Most every state has a law governing the labeling of
pet foods. This is what Pennsylvania has for it's Pet
Food Labeling Law. Most states are similar, but check
the internet for your state for specifics.
CHAPTER 72. PET FOOD
The provisions of this Chapter 72 issued under the
Pennsylvania Commercial Feed Law of 1966 (3 P. S.
§ § 58.1—58.16) (Repealed), unless otherwise noted.
The provisions of this Chapter 72 adopted June 29, 1972, 2
Pa.B. 1330, unless otherwise noted.
§ 72.1. Definitions.
The following words and terms, when used in this Chapter, shall
have the following meanings, unless the context clearly indicates
Act—The Pennsylvania Commercial Feed Law of 1966 (3 P. S.
§ § 58.1—58.16) (Repealed).
Immediate container—The unit, can, box, tin, bag or other
receptacle or covering in which a pet food is displayed for sale
Ingredient statement—A complete listing on the label of the
ingredients of which the pet food is composed.
Principal display panel—That part of a label on an immediate
container that is most likely to be displayed or examined under
normal and customary conditions of display for sale at retail.
§ 72.2. Label format.
(a) The following information shall be shown on the principal
(1) Statement of net content.
(2) Product name.
(3) The words ‘‘Dog Food,’’ ‘‘Cat Food’’ or similar
(b) The following information shall be shown either on the
principal display panel or elsewhere on the label and shall be
sufficiently conspicuous as to render it easily read by the
average purchaser under ordinary conditions of sale:
(1) Guaranteed analysis.
(2) Ingredients list.
(3) Listing of artificial color, drugs, and other additives,
(4) Directions for use, if a limited purpose food.
(5) Name and address of the manufacturer, packer or
§ 72.3. Statement of net content.
The declaration of net content shall be made in conformity with
the Fair Packaging and Labeling Act (15 U.S.C.A. § 1451 et
§ 72.4. Guaranteed analysis.
(a) The guaranteed analysis shall be stated in the following
(1) Crude protein (minimum).
(2) Crude fat (minimum).
(3) Crude fiber (maximum).
(4) Moisture (maximum).
(5) Any additional guarantees.
(b) The sliding scale method of expressing a guaranteed
analysis, such as ‘‘protein 15-18%,’’ is prohibited.
(c) The label of a pet food which is formulated as, and
represented to be, a mineral supplement shall include a guarantee
of all the minerals contained in the ingredient statement.
(d) Pet foods containing 5.0% or more mineral ingredients shall
include in the guaranteed analysis the minimum and maximum
percentage of calcium (Ca) and salt (NaCl) and the minimum
percentage of any added phosphorus (P) and iodine (I). Minerals
(except salt NaCl) shall be stated in terms of percentage of the
element when quantitatively guaranteed.
(e) The label of a pet food which is formulated as, and
represented to be, a vitamin supplement shall include a guarantee
of the minimum content of each vitamin contained in the
(f) Vitamin guarantees shall be stated in units or milligrams
per pound or parts per million, with the following exceptions:
(1) Vitamin E shall be stated in U.S.P. or International
(2) Vitamin A, other than percursors of vitamin A, shall be
stated in U.S.P. units.
(3) The compounds pyridoxine hydrochloride, choline chloride
and thiamine need not be stated in true vitamin units.
(g) Oils and concentrates containing vitamin A or vitamin D or
both may be additionally labeled to show vitamin contents in
units per gram.
(h) The term ‘‘d-pantothenic acid’’ may be used in stating the
pantothenic acid guarantee.
(i) The vitamin potency of pet foods distributed in container
smaller than one pound may be guaranteed in approved units per
(j) If the label of a pet food does not represent the product
to be either a vitamin or a mineral supplement, but does include
a table of comparison of a typical analysis of the vitamin,
mineral or nutrient content of the product with levels
recommended by a recognized animal nutrition authority, such
comparison may be stated in the units of measurement used by such
recognized authority. The statement, in a table of comparison, of
the vitamin, mineral or nutrient content shall constitute a
guarantee and need not be repeated in the guaranteed analysis.
§ 72.5. Ingredients statement.
(a) Each ingredient of the pet food shall be listed in the
ingredient statement in descending order of predominance by
weight and names of all ingredients in the ingredient statement
shall be shown in letters or type of the same size. Any
ingredient for which the Association of American Feed Control
Officials has established a name and definition shall be
identified by by the name so established. Any ingredient for
which no name and definition has been so established shall be
identified by the common or usual name of the ingredient. Brand
or trade names shall not be used in the ingredient statement.
