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ECFR human grade claims

ECFR_human_grade_claims

ecfr 240 tok en 2026-07-19

'Human grade' claims on US pet food are governed by the AAFCO-defined feed term 'human grade' (AAFCO Human Grade standard, administered with USDA AMS), not by a stand-alone FDA regulation. Per the AAFCO standard: (1) the term is only acceptable in reference to the product AS A WHOLE โ€” ingredient-level 'human grade' claims are not recognized; (2) every ingredient and the resulting product must be stored, handled, processed and transported in a manner consistent and compliant with 21 CFR part 117 (Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food) and all other applicable federal human food law. The earlier citation of '21 CFR 110 human food cGMP' is outdated: FSMA replaced part 110 with part 117, and part 110 was removed effective September 17, 2018. In August 2015 FDA announced it would no longer offer pre-market review of human-grade claim documentation, leaving substantiation to state feed control programs applying the AAFCO feed term; USDA's Agricultural Marketing Service offers Human Grade Pet Food certification under its Process Verified Program (PVP), and some states require AMS PVP certification before distribution. A pet food manufactured in an animal-food facility under 21 CFR part 507 (not part 117) does NOT meet the feed term, even if every ingredient is human-edible; false or misleading 'human grade' labeling renders a product misbranded under FDCA ยง403(a) (21 U.S.C. 343(a)(1)). No 'FDA 2023 guidance' on human-grade pet food claims exists in project sources.

Sources

  • AAFCO Human Grade Standards (AMS) via Tavily 2026-07-19 (aafco.org PDF snippets: product-as-a-whole; 21 CFR part 117 compliance)
  • eCFR 21 CFR part 117 (part 110 removed 2018-09-17) via Tavily 2026-07-19
  • 21 U.S.C. 343(a)(1) misbranding (uscode.house.gov) via Tavily 2026-07-19