FDA guidance preserves use of AAFCO-defined ingredients in animal food products

October 24, 2024 - The American Feed Industry Association (AFIA) thanked the Food and Drug Administration (FDA) for publishing final guidance that will allow animal food manufacturers to continue using ingredients, previously reviewed for safety and published in the 2024 Association of American Feed Control Officials' (AAFCO) official Publication, in products sold in interstate commerce. The AAFCO Official Publication is the main resource state and international regulators use for ensuring domestic and global acceptance of safety for animal food ingredients, so without the FDA's nod, the use of hundreds of ingredients could have been at risk for sale within the United States.

AFIA President and Chief Executive Officer Constance Cullman issued the following statement: "We are encouraged by the FDA Center for Veterinary Medicine's decision to formally recognise the safety of hundreds of AAFCO-defined animal food ingredients, ensuring there is no question about their ability to be used or marketed within the United States and internationally. This decision is crucial for maintaining stability and confidence in our regulatory system, especially after the FDA recently ended its longstanding partnership with AAFCO on the review of new animal food ingredients.

"Before moving forward, we will encourage the agency to accept the last ingredients completing their reviews under the prior FDA-AAFCO memorandum of understanding, which will be listed in future editions of the AAFCO Official Publication. Our members are also engaged in providing the FDA feedback on its additional efforts to modernise the existing and proposed regulatory review systems so that animal food ingredient innovators can not only bring their products to the US marketplace in a timely, efficient manner but compete with our competitors' modernised regulatory systems."

As of October 1, the FDA's and AAFCO's longstanding memorandum of understanding for reviewing new animal food ingredients officially ended, removing one of three regulatory review systems currently utilised by animal food innovators when bringing new products to market. The move raised concerns from the animal food industry on how the FDA would treat ingredients previously approved through AAFCO, rather than the FDA's Generally Recognised as Safe or Food Additive Petition processes. The FDA's guidance acknowledged that it would not tae enforcement action against manufacturers that use ingredients listed in the 2024 AAFCO Official Publication, provided they remain safe for the intended species, are used according to their intended uses, specifications and limitations and are listed under the official common and usual names chapter of the AAFCO Official Publication.

Given that animal food innovators could submit ingredients for review up until September 1, 2024, there are many ingredients still awaiting review through the AAFCO review process, a process that lasts several months to years. The US animal food industry encourages the FDA to update its guidance annually to accept future editions of the AAFCO Official Publication to be inclusive of all ingredients that have utilised this pathway.

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