Freeze-Dried Pet Food

Freeze-Dried Pet Food : Testing and Labeling Requirements

Freeze-dried pet food has moved well beyond niche status. Once limited to specialty raw diets and premium treats, freeze-dried formats are now common across complete diets, toppers, and functional snacks. This growth brings opportunity, but it also comes with a distinct set of food safety, testing, and labeling considerations that differ in important ways from traditional kibble or canned products.

How is Freeze-Dried Pet Food Different?

Freeze-dried pet food is made by removing moisture from ingredients through sublimation, a low-temperature process that preserves structure, flavor, and nutrients while creating a shelf-stable product with very low water activity. This low moisture environment limits microbial growth, but it does not kill pathogens that may already be present. Unlike extruded kibble or canned pet food, most freeze-dried pet foods do not include a validated lethality step such as high heat or retorting. As a result, freeze-dried products require a different food safety approach. Rather than relying on processing to eliminate hazards, manufacturers must place greater emphasis on raw material quality, supplier verification, sanitation, environmental monitoring, and finished product testing to manage risk throughout production and distribution.

Regulatory Oversight and Expectations

Freeze-dried pet food falls under the same federal framework as other animal foods, overseen by the U.S. Food and Drug Administration. Products must not be adulterated or misbranded, and manufacturers are expected to follow preventive control principles under the Food Safety Modernization Act (FSMA). At the state level, most pet food regulations align with the model guidelines developed by the Association of American Feed Control Officials (AAFCO). These standards heavily influence labeling structure, product registration, and how claims are evaluated. Where freeze-dried products tend to draw additional attention is in their risk profile, particularly when marketed as raw or minimally processed.

Key Risk Points in Freeze-Dried Production

Understanding where risk enters the process helps clarify why testing expectations often differ from conventional pet foods.

Raw ingredient sourcing

Freeze-dried formulations frequently use raw meats, organs, eggs, and produce. These ingredients carry inherent microbial risk and place greater importance on supplier approval programs and incoming specifications.

Processing and freeze-drying

The freeze-drying step stabilizes the product but should not be treated as a pathogen reduction step unless it has been specifically validated, which is uncommon.

Post-dry handling

Breaking, portioning, blending, or coating after freeze-drying is one of the highest-risk stages. Low-moisture foods are especially vulnerable to recontamination if environmental controls are weak.

Packaging and storage

Moisture and oxygen ingress can compromise shelf life and safety. Even small increases in water activity can affect product stability over time.

Testing Requirements: How Freeze-Dried Differs from Conventional Pet Food

Manufacturers often rely on a validated kill step and use finished product testing as a verification tool for extruded kibble or canned foods. Freeze-dried products typically require a more proactive approach.

Common practices include:

• Finished product testing for pathogens of concern, most often Salmonella
• Environmental monitoring programs focused on post-process areas
• Supplier verification testing to confirm ingredient controls

Environmental monitoring is especially important in freeze-dried facilities because contamination introduced after drying can persist in low-moisture environments if not identified early.

Process Validation Considerations

Manufacturers producing freeze-dried raw diets should be cautious about implying pathogen reduction unless a validated intervention is in place. If additional steps such as high-pressure processing or antimicrobial treatments are used, they must be scientifically validated and documented. Absent a kill step, regulators expect manufacturers to demonstrate that hazards are controlled through preventive measures rather than assumed to be eliminated.

Shelf-Life and Stability Testing

Freeze-dried products are shelf-stable, but stability still needs to be demonstrated.

Typical testing programs include:

• Water activity verification to ensure levels remain below growth thresholds
• Moisture content monitoring over time
• Oxidative stability testing, especially for high-fat formulations
• Sensory evaluation to confirm texture, aroma, and palatability

Packaging integrity testing is also important, as seal failures or oxygen exposure can shorten shelf life even when water activity remains low.

Nutritional and Composition Testing

Freeze-dried products must meet the same nutritional substantiation requirements as other pet foods. Manufacturers must verify Guaranteed Analysis values through appropriate laboratory testing and maintain documentation demonstrating compliance with established nutrient profiles when products are labeled as complete and balanced. It is equally important to clearly differentiate complete diets from treats or toppers, both in formulation and on the label, to avoid misleading claims and ensure regulatory compliance.

Labeling Requirements and Common Pitfalls

All pet food labels must include core elements such as product identity, ingredient statement, Guaranteed Analysis, net quantity, manufacturer information, and appropriate feeding directions. Freeze-dried products introduce additional labeling sensitivities.

Raw and freeze-dried claims

Terms like “freeze-dried raw” should accurately reflect the process used. Claims should be consistent across packaging, websites, and marketing materials.

Handling and preparation instructions

Many freeze-dried foods require rehydration. Clear instructions for preparation, storage after opening, and safe handling help reduce misuse and regulatory risk.

Claims that draw scrutiny

Statements such as “pathogen-free,” “human-grade,” or implied safety guarantees can create compliance issues if they are not carefully substantiated.

Treat vs complete diet clarity

Freeze-dried toppers and treats should not imply complete nutrition unless the product has been formulated and substantiated accordingly.

Documentation and Inspection Readiness

Because freeze-dried pet food relies more on controls than on processing lethality, documentation becomes especially important.

Manufacturers should maintain:

• A clear hazard analysis explaining how risks are controlled
• Supplier approval and verification records
• Sanitation and environmental monitoring logs
• Batch records with traceability from ingredient receipt through packaging
• Testing plans with defined acceptance criteria and corrective actions
• Recall and traceability procedures that are tested periodically

Freeze-dried pet food offers manufacturers a compelling way to meet consumer demand for minimally processed, premium products. At the same time, it requires a thoughtful approach to testing, labeling, and documentation that reflects its unique risk profile.