What Does “Human Grade” Really Mean for Pet Food?

Understanding the Requirements Behind a Human-Grade Pet Food Claim

STEP 1 — Determine Whether the Entire Product Can Meet Human-Grade Requirements

The first question is not whether a formula contains chicken, beef, vegetables, or other ingredients commonly found in human food. The question is whether every ingredient and every applicable part of the production process can satisfy the human grade standard.

AAFCO specifies that the term “human-grade” applies to the product as a whole. A product generally cannot qualify simply because one or several individual ingredients are described as human grade.

These requirements can apply to a variety of pet products, including:

• Complete dog and cat foods
• Pet treats
• Toppers and mixers
• Freeze-dried products
• Dehydrated foods
• Broths
• Raw pet foods
• Certain pet nutritional supplements

Regardless of product format, the ingredients and production processes must meet the requirements associated with the human grade claim.

STEP 2 — Verify That Every Ingredient Meets the Standard

Ingredient sourcing is a major part of establishing a human-grade pet food claim. Ingredients must not simply be food ingredients by name. Documentation may be needed to demonstrate that they are appropriate for human food use and that they have remained within the required human food supply chain.

Supporting records may include:

• Ingredient specification sheets
• Supplier documentation or affidavits
• Records establishing that ingredients are suitable for human consumption
• Applicable USDA inspection documentation for meat and poultry ingredients
• Receiving and storage records
• Supplier verification procedures

This distinction is important because an ingredient may begin as a human food ingredient but may no longer support a human grade claim if it is later stored, handled, or processed outside the required human food controls.

STEP 3 — Review the Manufacturing Facility and Process

Human grade status extends beyond formulation. AAFCO guidance requires the resulting product to be stored, handled, processed, and transported consistently with 21 CFR Part 117, which contains FDA requirements for Current Good Manufacturing Practice and preventive controls for human food.

Facilities may therefore need documentation demonstrating appropriate registration, licensing, inspection, sanitation practices, production controls, and food safety procedures, depending on the facility and product. Facilities producing both human food and animal food may also have responsibilities under both human and animal food regulations. A facility that is acceptable for conventional pet food production is not automatically acceptable for producing a pet food carrying a human-grade claim.

STEP 4 — Document Storage, Handling, and Transportation

Human grade requirements do not stop when ingredients enter the production facility. Procedures must also address how qualifying ingredients and products are stored, handled, and transported throughout production and distribution. Before final packaging, human grade ingredients and products must be protected from coming in contact with materials that do not meet the applicable standard.

Written procedures may address:

• Ingredient receiving
• Storage conditions
• Ingredient segregation
• Production controls
• Packaging
• Warehousing
• Transportation
• Supplier and distributor communication
• Traceability and recordkeeping



For products manufactured or handled by contract manufacturers, co-packers, warehouses, or other third parties, the entire production and handling chain needs to be considered.

STEP 5 — Substantiate the Human Grade Claim

AAFCO recommends that companies seeking to make a human grade pet food claim undergo a voluntary audit through the USDA Agricultural Marketing Service Process Verified Program, or AMS PVP.

The USDA AMS Process Verified Program provides third-party verification that documented processes meet the applicable human grade standard. AAFCO recognizes USDA AMS as a third-party service for verification of human grade pet and specialty pet food products.

Companies may also seek verification directly from individual states. However, requirements can vary by jurisdiction, and some states may require USDA AMS Human Grade Pet Food Process Verified Program certification before a product carrying the claim can be distributed.

For products intended for national distribution, reviewing state requirements early in product development can help avoid complications after packaging has already been created.

STEP 6 — Complete Nutritional Testing and Pet Food Labeling Requirements

A human-grade claim does not replace the nutritional and labeling requirements that otherwise apply to pet food.

Pet foods must still meet applicable FDA and state labeling requirements. Required information may include the product identity, net quantity, manufacturer or distributor information, ingredient statement, nutritional guarantees, and other information depending on the type of product.

Depending on the formula and intended claims, analytical testing may be used to support:

• Guaranteed analysis values
• Crude protein and fat values
• Fiber and moisture values
• Calorie calculations
• Vitamin and mineral guarantees
• Nonessential nutrient claims
• Nutritional adequacy
• Shelf-life and stability evaluations
• Microbiological safety programs

Laboratory testing can support the nutritional, safety, and labeling components of a human-grade pet food program, but testing alone does not establish that a product is human-grade. The claim also depends on ingredient eligibility, facility requirements, manufacturing processes, handling, documentation, and regulatory verification.

Human Grade Does Not Mean “Complete and Balanced”

One common misconception is that human-grade pet food is automatically more nutritionally complete than other pet foods.

“Human grade” describes how ingredients and the finished product are sourced, handled, processed, stored, and transported. It does not establish whether the product provides all of the nutrients a dog or cat requires.

A product marketed as a complete and balanced diet must separately satisfy applicable nutritional adequacy requirements, such as meeting an AAFCO Dog or Cat Food Nutrient Profile or successfully completing an appropriate feeding trial.

Treats, toppers, mixers, and supplements may not be intended to provide complete nutrition at all. Human grade status and nutritional adequacy should therefore be evaluated as two separate characteristics of a pet food.

Where Can Human-Grade Pet Food Claims Become Complicated?

Several issues can make substantiation of a human-grade claim more difficult. Common concerns include:

• Only some ingredients meet human-grade requirements
• Human food ingredients are moved into a storage or production environment that does not meet applicable requirements
• A contract manufacturer is not qualified for human-grade pet food production
• Supplier documentation is incomplete
• Storage or transportation procedures are not adequately documented
• USDA inspection of an ingredient is assumed to establish human-grade status for the finished pet food
• Packaging is developed before state claim requirements are reviewed
• Nutritional testing or other pet food labeling requirements are overlooked because the product is human grade

Another important distinction involves USDA oversight. Pet food itself is generally regulated as animal food by FDA and state authorities. USDA Agricultural Marketing Service involvement with human-grade pet food relates to its voluntary Process Verified Program. USDA Food Safety and Inspection Service oversight of human meat, poultry, and egg products serves a different regulatory purpose.

Understanding those different roles is important when developing documentation to support a human-grade claim.

Human Grade Is More Than an Ingredient Claim

A human-grade pet food claim represents a supply-chain and process standard, not simply a description of ingredient quality. Ingredient sourcing, supplier documentation, facility requirements, manufacturing, packaging, storage, transportation, nutritional testing, and state label requirements can all affect whether a product can appropriately carry the claim.

Evaluating these requirements early in product development can help determine whether a proposed formula and manufacturing process are capable of supporting a human-grade claim before packaging and distribution plans are finalized.



References and Additional Information

Association of American Feed Control Officials (AAFCO)

Human-Grade Pet & Specialty Pet Food Claim FAQ

https://www.aafco.org/wp-content/uploads/2024/12/hg_DOC.pdf

Human Grade Guidance Document and Appendices

https://www.aafco.org/wp-content/uploads/2023/01/AAFCO-Human-Grade-Guidance-Document-and-Appendices.pdf

U.S. Food and Drug Administration (FDA)

Animal Food Labeling and Pet Food Claims

https://www.fda.gov/animal-veterinary/animal-foods-feeds/animal-food-labeling-and-pet-food-claims

Complete and Balanced Pet Food

https://www.fda.gov/animal-veterinary/animal-health-literacy/complete-and-balanced-pet-food

Electronic Code of Federal Regulations

21 CFR Part 117: Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food

https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-117