(b) The term ‘‘dehydrated’’ shall precede the name of any
ingredient in the ingredient list that has been artificially
(c) No reference to quality or grade of an ingredient shall
appear in the ingredient statement of a pet food product label.
§ 72.6. Brand and product names.
(a) No flavor designation shall be used on a pet food label
unless the designated flavor is detectable by a recognized test
method, or is one the presence of which provides a characteristic
distinguishable by the pet. Any flavor designation on a pet food
label must either conform to the name of its source as shown in
the ingredient statement or the ingredient statement shall show
the source of the flavor. Distributors of pet food employing such
flavor designation or claims on the labels of the product
distributed by them shall, upon request, supply verification of
the designated or claimed flavor to the Secretary.
(b) The designation ‘‘100%’’ or ‘‘All’’ or words of similar
connotation shall not be used in the brand or product name of a
pet food if it contains more than one ingredient. Water
sufficient for processing, required decharacterizing agents, and
trace amounts or preservatives and condiments shall not be
considered ingredients for the purpose of this subsection.
(c) The terms ‘‘meat’’ and ‘‘meat byproducts’’ shall be used on
a pet food label only if the meat and meat byproducts are from
cattle, swine, sheep and goats.
(d) The name of the pet food shall not be derived from one or
more ingredients of a mixture to the exclusion of other
ingredients and may not be one representing any components of a
mixture of a pet food product unless all components or
ingredients are included in the name except as specified in
subsection (a), (e) or (f). If any ingredient or combination of
ingredients is intended to impart a distinctive characteristic to
the product which is significant to the purchaser, the name of
the ingredient or combination of ingredients may be used as a
part of the name of the pet food provided the following
(1) The ingredient or combination of ingredients is present
in sufficient quantity to impart a distinctive characteristic to
(2) It does not constitute a representation that the
ingredient or combination of ingredients is present to the
exclusion of other ingredients.
(3) It is not otherwise false or misleading.
(e) When an ingredient or a combination of ingredients derived
from animals poultry or fish constitutes 95% or more of the total
weight of all ingredients of a pet food mixture, the name or
names of such ingredients may form a part of the product name of
the pet food. Where more than one ingredient is part of such
product name, then all such ingredient names shall be in the same
size, style and color printing.
(f) If an ingredient or a combination of ingredients derived
from animals, poultry or fish constitutes at least 25% but less
than 95% of the total weight of all ingredients of a pet food
mixture, the name or names of such ingredient or ingredients may
form a part of the product name of the pet food only if the
product name also includes a primary descriptive term, such as
‘‘meatballs’’ or ‘‘fishcakes,’’ so that the product name
describes the contents of the product in accordance with an
established law, custom or usage or so that the product name is
not misleading. All such ingredient names and the primary
descriptive term shall be in the same size, style and color
(g) Contractions or coined names referring to ingredients shall
not be used in the brand name of a pet food unless it is in
compliance with subsection (a), (d), (e) or (f).
§ 72.7. Balanced and complete rations.
(a) The label of a pet food shall not contain an unqualified
representation or claim, directly or indirectly, that the pet
food therein contained, or a recommended feeding thereof, is or
meets the requisites of a complete, perfect, scientific, or
balanced ration for dogs or cats unless such product or feeding
meets one of the following requisites:
(1) If contains ingredients in quantities sufficient to
provide the estimated nutrient requirements for all stages of the
life of a dog or cat, as the case may be, which have been
established by a recognized authority on animal nutrition, such
as the Committee on Animal Nutrition of the National Research
Council of the National Academy of Sciences.
(2) It contains a combination of ingredients which when fed
to a normal animal as the only source of nourishment will provide
satisfactorily for fertility of male and female gestation and
lactation, normal growth from weaning to maturity without
supplementary feeding, and will maintain the normal weight of an
adult animal whether working or at rest and has had its
capabilities in this regard demonstrated by adequate testing.
(b) To the extent that the ingredients of the product provide
nutrients in amounts which substantially deviate from those
nutrient requirements estimated by a recognized authority on
animal nutrition, or in the event that no estimation has been
made by a recognized authority on animal nutrition of the
requirements of animals for one or more states of these animals
lives, the represented capabilities of the product in this regard
shall have been demonstrated by adequate testing.
