Navigating Change as the FDA Reshapes the Future of Animal Food

Written by: Louise Calderwood and Leah Wilkinson   |   September 9, 2024

Animal Food, FDA, AAFCO

Change is inevitable in life and even “good change” requires a degree of effort to navigate successfully. How change impacts you is correlated to how you respond to it. Do you shy away? Do you embrace it? Or are you the type that prepares for change and then turns it into something even better than you anticipated for your life situation? Every opportunity differs, but hopefully you have learned some tips along the way, so change is not as scary every time you work through it.  

The U.S. animal food industry is currently undergoing significant changes for how new animal food ingredients are reviewed. In August, the Food and Drug Administration announced its intention to end its longstanding partnership with the Association of American Food Control Officials (AAFCO) on Oct. 1. Over several decades, hundreds of animal food ingredients have successfully completed FDA’s safety review under this memorandum of understanding, permitting them to safely enter the marketplace. For multiple reasons, the FDA is unable to continue the partnership and hence the upcoming change.  

While the American Feed Industry Association is disappointed this relationship is ending, we are appreciative of the FDA for not leaving the industry “high and dry” without a plan. The FDA realized the impact its decision would have on the animal food industry if this long-standing review pathway ended. The agency has drafted guidance for this transition and, today, the AFIA provided our feedback to make the new process even better.  

Let’s walk through it a bit… 

Q. What is going away?  

A. The current AAFCO ingredient review process with the FDA as the safety reviewer. Currently, the Food Additive Petition process and Generally Recognized as Safe (GRAS) notification process remain unchanged. 

Q. What is the FDA proposing to put in its place?  

A. The FDA is proposing a new consultation-based process, called the Animal Food Ingredient Consultation (AFIC), to be put in the AAFCO ingredient review process’s place. The FDA describes this new process in draft guidance for industry 294 as an interim process to support firms developing animal food ingredients, which would have otherwise utilized the AAFCO ingredient review process.  

Q. What happens to the ingredients that have gone through the AAFCO process and are defined in the AAFCO Official Publication?  

A. The FDA is proposing in draft guidance for industry 293 to continue providing enforcement discretion for animal food ingredients listed in the 2024 edition of the AAFCO Official Publication. This means that ingredients would be allowed to be marketed in interstate commerce without the fear of the FDA taking enforcement action on the ingredient so long as there are not safety concerns.   

Q. What is happening to AAFCO? 

A. The current ingredient review process at AAFCO will stop on Oct. 1. AAFCO is exploring a new process for the scientific review of new ingredients that would continue to flow through its committees and membership for ultimate approval. AAFCO is considering the possibility of the new process to recognize ingredients approved by the Canadian Food Inspection Agency and the European Food Safety Authority.  

AFIA’s take: 

In the comments submitted today, the AFIA provided suggestions to make the information on draft guidance for industry 293 and 294 clearer and assign expectations to ingredient submitters as well as to the FDA as the reviewer. In particular, the AFIA seeks to ensure that any ingredient that typically would have been reviewed as an AAFCO ingredient can utilize the new AFIC review process. The AFIA also asked the agency to accept future editions of the AAFCO Official Publication that will reflect all the ingredients completed under the MOU that have yet to be published. This will ensure a path to market for ingredients moving through review as the MOU ends. 

The greatest need is for the FDA to finalize these guidance documents as soon as possible so the industry can continue to provide innovative solutions for our animal agriculture and companion animal customers at home and abroad.  

Change is happening. Rest assured that the AFIA is here to make sure the change has minimal impact on our members and work toward an ingredient system that is better in the long run.