Understanding AAFCO Ingredient Listing Rules

The Association of American Feed Control Officials (AAFCO) sets clear guidelines for how ingredients must be presented on product labels. These rules are designed to ensure transparency, support regulatory compliance, and help consumers make informed choices about the products they purchase for their pets.

Below is an overview of the core AAFCO ingredient listing requirements.

1. All Ingredients Must Be Listed

Every ingredient in the formula, regardless of the amount, must appear on the product’s ingredient list. There is no allowable threshold below which an ingredient can be excluded entirely. Even trace amounts must be declared.

This requirement underscores the importance of maintaining precise formulation records and accurately translating these records into labeling statements. Omitting an ingredient, even unintentionally, may result in non-compliance.

2. Order Matters

AAFCO requires that ingredients be listed in a specific order based on their inclusion rate in the product prior to processing:

• Ingredients over 2%—These must appear in descending order by weight before processing.
• Ingredients at 2% or less—These may be listed in any order following the ingredients over 2%, unless they have a preservative function. In that case, specific labeling rules for preservatives must be followed.

In practical terms, the bulk of most pet food components, such as primary protein sources, grains, and legumes, appears first, with oils, supplements, and minor additives following.

3. Functional Ingredients

Functional ingredients, such as vitamins, minerals, preservatives, and flavorings, are usually included at levels well below 2%. While their percentage may be small, their impact is significant, whether it’s preserving shelf life, enhancing palatability, or providing essential nutrients. AAFCO requires that these ingredients always be listed, regardless of quantity. Their inclusion is not optional.

Example Application

Consider a formulation with the following composition:

• Chicken: 40%
• Brown rice: 30%
• Peas: 15%
• Salmon oil: 1.5%
• Vitamin mix: 0.5%

The correct ingredient statement would be: Chicken, Brown Rice, Peas, Salmon Oil, Vitamin Mix

The first three ingredients (over 2%) are listed in descending order. The last two ingredients (both under 2%) can be listed in any order following the major ingredients—yet they are still required to appear on the label.

Why Compliance Matters for Pet Food Manufacturers

Failure to comply with AAFCO ingredient listing rules can result in regulatory action, product recalls, or reputational damage. Moreover, accurate labeling supports consumer trust, aids veterinarians in making dietary recommendations, and ensures a level playing field in the competitive pet food market.

Key Points for Manufacturers

• Keep thorough and accurate formulation records.
• Follow descending order for ingredients over 2% by weight before processing.
• Include every ingredient, no matter how small the amount.
• Remember that functional ingredients must be declared, even at trace levels.

For more information about AAFCO ingredient labeling requirements, you can search the AAFCO site: https://www.aafco.org/