Finding the best route for Pet Food Label Modernization changes | USA

January 18, 2024

Pet food manufacturers face a high level of uncertainty surrounding state-level implementation of the new Model Regulations for Pet Food and Specialty Pet Food. The Association of American Feed Control Officials (AAFCO) has been meticulous in its planning, preparation, and guidance for Pet Food Label Modernization (PFLM). However, the responsibility for any necessary updates to legislation and regulation lies with state authorities. There’s likely to be a great deal of variation in how and when states respond, so navigating the six-year discretionary period will present challenges.

Pet Food Label Modernization: challenges for manufacturers

Most manufacturer difficulties related to PFLM will centre on logistical and technical matters. Some pet food companies have hundreds, even thousands, of labels to review across product portfolios encompassing food, treats, and nutritional supplements. Updating their design will be costly and time consuming. Some new requirements, such as the inclusion of data about dietary fiber in the nutrition facts box, may require laboratory analysis too.

While the new data and design requirements have been commanding a lot of attention, the print, distribution, and rollout of new labels may present a bigger challenge. Identifying the best point in time to introduce new labels, and whether to take a phased approach across product ranges and / or regions of the US, requires careful consideration.

Labels for existing portfolios are just one part of the equation. What about new products scheduled to launch during the discretionary period? Is it best to align with PFLM guidelines, or could inconsistent labeling across products from the same manufacturer confuse consumers?

Another technical challenge relates to smaller, individually packaged items. PFLM involves the use of intuitive graphics for handling and storage instructions, based on extensive consumer research conducted by AAFCO. The icons are clear and intuitive, but it won’t be easy to incorporate them into the design of smaller labels.

Stay tuned for insights

AAFCO is running a dedicated half-day workshop on PFLM for members and non-members on January 22, ahead of its 2024 Midyear Meeting. The workshop will outline useful information related to the nutrition facts box, intended use statement, ingredients, and handling and storage instructions. However, peer discussions at the Midyear Meeting are also likely to yield the valuable insights surrounding state-level implementation. Principal Regulatory Consultant Shannon Bryant-Spas will be representing TSG Consulting at the workshop and the main event. Please contact us if you are attending and would like to arrange a meeting with Shannon. Or stay tuned for further insights and updates from TSG on how to determine the best route for PFLM changes over the coming weeks.

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