§ 72.8. Limited purpose pet foods.
(a) The label of a pet food product which is suitable only for
intermittent or supplemental feeding or for some other limited
purpose shall either bear a clear and conspicuous disclosure to
that effect or contain specific feeding directions which clearly
state that the product should be used only in conjunction with
(b) Labels for products which are compounded for or which are
suitable for only a limited purpose may contain representations
that the particular pet food product or a recommended feeding
thereof is or meets the requisites of a complete, perfect,
scientific, or balanced ration for dogs or cats only in
conjunction with a statement of the limited purpose for which the
product is intended or suitable, for such as ‘‘a complete food
for puppies.’’ Such representations and the required
qualifications of purpose shall be juxtaposed on the same panel
and in the same size, style and color printing.
(c) Qualified representations for limited purpose pet food
products may appear on labels only if one of the following
(1) The pet food contains ingredients in quantities
sufficient to satisfy the estimated nutrient requirements
established by a recognized authority on animal nutrition, such
as the Committee on Animal Nutrition of the National Research
Council of the National Academy of Sciences for such limited or
(2) The pet food product contains a combination of
ingredients which when fed for such limited purpose will satisfy
the nutrient requirements for such limited purpose and has had
its capabilities in this regard demonstrated by adequate testing.
§ 72.9. Moisture limitation.
The maximum moisture in all pet foods shall not exceed 78% or
the natural moisture content of the constituent ingredients of
the product, whichever is greater. Pet foods such as those
consisting principally of stew, gravy, sauce, broth or juice
which are so labeled, may contain moisture in excess of 78%.
§ 72.10. Drugs and additives.
(a) An artificial color may be used in a pet food only if it
has been shown to be harmless to pets. The permanent or
provisional listing of an artificial color by the United States
Food and Drug Administration at 21 CFR Parts 8 and 9 as safe for
use, together with the conditions, limitations and tolerances, if
any, incorporated therein, shall be deemed to be satisfactory
evidence that the color is, when used, under the regulations,
harmless to pets.
(b) Prior to approval of a facility registration for pet foods
which contain additives, including drugs, other special purpose
additives or nonnutritive additives, the distributor may be
required to submit evidence to prove the safety and efficacy of
the pet food, when used according to directions furnished on the
label. Evidence of the safety and efficacy of a pet food is not
required under the following conditions:
(1) The pet food contains additives which conforms to the
requirements of Federal standards set forth at 21 CFR
121.101(a)—(h), or which are prior sanctioned or generally
recognized as safe for that use.
(2) The pet food itself is a drug as defined in section 3 of
the act (3 P. S. § 58.3) and is generally recognized as safe and
effective for use or is marketed subject to an application
approved by the United States Food and Drug Administration under
the provisions of sections 505 and 507 of the Food, Drug and
Cosmetic Act of 1938 (21 U.S.C.A. § § 355 and 357).
(c) The medicated labeling format recommended by Association of
American Feed Control Officials shall be used.
§ 72.11. Misrepresentations.
(a) A vignette, graphic or pictorial representation of a
product on a pet food label shall not misrepresent the contents
of the package.
(b) The use of the word ‘‘proven’’ in connection with label
claims for a pet food is prohibited unless scientific or other
empirical evidence establishing the claim is first submitted to
the Secretary for review.
(c) No statement may appear upon the label of a pet food which
makes false or misleading comparisons between that pet food and
another pet food.
(d) Personal or commercial endorsements are permitted on pet
food labels where said endorsements are factual and not otherwise
§ 72.12. Identification of producer.
(a) The label of a pet food shall specify the name and address
of the manufacturer, packer or distributor of the pet food. The
statement of the place of business shall include the street
address, if any, of the place unless the street address is shown
in a current city directory or telephone directory.
(b) If a person manufactures, packages or distributes a pet
food in a place other than his principal place of business, the
label may state the principal place of business in lieu of the
actual place where each package of the pet food was manufactured
or packaged or is to be distributed, if the statement is not
misleading in any particular.
§ 72.13. Outer containers or wrappers.
When a pet food is enclosed in an outer container or wrapper
which is intended for retail sale, the required label information
shall appear on the outside wrapper or container unless all of
the required label information is readily legible through
apertures or transparencies in the outside container or wrapper.
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