Human-grade, grain-free, holistic — three pet-food terms with no shared rulebook
Not every pet-food claim is defined the same way — some are tightly constrained, some are merely unregulated, and at least one is undefined in every market covered. This piece maps the status of three frequently seen terms.
Human grade — defined in the US, prohibited in Korea
In the US, "human grade" is acceptable only in reference to the product as a whole: every ingredient and the finished product must be stored, handled, processed and transported in a manner compliant with 21 CFR part 117. A pet food made in an animal-food facility under 21 CFR part 507 (not part 117) does not meet the term even if every ingredient is human-edible; ingredient-level "human grade" claims are not recognised, and false labelling is misbranded under FDCA §403(a).
Korea takes the opposite tack: expressions such as "human-edible food" or "made with human-edible ingredients" are prohibited unless the manufacturer can prove the product meets food-related legal standards (MAFRA Art. 14.d).
Grain-free — a term, not a definition
"Grain-free" is not an AAFCO-defined term. The US FDA's July 2018 investigation into diet-associated dilated cardiomyopathy (DCM) targeted products "many labeled as 'grain-free,' which contained a high proportion of peas, lentils, other legume seeds (pulses)" — over 90% were grain-free and 93% contained peas and/or lentils — but this is observational context, not a definition. The EU has no FEDIAF-defined grain-free rule either. China does not define "grain-free"; it recognises 无麸质 (gluten-free) at ≤20 mg/kg as a negative claim, which is a different thing.
Holistic — undefined everywhere
Across all five jurisdictions (US, EU, CN, CA, KR), no first-hand source defines "holistic" for pet food. FDA defers labelling structure to AAFCO, which is silent; FEDIAF has no holistic rule; China, Korea and Canada have no holistic definition in the in-repo material. "Holistic" is an unregulated marketing term in every covered market — an honest gap, not a retrieved definition.
Why this matters
A claim's legal weight depends entirely on where it sits: human-grade is a whole-product compliance test in the US but a prohibition in Korea; grain-free is a descriptor with no standard; holistic carries none at all. Buyers comparing labels across borders should read each term against the market that issued it.
Sources
label_claim_matrix— five-term × five-jurisdiction claim-definition crosswalk; the "human grade", "grain-free", and "holistic" per-term sections (US 21 CFR 117 / KR Art. 14.d; US FDA DCM + EU FEDIAF; all-jurisdiction holistic gap) are quoted verbatim from first-hand sources.