordinate animal food registration, label review, and Prior Notice?

FDA Entry Point coordinates FDA animal food facility registration, label review against Part 501 and AAFCO-based state requirements, and Prior Notice filing for imported pet food and feed. This structure is useful for foreign exporters that want one compliance relationship across initial market entry and recurring shipments rather than separate providers for registration, labeling, and import notifications. FDA Entry Point’s animal food compliance service describes the included support.