ATLANTA — Following several months of regulatory uncertainty in the pet food industry, the American Feed Industry Association (AFIA) and Association of American Feed Control Officials (AAFCO) shared several critical updates at the 2025 Pet Food Conference, Jan. 28 in Atlanta. 

Leah Wilkinson, vice president of public policy and education at the AFIA, and Austin Therrell, executive director of the AAFCO, discussed several regulatory topics, including new policies for manufacturers to prevent animal diseases and a new ingredient pathway. 

 

HPAI raises the alarm

Leah Wilkinson, vice president of public policy and education at the AFIA, presenting at the 2025 Pet Food Conference

Leah Wilkinson, vice president of public policy and education at the AFIA, presenting at the 2025 Pet Food Conference.

| Source: Sosland Publishing Co.

Wilkinson first took the stage, providing an update on the threat of highly pathogenic avian influenza (HPAI). Traditionally a wild bird disease, the virus has made the leap over the past couple years to mammals. According to Wilkinson, the disease has shown up in dairy cows, skunks, field mice, raccoons, dolphins, zoo animals (including polar bears, tigers and lions), foxes and the latest — domestic cats. The H5N1 strain of the virus poses particularly dangerous towards felines, with many who have contracted the virus experiencing severe illness and even death. Dogs are also able to contract the virus, however, they usually exhibit mild signs and low mortality compared to cats. 

Toward the end of 2024, the Oregon Department of Agriculture discovered a pet cat died from contracting the virus after consuming raw cat food that tested positive, leading to a recall. Later, the Los Angeles County Department of Public Health discovered several cats that had also tested positive for the virus after consuming raw pet food. 

Following this, the US Food & Drug Administration (FDA) is now requiring pet food manufacturers to reanalyze their food safety plans to include HPAI as a hazard. According to Wilkinson, this is the first time the FDA is invoking this part of the Food Safety Modernization Act (FSMA) regulations. 

“If you use uncooked or unpasteurized poultry or cattle products, you must reanalyze your food safety plan,” Wilkinson shared. “Specifically, the H5N1 strain should be considered a known or reasonably foreseeable hazard in your food safety plan.”

Though the FDA’s original announcement on this specifically mentioned manufacturers that use uncooked or unpasteurized ingredients derived from poultry or cattle, Wilkinson believes this extends far beyond to include all dog and cat food manufacturers and ingredient suppliers. 

According to Wilkinson, it has yet to be determined how soon this reanalysis needs to be done, but the current estimation is around 90 days for validation. 

“I would advise you to not wait, get working on this especially if you have multiple facilities, suppliers,” she said. “You don’t have to have it done tomorrow, but don’t wait and don’t delay. The FDA will come check during inspections… they’re going to look specifically for your reanalysis.”

 

The ingredient pathway 

Wilkinson then provided a brief update on the latest news on the animal food ingredient pathway. The issue first emerged last August, when the FDA announced it would not renew its Memorandum of Understanding (MOU) with AAFCO that outlines the regulatory process for new animal nutrition ingredients. Following expiration of the MOU in October, the FDA introduced its new Animal Food Ingredient Consultations (AFIC) and the AAFCO introduced its new process with Kansas State University Olathe (K-State Olathe). 

Prior to the expiration of the MOU, there were three ingredient approval pathways: the AAFCO-FDA process, the FDA generally recognized as safe (GRAS) notification, and the FDA food additive petition process. Now, with the new FDA and AAFCO processes, the industry has four different processes. 

According to Wilkinson, the FDA’s new AFIC process is currently open. 

“It is meant to essentially replace the old AAFCO ingredient pathway,” she said. “The data that is required for submission is very similar to what was required through AAFCO submission. It does add more transparency to the process. The FDA will have a public-facing website where they will post once you have made a submission through AFIC and started the consultation. Then once they have finished the consultation, they will post the final determination.”

A new piece to this, different from the GRAS and food additive petition, is a comment period. Through the AFIC process, the FDA will take comments for 60 days, accepting scientific data regarding the safety of the ingredients. 

Austin Therrell, executive director of AAFCO, presenting at the 2025 Pet Food Conference

Austin Therrell, executive director of AAFCO, presenting at the 2025 Pet Food Conference.

| Source: Sosland Publishing Co.

Moving to AAFCO’s new ingredient process, Therrell took a deep dive into the association’s current plans for the process with K-State Olathe. The process will begin with an AAFCO Investigator review, which is expected to take 30 days, followed by a review from a panel of subject-matter experts led by K-State Olathe, which is expected to take 60 to 90 days. The panel will then make a recommendation. The ingredient will then pass on to the association’s Ingredient Definitions Committee, then the board of directors, and finally to general membership approval. 

According to Therrell, this process is estimated to decrease ingredient review time by half. 

“With an ideal submission within this new process, we’re looking at a potential pathway to bring new, innovative ingredients to the market in about nine months versus 18,” he shared.

Through this process, there will be three tiers for submission, each costing a fee:

  • Basic Scientific Reviews will be for the modification of an AAFCO definition that requires a scientific review from at most two subject-matter experts. These reviews will cost $10,000.
  • Full Submission Package will allow for data for one to two animal species and a minimum of two subject-matter experts. These reviews will cost $25,000.
  • Expanded Submission Package will include data for three or more animal species and a minimum of three subject-matter experts. These reviews will cost $35,000. 

Additionally, AAFCO plans to charge an additional $5,000 per subject-matter expert if additional ones are needed. 

“Essentially, this offers an ability to bring ingredients to the market with a lot more flexibility than what we had previously under some of the old regulatory pathways,” Therrell said. 

To help in creating this process, the association will be creating a Steering Committee of industry members. The committee will provide insight on new procedures to select subject-matter experts, figure out extra panel fees, provide guidance on how potential conflict of interest can be avoided and more. 

According to Therrell, AAFCO plans to have this new process up and running by the third quarter of this year. 

 

Additional AAFCO updates

In addition to the new ingredient approval process, Therrell also shared other updates from the association’s Mid-Year meeting held earlier this year. 

The biggest update from the meeting includes the approval of ingredients including dried mealworm meal and dried crickets for use in adult dog food, Black Soldier Fly Larvae (BSFL) oil for use in adult cat food, clam meal, shellfish and alligator. Additionally, the association updated the calcium/phosphorus ratios in the AAFCO Cat Food Nutrient Profile. 

The association also established the Technical Assistance Network (TAN), a new mechanism on AAFCO’s website to help industry members with regulatory interpretation. 

Lastly, Therrell provided an update on AAFCO’s position on the PURR Act 2025, which was reintroduced earlier this year, expressing concern about the legislation.  

“AAFCO will continue, as we go through this year, to speak out against this piece of legislation,” Therrell said. “We realize as an association that we are not perfect. When we look at the regulatory system across the United States, there are a lot of improvements that still need to be made… So, I say that knowing that there are issues that exist, but we don’t believe federal legislation is the way to address this issue. 

“When consumers find out that this bill wants to take authority away from state regulators and hand it over the FDA to retroactively try and enforce, I think consumers will find that to be very off putting,” he detailed. “Consumers want oversight, and they want transparency, and that’s what we strive to do.

“When we look at the regulatory system, we have to balance it out by not being overly burdensome while supporting innovation, the ability to bring new ingredients into the marketplace, and clear guidance to make marketing claims,” Therrell added. “We want to promote that within the industry and there’s a smart, efficient way to do that with state regulation.”

Read more of our coverage from the 2025 Pet Food Conference