ECFR pet food labeling AAFCO

AAFCO nutritional adequacy statements are governed by AAFCO Model Regulations PF4/PF5 (adopted at state level), not by a "Section 4.2 of 21 CFR 501" — FDA's 21 CFR 501 contains no life-stage statement rules. Under Regulation PF5, every complete pet food must carry one of the verbatim statements: "(Name of product) is formulated to meet the nutritional levels established by the AAFCO Dog (or Cat) Food Nutrient Profiles for ___" or "Animal feeding tests using AAFCO procedures substantiate that (Name of Product) provides complete and balanced nutrition for ___" (plus the product-family variant "comparable in nutritional adequacy to a product which has been substantiated using AAFCO feeding tests"). The recognized life-stage categories are four: gestation/lactation, growth, maintenance, and all life stages — there is no AAFCO "senior" life stage in the 2024 Model Regulations. Dog foods claiming growth or all life stages must additionally state verbatim either "including growth of large size dogs (70 lb. or more as an adult)" or "except for growth of large size dogs (70 lb. or more as an adult)". Products not meeting PF4 requirements (treats, snacks, supplements, food mixers) must not make adequacy claims and instead bear the statement "This product is intended for intermittent or supplemental feeding only."